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CPI
AEROSTRUCTURES, INC.

91
Heartland Blvd.

Edgewood,
NY 11717

December
12, 2017

Melissa
Raminpour

Branch
Chief

Office
of Transportation and Leisure

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Re:
    CPI
    Aerostructures, Inc.

    Form
    10-K for the Year Ended December 31, 2016

    Filed
    March 8, 2017

    File
    No.: 001-11398

Dear
Ms. Raminpour:

CPI
Aerostructures, Inc. (the “Company”) responds as follows to the Staff’s comment letter, dated November 30, 2017,
relating to the above-captioned Form 10-K. Please note that, for the Commission Staff’s convenience, we have recited each
of the Staff’s comments and provided the response to each comment immediately thereafter.

Form
10-K for the Year Ended December 31, 2016 Filed March 8, 2017

Item
7. Management's Discussion and Analysis of Financial Condition and Results of Operations

Adjusted
Earnings, page 23

1. On
                                         pages 23 and 24, you present a full non-GAAP income statement when reconciling non-GAAP
                                         measures to the most directly comparable GAAP measures. Please be advised it is not appropriate
                                         to present a full non-GAAP income statement for purposes of reconciling non-GAAP measures
                                         to the most directly comparable GAAP measure. Please revise and reconcile without presenting
                                         a full non-GAAP income statement. See Question 102.10 of the updated Non-GAAP Compliance
                                         and Disclosure Interpretations issued on May 17, 2016.

In
response to your comment regarding non-GAAP measures, we acknowledge your comment and point out that we are no longer using or
disclosing non-GAAP measures in our filings. If, in the future, we disclose non-GAAP measures we will specifically prepare such
disclosure following the guidance provided in Question 102.10 of the updated Non-GAAP Compliance and Disclosure Interpretations
issued on May 17, 2016.

Securities
and Exchange Commission

Page
2

December
12, 2017

2. Please
                                         revise to disclose revenues from external customers for each product and service or each
                                         group of similar products and services in accordance with ASC 280-10-50-40. Also, in
                                         light of your disclosure on page 3 that you provide engineering, program management,
                                         supply chain management, and MRO services, please revise your statements of operations
                                         to present revenue from products and services separately if the amount related to these
                                         services is over 10%. Refer to Rule 5-03.1 of Regulation S-X.

In
response to your request to provide further detail on revenues which were generated from the products and services of the Company
based on FASB ASC paragraph 280-10-50-40, the Company respectfully believes further breakout of the “Segment Sales and
Other Operating Revenues” is not required. In reaching this conclusion, the Company considered the guidance related
to the segment aggregation criteria in ASC 280-10-50-11. Specifically, we note that our products are similar in nature, have similar
production processes, classes of customers and degree of risk and opportunities for growth.

Additionally,
in response to your comment that on page 3 we disclose that we provide engineering, program management and supply chain management
services, such services are only provided in conjunction with the production of an aerospace product. We do not provide such services
on a stand-alone basis as a separate revenue stream. In addition, revenues from external customers by service are not reviewed
by the Company’s Board of Directors or Chief Operating Decision Maker, and presentation of such data does not reflect the
way the Company’s business is managed.

Lastly,
MRO services comprise less than 1% of our revenue and are therefore not disclosed separately because they are immaterial.

*
* * * * *

Finally,
the Company acknowledges the following:

 ● The
                                         Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 ● Staff
                                         comments or changes to disclosure in response to staff comments do not foreclose the
                                         Commission from taking any action with respect to the filing; and

 ● The
                                         Company may not assert staff comments as a defense in any proceeding initiated by the
                                         Commission or any person under the federal securities laws of the United States.

Securities and Exchange Commission

Page
3

December
12, 2017

If
the Staff has any further questions or comments regarding the information in this letter, kindly contact the undersigned.

    Sincerely,

    By:
    /s/
    Vincent Palazzolo

    Chief
    Financial Officer