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October 17, 2023
James Britton
Executive Vice President and Chief Financial Officer
First Foundation Inc.
200 Crescent Court, Suite 1400
Dallas, Texas 75201
Re:First Foundation Inc.
Form 10-Q for the quarterly period ended June 30, 2023
Filed August 8, 2023
File No. 001-36461
Dear James Britton:
            We have conducted a limited review of your quarterly report and have the following
comments.
            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 a
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.
Form 10-Q for quarterly period ended June 30, 2023
Deposits, page 48
1.We note disclosure that as of June 30, 2023 you held $2.2 billion of brokered deposits,
mostly comprised of certificates of deposit, compared to $1.3 billion of brokered deposits
as of December 31, 2022 as disclosed on page 55 of your Form 10-K for the fiscal year
ended December 31, 2022. To the extent material, please revise future filings, beginning
with your September 30, 2023 Form 10-Q, to provide additional quantitative and
qualitative information explaining any material changes in your deposit base, such as
increased reliance on brokered deposits, and the related impact on your funding costs and
liquidity. Please also discuss any factors driving such an increase in utilizing brokered
deposits as a source of funding.  Please provide us with your proposed disclosures.
2.We note the discussion on page 23 of your Form 10-K for the fiscal year ended December
31, 2022 regarding the five largest bank depositors accounting for 20% of your total
deposits. Please revise future filings, beginning with your September 30, 2023 Form 10-Q,
to identify and describe significant concentrations in deposits or advise us why you

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First Foundation Inc.
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believe such disclosure is not important to an understanding of your liquidity and material
events and uncertainties. Please provide us with your proposed disclosures.
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Loans, page 48
3.We note your disclosure on page 21 of your Form 10-K for the fiscal year ended
December 31, 2022 indicating that your loans are geographically concentrated. Please
revise your Management's Discussion and Analysis in future filings, beginning with your
September 30, 2023 Form 10-Q, to address your geographic loan concentrations. Please
also revise future filings to disclose any significant loan concentrations subject to higher
credit risk and how you are managing the risk and exposure. In this regard, we note the
statement from your June 30, 2023 quarterly earnings call that you “have very little to no
exposure to construction, hotels or commercial office space.” Please provide us with your
proposed disclosures.
Liquidity, page 53
4.We note disclosure in separate sections of your filing regarding sources of liquidity (e.g.,
discussion of unused borrowing capacity on pages 28-29). Please revise future filings,
beginning with your September 30, 2023 Form 10-Q, to further clarify your available
sources of liquidity.  Consider including tabular disclosure, separately by type of
borrowing capacity and showing total borrowing capacity, less borrowings outstanding, to
arrive at remaining capacity and then adding other sources of liquidity (i.e. cash and cash
equivalents, securities) to arrive at total available liquidity. Please also discuss any
parameters to access any borrowing capacity, as applicable.  Please provide us with your
proposed disclosures.
Managements Discussion and Analysis of Financial Condition and Results of Operations
Liquidity, page 53
5.We note your disclosure that you monitor your liquidity in accordance with guidelines
established by your Board of Directors, as well as your reference to your disclosure in
your Annual Report on Form 10-K for fiscal year ended December 31, 2022.  We note
you state on page 61 of your Form 10-K that "The Board of Directors of FFB approves
policies and limits governing the management of interest rate risk" and that "The asset /
liability committee formed by these policies is responsible for monitoring our interest rate
risk and providing periodic reports to the Board of Directors regarding our compliance
with these policies and limits."  Please revise future filings to include a materially
complete description of how you seek to manage risks due to changes in interest rates and
other material impacts on your operational facts and circumstances, including any
management or corporate governance controls or procedures for identifying and
responding to rapid changes in interest rates due to or as a result of exogenous or
unknown factors. For example, please describe the Board of Directors' established

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First Foundation Inc.
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liquidity guidelines and the Board of Directors' approved policies and limits governing
management of interest rate risk. In addition, indicate whether you were in compliance
with the guidelines, policies and limits. If not in compliance, discuss any planned actions
to be taken to reestablish compliance.  Please revise your future filings, beginning with
your September 30, 2023 Form 10-Q, to include an enhanced discussion of your liquidity
policy guidelines and metrics used to manage your liquidity, such as different types of
funding or coverage ratios. Please also disclose compliance with each of these guidelines
and metrics, or in the event of non-compliance, disclose any planned actions to ensure
compliance.  Please provide us with your proposed disclosures.
Item 3. Quantitative and Qualitative Disclosures about Market Risk, page 56
6.We note your disclosure that there have been no material changes to your quantitative and
qualitative disclosures about market risk since December 31, 2022. Given the recent
banking industry issues, the current economic environment, and your continued net
interest margin compression during the three and six-months ended June 30, 2023 as
disclosed on pages 38-39, please revise future filings, beginning with your September 30,
2023 Form 10-Q, to provide material updates to your interest rate risk disclosures (i.e.
Gap Analysis, Net Interest Income Simulations, Economic Value of Equity Calculations)
similar to the disclosures provided in your Form 10-K for the fiscal year ended December
31, 2022. Please ensure that your revised disclosures include a discussion of the key
assumptions (e.g., future balance sheet composition, loan and deposit repricing,
assumptions related to the magnitude of asset prepayments, earlier than anticipated
deposit withdrawals, etc.) for each of these interest rate risk disclosures and a discussion
of any changes in these key assumptions from period to period along with the factors
driving these changes. Refer to Item 305(a)(1)(ii)(B) of Regulation S-K. Please provide us
with your proposed disclosures.
7.We note disclosure on page 61 of your Form 10-K for the fiscal year ended December 31,
2022 that the Board of Directors approves policies and limits governing the management
of interest rate risk and that the asset/liability committee formed by these policies is
responsible for monitoring your interest rate risk and providing periodic reports to the
Board of Directors regarding compliance with these policies and limits. Please revise
future filings, beginning with your September 30, 2023 Form 10-Q, to include a similar
discussion enhanced to include a more detailed description of such material policies, the
limits governing your management of interest rate risk, a discussion of the
material information the asset/liability committee gains from these analyses (i.e. Gap
Analysis, Net Interest Income Simulations, Economic Value of Equity Calculations), and
any limitations of using these analyses.  Additionally, to the extent there are significant
changes in the outputs from these analysis from period to period, please discuss the factors
driving the change(s). Please provide us with your proposed disclosures.
            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

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 Comapany NameFirst Foundation Inc.
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James Britton
First Foundation Inc.
October 17, 2023
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action by the staff.
            Please contact John Spitz at 202-551-3484 or Ben Phippen at 202-551-3697 if you have
questions regarding comments on the financial statements and related matters. Please contact
Todd Schiffman at 202-551-3491 or Susan Block at 202-551-3210 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance