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December 12, 2022
Raymond Lopez
EVP, Chief Operating Officer, Chief Financial Officer and Treasurer
Bluegreen Vacations Holding Corporation
4960 Conference Way North, Suite 100
Boca Raton, FL 33431
Re:Bluegreen Vacations Holding Corp
Form 10-K for the year ended December 31, 2021
Filed March 4, 2022
Form 10-Q for the quarterly period ended September 30, 2022
Filed November 3, 2022
File No. 001-09071
Dear Raymond Lopez:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the quarterly period ended September 30, 2022
Item 2. Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 29
1.We note your updated disclosures within Use of Estimates on page 10 and your
Cautionary Note Regarding Forward-Looking Statements on page 29 which highlight
some potential risks related to the adverse impact of economic conditions including,
among other things, impacts from rising interest rates.  Please revise your discussion to
specifically describe how increased interest rates impact your results of operations,
including:
•Expected changes to your product mix, including specific challenges or opportunities
a rising interest rate environment presents in the near-term to certain segments or
product lines, and the impact ongoing supply chain challenges or disruptions may

 FirstName LastNameRaymond Lopez
 Comapany NameBluegreen Vacations Holding Corporation
 December 12, 2022 Page 2
 FirstName LastName
Raymond Lopez
Bluegreen Vacations Holding Corporation
December 12, 2022
Page 2
have on your ability to make these changes;
•Expected decreases in sales volumes given consumer’s increased cost of financing;
•Changes to your pricing strategy in the near-term, including how you consider
customer sensitivity to price increases;
•Adjustments to your planned capital expenditures;
•Expected impacts to your short-term funding costs; and
•The impact on liquidity resulting from your variable-rate debt outstanding.
2.We note your disclosure throughout your filing about rising interest rates and inflation.
Please disclose any known trends or uncertainties that have had or are reasonably likely to
have a material impact on your cash flows, liquidity, capital resources, cash requirements,
financial position, or results of operations arising from, related to, or caused by the rising
interest rates and inflation. Trends or uncertainties may include the impact of interest rates
and inflation on cost of sales, gross profit, and inventory as well as decrease in demand for
VOIs, and increase in default and delinquency rates.
            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.
            You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at 202-551-3295 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction