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                             July 26, 2023

       Brent Beal
       Chief Executive Officer
       ETX Park Fund #2, LLC
       203 East Main, Suite 200
       Nacogdoches, TX 75961

                                                        Re: ETX Park Fund #2,
LLC
                                                            Amendment No. 1 to
Offering Statement on Form 1-A
                                                            Filed June 28, 2023
                                                            File No. 024-12222

       Dear Brent Beal:

             We have reviewed your amended offering statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our May
1, 2023 letter.

       Amendment No. 1 to Offering Statement on Form 1-A

       Cover Page

   1.                                                   We note your response
to comment 1. Please clarify whether Thread Bank will be
                                                        holding funds in its
account until a certain minimum threshold has been met as it is not
                                                        clear from your
disclosure why you require an escrow arrangement.
 Brent Beal
FirstName  LastNameBrent
ETX Park Fund   #2, LLC Beal
Comapany
July       NameETX Park Fund #2, LLC
     26, 2023
July 26,
Page  2 2023 Page 2
FirstName LastName
Risk Factors, page 7

2.       We refer to your revised disclosure on page 11 regarding the first
position lien on the
         optioned property held by Austin Bank, and your statement that
approval of the sale of
         such property may be required of Austin Bank "prior to the execution
of the option."
         Please revise to discuss this risk in a separate risk factor, and also
expand your disclosure
         to describe the circumstances when Austin Bank may need to provide its
approval, and
         whether this requirement may depend on the amount of proceeds you are
able to raise.
No Guaranteed Preferred Return, page 7

3.       We acknowledge your revised disclosure in response to prior comment 3,
and note your
         statements that the Company may not generate sufficient cash flows to
distribute the
         preferred return of 7% to investors "on a regular basis or at all."
Please further revise to
         discuss the preferred return rate in light of the fact that you have a
limited history and no
         current operations, that your proposed operations involve the initial
purchase of property
         and construction of rental property, and that you may not raise
sufficient funds to begin
         the initial phases of your business plan.
4.       We note your revised operating agreement, but reissue comment 5 as we
are unable to
         locate responsive disclosure in your offering circular, and that your
offering circular
         continues to state that profits are to be allocated among Class A and
Class B members
         with reference to their Invested Capital. Please also revise to make
clear the order of
         allocation for the profits, so that investors understand when profits
might be allocated to
         the payment of their Preferred Return.
Officers and Significant Employees, page 22

5.       We acknowledge your revised disclosures in response to comment 4.
However, as
         previously stated, please revise the disclosure regarding the business
experience of Brent
         Beal and Brock Beal by discussing their experience in ETX Park Fund
#1, LP. In
         addition, to the extent applicable, please revise to discuss any
limitations with respect to
         the access road, and clarify if the optioned property is currently
landlocked. Please also
         revise in an appropriate section how access to the optioned property
will take place if the
         access road is not fully built, as we note your disclosure in the Use
of Proceeds section
         indicating that if you do not raise more than 50% of the maximum
offering amount, you
         anticipate that only half of the access road will be built.
General

6.       Please note that the offering statement also must be signed by your
principal accounting
         officer and governing body, and revise accordingly.
 Brent Beal
FirstName  LastNameBrent
ETX Park Fund   #2, LLC Beal
Comapany
July       NameETX Park Fund #2, LLC
     26, 2023
July 26,
Page  3 2023 Page 3
FirstName LastName
       You may contact Isabel Rivera at 202-551-3518 or Dorrie Yale at
202-551-8776 with any
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Real Estate &
Construction
cc:      Nicholas Antaki