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March 2, 2022
Abbott Cooper
Managing Member
Driver Management Company LLC
250 Park Avenue
7th Floor
New York, NY 10177
Re:REPUBLIC FIRST BANCORP INC
PRRN14A filed February 23, 2022
Filed by Driver Management Company LLC, et al.
SEC File No. 0-17007
Dear Mr. Cooper:
            We have reviewed your revised filing 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 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.
Revised preliminary proxy statement filed February 23, 2022
General
1.We refer to comment 1 in our prior comment letter dated February 7, 2022 and your
response. We continue to believe that each participant's plans for Republic First is
material information.  To the extent that participants do not have specific plans, please
disclose this fact in the revised proxy statement.  Please revise to describe, as previously
requested.
2.Refer to comment 2 in our prior comment letter dated February 7, 2022.  We continue to
believe that a participant's recent statements advocating for a sale of Republic First are
material and should be included in the proxy statement.  Your revised disclosure can
explain the circumstances under which those statements were made, and may limit their
scope with additional explanation.  Your statements (and explanation) may be particularly

 FirstName LastNameAbbott Cooper
 Comapany NameDriver Management Company LLC
 March 2, 2022 Page 2
 FirstName LastName
Abbott Cooper
Driver Management Company LLC
March 2, 2022
Page 2
helpful to shareholders, since after they were made, the Braca Group filed beneficial
ownership reports indicating that it has engaged a financial advisor to make contact with
Republic First's financial advisor.  Please revise your proxy statement, as previously
requested.
            We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please direct any questions to Christina Chalk at (202) 551-3263.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions