SecProbe.io

United States securities and exchange commission logo
June 20, 2024
Nick Bhargava
Executive Vice President
Groundfloor Finance Inc.
1201 Peachtree St NE, Suite 1104-400
Atlanta, GA 30361
Re:Groundfloor Finance Inc.
Offering Statement on Form 1-A
Post-qualification Amendment No. 8
Filed June 17, 2024
File No. 024-12013
Dear Nick Bhargava:
            We have reviewed your amendment and have the following comment.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe the comment applies 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 offering statement and the information you
provide in response to this letter, we may have additional comments.
Amended Post-Qualification Amendment dated June 17, 2024
General
1.We note the response to prior comment 2 that you are offering only one series of LROs
per property. However, we continue to note two series related to the 3353 North 2nd
Street Philadelphia PA property. Please revise or advise.
            We will consider qualifying your offering statement at your request. If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            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.

 FirstName LastNameNick  Bhargava
 Comapany NameGroundfloor Finance Inc.
 June 20, 2024 Page 2
 FirstName LastName
Nick  Bhargava
Groundfloor Finance Inc.
June 20, 2024
Page 2
            Please contact Pearlyne Paulemon at 202-551-8714 or Pam Howell at 202-551-3357 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Brian Korn