United States securities and exchange commission logo





                              October 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. 4 to
                                                            Offering Statement
on Form 1-A
                                                            Filed October 23,
2023
                                                            File No. 024-12222

       Dear Brent Beal:

                                                        We have reviewed your
amended offering statement and have the following comment.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comment applies 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 this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our October 19, 2023
letter.

       Form 1-A filed October 23, 2023

       Risk Factors
       Potential Conflicts of Interest, page 11

   1.                                                   We acknowledge your
revised disclosures in response to prior comment 2 that any
                                                        amounts owed on the
Austin Bank lien above the purchase price in the option agreement
                                                        between ETX Park Fund
#1 and the Company will be paid for by ETX Park Fund #1.
                                                        Please further revise
your disclosures to reconcile this intention with your statement
                                                        in your risk factor
disclosure that "[t]he Company has no intention of exercising the option
                                                        if the Proceeds are not
sufficient to lift the lien held by Austin Bank." Please also add
                                                        disclosure on your
cover page regarding the conflicts of interest relating to your proposed
                                                        use of proceeds.
 Brent Beal
ETX Park Fund #2, LLC
October 26, 2023
Page 2

       Please contact Isabel Rivera at 202-551-3518 or Dorrie Yale at
202-551-8776 with any
questions.



                                                          Sincerely,
FirstName LastNameBrent Beal
                                                          Division of
Corporation Finance
Comapany NameETX Park Fund #2, LLC
                                                          Office of Real Estate
& Construction
October 26, 2023 Page 2
cc:       Nicholas Antaki
FirstName LastName