SecProbe.io

June 18, 201 5

Terry McNew
Chief Executive  Officer
MCBC Holdings , Inc.
100 Cherokee Cove Drive
Vonore, TN 37885

Re: MCBC Holdings , Inc.
  Amendment No. 1 to  Registration Statement on Form  S-1
Filed  June  5, 201 5
  File No.  333-203815

Dear Mr. McNew :

We have reviewed your amended registration statement 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.   Unless we note
otherwise, our references to prior comments are to comments in our May 28, 2015  letter .

Principal Stockholders, page 106

1. We note your response to our prior comment 12.  Please identify the individual or
individuals at Wayzata Investment Partners who have voting and dispositive power with
respect to t he shares held by Wayzata .  If the individual  would be Mr. Halloran, please
revise your disclosure to make that clear .

Terry McNew
MCBC Holdings , Inc.
June 18, 201 5
Page 2

 Notes to the Consolidated Financial Statements

Note 12. Income taxes, page F -24

2. We note your response to comment 18 in your response letter dated June 5, 2015 in
which you state as of June 30, 2014, you emerged from a three -year cumulative loss after
adjusting historic income for the disposition of the Hydra -Sport division and
nonrecurring impairment charges.  Please tell us wh y you believe these adjustments are
aberrations rather than continuing events.  Please refer to ASC 740 -10-30-22(c).  Further,
please tell us and quantify the components that are included in the adjustment for the
“disposition of Hydra -Sport division” and non-recurring impairment charges.

Note 18. Segment Information, page F -32

3. We note your response to comment 21 and your chief operating decision makers
(“CODM”) are your Chief Executive Officer, Chief Financial Officer and Chief
Operations Officer. We also note you do not consider the Mastercraft NXT product line
as an operating segment because the CODM do not review the results of the Mastercraft
NXT product line performance or allocate resources with respect to such product line
independently from the remainder of the Mastercraft model portfolio.

In order to better understand your conclusion in light of the apparent different customer
market the Mastercraft NXT product line plans to target, please address the following
additional comments:

 Please tell us the nature of the financial information available for the Mastercraft
NXT product line;

 Please describe your organizational structure.   In this regard, please:

o Tell us the titles and roles of the individuals who report to your CODM.
o Please explain to us how the product lines, particularly the Mastercraft NXT
product line,  are managed and identify for us the individuals considered product
line and segment managers and to whom they report;

 Please tell us what type of financial information is reviewed by the CODM on a
periodic basis. As part of your response, please provide us a copy of the report
reviewed by the CODM, and provide us the following information:

o The frequency of meetings between segment managers, product line managers
and the CODM;
o The nature of the resource allocation and performance assessment decisions the
CODM makes, including examples to illustrate the description;

Terry McNew
MCBC Holdings , Inc.
June 18, 201 5
Page 3

 o The basis on which segment managers and product line managers are
compensated (i.e. fixed salary, bonus based on p erformance of product, etc.);
o How budgets are developed and the nature of information reviewed and approved
at each level of the process; and
o The process or discussions that occur when actual amounts fall short or exceed
budgets.

 Additionally, please a dvise us of the amount of revenues and gross profit generated
by Mastercraft NXT product line for the fiscal year ended June 30, 2014 and for nine
month period ended March 29, 2015.

You may contact  Melissa Gilmore  at (202) 551 -3777 or Andrew Mew  at (202) 551-3377
if you have questions regarding comments on the financial statements and related matters.
Please contact Ada D. Sarmento  at (202) 551 -3798 or me at (202) 551 -3469 with any other
questions.

Sincerely,

 /s/ Justin Dobbie

Justin Dobbie
Legal Branch Chief

cc:  Kirk A. Davenport  II, Esq.