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April 19, 2024
Paul Langdale
Executive Vice President and Chief Financial Officer
Independent Bank Group, Inc.
7777 Henneman Way
McKinney, TX 75070
Re:Independent Bank Group, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-35854
Dear Paul Langdale:
            We have limited our review of your filing to the financial statements and related
disclosures 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-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Loan Portfolio, page 51
1.We note your disclosure on page 52 that commercial real estate (CRE) loans have
historically been your largest category of loans and that these loans "...generally involve
less risk than other loans in the portfolio." Please tell us and revise future filings to
identify these other loans and explain why they generally involve more risk than CRE
loans.
2.In your tabular disclosure on page 53 of your concentrations of CRE loans by property
type, we note that 30.4%, 18.6%, and 12.2% of your total CRE loans represented retail,
offices and office warehouses, and multifamily, respectively as of December 31, 2023.
We also note your disclosure on page 102 that at December 31, 2023, your CRE portfolio
consisted of approximately 21% of owner-occupied property (i.e., 79% was non owner-
occupied), that you track the level of owner-occupied property versus non owner-occupied
property, and that CRE loans may be more adversely affected by conditions in the real
estate market or in the general economy. Given that CRE loans have historically been

 FirstName LastNamePaul Langdale
 Comapany NameIndependent Bank Group, Inc.
 April 19, 2024 Page 2
 FirstName LastName
Paul Langdale
Independent Bank Group, Inc.
April 19, 2024
Page 2
your largest category of loans, please revise future filings to further disaggregate the
composition of your CRE loan portfolio to address other concentrations to the extent
material to an investor’s understanding. In this regard, provide quantitative and qualitative
disclosure regarding current weighted average and/or range of loan-to-value ratios and
occupancy rates, and separately present owner-occupied and non-owner occupied CRE by
borrower type.
3.Additionally, we note your disclosure on page 22 that you have a significant concentration
in CRE loans and that adverse developments, including those affecting real estate values
in your market areas, could increase the credit risk associated with your CRE loan
portfolio. Please revise future filings to provide an enhanced discussion and describe the
specific details of any risk management policies, procedures or other actions undertaken
by management in response to the current economic environment in the markets in which
you operate.
            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.
            Please contact Shannon Davis at 202-551-6687 or Amit Pande at 202-551-3423 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance