United States securities and exchange commission logo December 19, 2023 Yoshi Niino Chief Accounting Officer Harbor Custom Development, Inc. 1201 Pacific Avenue, Suite 1200 Tacoma, WA 98402 Re: Harbor Custom Development, Inc. Form 10-K for the Year Ended December 31, 2022 Filed March 31, 2023 File No. 001-39266 Dear Yoshi Niino: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Yoshi Niino FirstName LastNameYoshi Niino Harbor Custom Development, Inc. Comapany19, December NameHarbor 2023 Custom Development, Inc. December Page 2 19, 2023 Page 2 FirstName LastName Form 10-K for the Year Ended December 31, 2022 Item 9A. Controls & Procedures, page 68 1. Please amend your filing to provide management's annual report on internal control over financial reporting as of December 31, 2022; refer to Item 308(a) of Regulation S-K. In addition, given the omission of your annual report on internal control over financial reporting, tell us how you determined that your disclosure controls and procedures were effective as of December 31, 2022. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact William Demarest at 202-551-3432 or Mark Rakip at 202-551-3573 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction