SecProbe.io

CORRESP
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    ATTORNEYS
    AT LAW

Michael
J. FitzGerald*

Eoin L. Kreditor*

Lynne Bolduc

Robert C. Risbrough

George Vausher, LLM, CPA‡

David M. Lawrence

Charles C. McKenna

Brook John Changala

Natalie F. Foti

Josephine Rachelle Aranda

Pfrancez C. Quijano

  January 18, 2024
   William Allen Miller

Litao Zhou

Ikechukwu (Ike) Ubaka

John M. Marston†

Ralph G. Martinez†

Deborah M. Rosenthal†

Maria M. Rullo†

    VIA
    EDGAR
    Author’s
    Email: lbolduc@fkbrlegal.com

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Real Estate & Construction

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
William Demarest and Mark Rakip

    Re:
    Harbor
Custom Development, Inc.

    Form
    10-K for the Year Ended December 31, 2022

    Filed
    March 31, 2023

    File
    No. 001-39266

Gentlemen:

On
behalf of Harbor Custom Development, Inc. (the “Company”), we are responding to the comment (the “Comment”) of
the staff (the “Staff”) of the Securities and Exchange Commission contained in its letter dated December 19, 2023 (the “Comment
Letter”), relating to the above-referenced Form 10-K for the Year Ended December 31, 2022 (the “Form 10-K”).

Below
is the Company’s response to the Comment. The heading and page number in this letter correspond to the heading and page number
contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comment
in bold below. Capitalized terms used but not defined herein have the meanings given to them in the Form 10-K.

Form
10-K for the Year Ended December 31, 2022

Item
9A. Controls & Procedures, page 68

    1.
    Please
    amend your filing to provide management’s annual report on internal control over financial reporting as of December 31, 2022;
    refer to Item 308(a) of Regulation S-K. In addition, given the omission of your annual report on internal control over financial
    reporting, tell us how you determined that your disclosure controls and procedures were effective as of December 31, 2022.

Response:
We have amended the Form 10-K to provide management’s annual report on internal control over financial reporting as of December
31, 2022. In addition, in light of the omission of the aforementioned report, we have amended our disclosure to state that both our disclosure
controls and procedures and our internal control over financial reporting were ineffective as of December 31, 2022.

2
Park Plaza, Suite 850 ˖ Irvine, California 92614 1150 South Olive Street, Suite 10-128 ˖ Los Angeles, California 90015

Telephone: 949-788-8900 ˖ Facsimile: 949-788-8980 ˖ www.fkbrlegal.com

*Professional
Corporation ˖ †Of Counsel ˖ ‡Certified Specialist in Estate Planning,

Trust & Probate Law, and in Taxation
Law, State Bar of California

  January 18, 2024

                                  Page 2 of 2

Please
direct any questions or comments concerning this response letter to the undersigned at (949) 788-8900 or by email at lbolduc@FKBRlegal.com.

    Very
    truly yours,

    /s/
    Lynne Bolduc

    Lynne
    Bolduc

    cc:
    Yoshi
    Niino, Chief Accounting Officer, Harbor Custom Development, Inc.