SecProbe.io

CORRESP
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    Brian S. Korn

    Manatt, Phelps & Phillips, LLP
 Direct Dial: (212) 790-4510

    BKorn@manatt.com

May 19, 2023

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

    Attention:
     Pearlyne Paulemon and Pam Howell

    Office of Real Estate and Construction

Re:
Groundfloor Yield LLC
 Offering Statement on Form 1-A
 Post-qualification Amendment
 Filed April 28, 2023
 File No. 024-11411

Dear All:

We are submitting this letter
on behalf of our client, Groundfloor Yield LLC (the “Company”), in response to the written comments of the staff (the “Staff”)
of the United States Securities and Exchange Commission (the “SEC”) contained in your letter dated May 8, 2023 (the “Comment
Letter”) in connection with the Company’s Post-Qualification Offering Statement on Form 1-A, as submitted with the SEC on
April 28, 2023 (the “Offering Circular Amendment”).

For your convenience, our
responses are set forth below, with the headings and numbered items of this letter corresponding to the headings and numbered items contained
in the Comment Letter. Each of the comments from the Comment Letter is restated in bold and italics prior to the Company’s response.
Capitalized terms used but not defined in this letter shall have the respective meanings given to such terms in the Offering Circular
Amendment. All page number references in the Company’s responses are to page numbers in the Offering Circular Amendment, which is
being refiled concurrently with this response.

Manatt, Phelps & Phillips, LLP 7 Times Square,
New York, New York 10036 Tel: 212.790.4500 Fax: 212.790.4545

Albany | Boston | Chicago | Los Angeles | New York
| Orange County | Sacramento | San Francisco | Silicon Valley | Washington, D.C.

May 19, 2023

Page 2

Form 1-A-POS filed April 28, 2023

1.       We
reissue comment 2. It appears you commenced your offering on May 14, 2021 and that offering is continuing. Please provide your analysis
of how you are in compliance with the requirement that you update your offering statement on an annual basis as set forth in Rule 252(f)(iii)(2)(i)
of Regulation A. Also, please clarify whether you have sold securities since the date that was 12 months after the qualification date.

Response: The Company acknowledges the comment. The
Company commenced the offering on May 14, 2021 and the offering is continuing. The Company filed annual reports on Form 1-K on March 31,
2022 and March 10, 2023 to report the annual audited financial statements of the Company for the years ended December 31, 2021 and 2022,
respectively. The company also recently updated its financial statements in the Form 1-A by filing a Form 1-A POS on April 28, 2023 to
incorporate by reference the financial statements of the 2022 1-K into the Form 1-A. However, the Company failed to make such a filing
for the 2021 1-K. Investors continued to have complete access to all of the available financial information of the Company by reviewing
the 2021 1-K filing, but such filing was not incorporated formally into the Form 1-A pursuant to Rule 252(f)(iii)(2)(i). The failure to
file was accidental and the Company believes that its actions fall within the safe harbor of insignificant deviations from Regulation
A contemplated and covered by Rule 260(a). The Company has added risk factor disclosure to the Offering Statement to highlight the additional
risk this failure to file might cause. See pg. 15.

2.       We
reissue comment 3. Form 1-A requires that issuers specify the price of the securities being offered. This means that the interest
rate payable on the note must be calculable by investors or determined by reference to a formula with publicly available inputs (for
example, by reference to a benchmark). Your ability to change interest rates is within your complete discretion and therefore lacks
transparency that is present when a rate is calculable by investors or determined by reference to a formula with publicly available
inputs. Please revise your pricing method to comply with Regulation A. For additional guidance, please see Note 2 of Item 501(b)(3)
from Regulation S-K.

Response: The Company acknowledges the comment and
has modified its methodology for calculating the price and interest rate of the securities being offered. The price and rate will be offered
on a fixed basis. Any modification from the stated rate will be preceded by a qualified Form 1-A POS setting forth the proposed new price
or rate. See pp. 2, 7, 21 and 32.

****************

May 19, 2023

Page 3

We thank you for your prompt
attention to this letter responding to the previously submitted Registration Statement on Form 1-A and Comment Letter. Should you or the
Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact the undersigned at (212) 790-4510.

    Sincerely,

    Brian S. Korn

    cc:
    Groundfloor Yield LLC

    Nick Bhargava