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March 17, 2023
Joseph W. Turner
Chief Executive Officer
Ministry Partners Investment Company, LLC
915 West Imperial Highway, Suite 120
Brea, CA 92821
Re:Ministry Partners Investment Company, LLC
Post-Effective Amendment No. 4 to Registration Statement on Form S-1
Filed March 3, 2023
File No. 333-250027
Dear Joseph W. Turner:
            We have reviewed your post-effective amendment 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Post-Effective Amendment No. 4 to Form S-1 filed March 3, 2023
Risk Factors
We may face potential claims from certain holders of our 2021 Class A Notes, page 24
1.We note your response to comment 1 and reissue in part. It appears that the amount of
contingent liability related to this matter is $26.9 million. In your response letter you state
that the contingent liability is less than that amount, however, your rationale does not
appear to have a basis in Section 5 of the Securities Act. In this risk factor, please disclose
the contingent liability amount of $26.9 million related to your rescission
risk. Additionally, please reconsider the last sentence of this risk factor in light of the
$26.9 million contingent liability amount, as it appears from your response letter that this
sentence was based on a lesser amount. If you continue to believe that the last sentence of
this risk factor is correct in light of the $26.9 million contingent liability amount, please

 FirstName LastNameJoseph W.  Turner
 Comapany NameMinistry Partners Investment Company, LLC
 March 17, 2023 Page 2
 FirstName LastName
Joseph W.  Turner
Ministry Partners Investment Company, LLC
March 17, 2023
Page 2
provide us your analysis as to why this is the case.

            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 Robert Arzonetti at (202) 551-8819 or Tonya Aldave at (202) 551-3601
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Randy Sterns, Esq.