SecProbe.io

Mail Stop 4631
November 22, 2016

Via E -Mail
Michael Chavez
President
Reliant Holdings, Inc.
12343 Hymeadow Drive, Suite 3 -A
Austin, Texas 78750

Re: Reliant Holdings, Inc.
Registration Statement on Form S-1
Filed October 27, 2016
  File No. 333 -214274

Dear Mr. Chavez :

We have reviewed your 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.

General

1. Please advise us of all registration statements of co mpanies for which your sole D irector
and President may have a cted as a promoter or in which he had a controlling interest.
Descri be in detail the nature and extent of the direct or indirect relationship between your
sole D irector  and President  and those companies and their affiliates.  Indicate which
companies are now viable or dormant and which businesses have been modified and
restated from that described in their offering documents, noting the companies that are
still actively reporting with the Commission.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 2

 2. We note that your counsel, David M. Loev, has been involved in the initial filings of
several development stage and shell co mpanies.  Please provide us with an analysis
regarding why Mr. Loev should not be considered a promoter as that term is defined
under Rule 405 of Regulation C under the Securities Act.

Cover Page

3. Please remove Pink Sheets market from the list of market p laces.

Prospectus Summary, page 1

Description of Business Operations, page 1

4. We note your reference to awards won by Reliant Pools.  Please revise your disclosure
here and in your Business section to provide specifics regarding such awards.

Plan of Operations, page 2

5. We note your disclosure that you do not anticipate the need for any additional funding in
order to continue your operations at their current levels.  Please reconcile this disclosure
with your disclosure elsewhere in your registration s tatement that following this offering,
as a public company, you will incur expenses of approximately $75,000 to comply with
public company reporting requirements.  We note that similar disclosure appears in the
Summary of the Offering section and Business section of your registration statement.

Risk Factors, page 9

6. Please revise this section in its entirety to remove redundant risk factors.  By way of
example, we note that (i) risks associated with compliance with Sarbanes -Oxley are
located on both page 1 8 and page 19 and (ii) risks associated with the lack of a public
market for your securities are included on page 20 and page 23.

We require additional financing, and we may not be able to raise funds . . ., page 9

7. We note your disclosure that you need  approximately $200,000 in additional funding to
support your operations over the next 12 months.  Please reconcile this disclosure with
your disclosure elsewhere in your registration that you do not anticipate the need for any
additional funding to contin ue your operations at their current levels.

Directors, Executive Officers and Corporate Governance, page 26

8. Please revise your biographical information for Elijah May to include a discussion of his
principal occupations and employment during the past fiv e years.  See Item 11(k) of
Form S -1 and Item 401(e)(1) of Regulation S -K.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 3

Executive and Director Compensation, page 29

9. Please revise the disclosure in your summary compensation table under Footnote (2) to
provide more detail regarding the tax reimbursement.

Description of Business, page 32

Organizational History, page 32

10. Please revise your disclosure to describe the development of Reliant Pools, Inc.  See Item
11(a) of Form S -1 and Item 101(h) of Regulation S -K.

Competitive Strengths, page 33

11. We note your reference to a “pool development team.”  We further note your references
on page 34 to “schedulers” and “field supervisors.”  Please reconcile with your disclosure
on page 38 that you have four employees.

Swimming Pool Sales and Industry,  page 33

12. We note your disclosure on page 33 that you focus on the installation of concrete pools.
We also note your disclosure on page 34 regarding vinyl -lined pools and fiberglass pools.
Please tell us if you also design and install vinyl -lined and fib erglass pools.

Dependence on a Limited Number of Customers, page 35

13. Please tell us whether your large customers are the home builders you refer to on page
33.

Government Regulations, page 38

14. Please expand your disclosure to discuss in more detail the r egulations affecting and the
effect of such regulations on your business.  In particular, discuss the environmental laws
your business is subject to as well as the broader financial impact that various regulations
have on your business.  See Item 11(a) of Form S -1 and Item s 101(h)(4)(ix) and (xi) of
Regulation S -K.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 4

 Management’s Discussion and Analysis of Financial Condition . . ., page 40

15. Please revise your disclosure throughout this section to discuss the specific reasons for
the changes in your operating results so that potential investors gain better insight into
your results, particularly for trend purposes and discerning future prospects.  By way of
example, you state that several results increased because of your referral business; you
state that interest expense was due to an equipment purchase; and you state that operating
expenses increased due to the addition of personnel to help with increased operations.
See Item 11(h) of Form S -1 and Item 303 of Regulation S -K.

Results of Operations, page 41

16. Gross margin increased from 19% of revenue for the fiscal year ended December 31,
2014, to 27% for the same period in 2015.  Please amend your filing to provide a more
robust analysis of the contributing factors (i.e. lower cost of supplies, decre ased salaries,
increased selling price, etc.) driving the increase in gross margin.  Refer to Item 303 of
Regulation S -K for guidance.

Liquidity and Capital Resources, page 42

17. Please amend your filing to explain the nature of your $10,000 federal income tax
receivable as of June 30, 2016.  Refer to Item 303 of Regulation S -K for guidance.

Exhibits

18. We note that you have provided  a form  of legality  opinion .  Please file an executed
opinion  before you request acceleration of the effectiveness of your regis tration
statement.  See Section III.D.3 of Staff Legal Bulletin No. 19 (October 14, 2011).

19. Because the opinion that the common stock has been “validly issued” is understood to
mean that the registrant is validly existing under the laws of the jurisdiction  in which it is
incorporated, and the securities are duly authorized, please remove the assumption in
subparagraph (4) on page 2 of the legal  opinion that the Company will at all times remain
duly organized, validly existing, and in good standing under the laws of the State of
Nevada.  See Section II.B.1.a of Staff Legal Bulletin No. 19 (October 14, 2011).

We remind you that the company and its management a re responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Refer to Rules 460 and 461 regarding requests for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Michael Chavez
Reliant Holdings, Inc.
November 22, 2016
Page 5

 You may contact  Tracey McKoy  (Staff Accountant) at 202-551-3772  or Terence O’Brien
(Accounting Branch Chief ) at 202-551-3355  if you have questions re garding comments on the
financial statements and related matters.  Please contact  Frank Pigott  (Staff Attorney) at 202-
551-3570  or me at 202-551-3729  with any other questions.

Sincerely,

 /s/ Craig Slivka, for

 Pamela Long
Assistant Director
Office of Manufacturing and
Construction

cc: David M. Loev
 The Loev Law Firm, PC