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July 26, 2023
Brent Beal
Chief Executive Officer
ETX Park Fund #2, LLC
203 East Main, Suite 200
Nacogdoches, TX 75961
Re:ETX Park Fund #2, LLC
Amendment No. 1 to Offering Statement on Form 1-A
Filed June 28, 2023
File No. 024-12222
Dear Brent Beal:
            We have reviewed your amended offering 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 offering 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 offering 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 1, 2023 letter.
Amendment No. 1 to Offering Statement on Form 1-A
Cover Page
1.We note your response to comment 1.  Please clarify whether Thread Bank will be
holding funds in its account until a certain minimum threshold has been met as it is not
clear from your disclosure why you require an escrow arrangement.

 FirstName LastNameBrent Beal
 Comapany NameETX Park Fund #2, LLC
 July 26, 2023 Page 2
 FirstName LastName
Brent Beal
ETX Park Fund #2, LLC
July 26, 2023
Page 2
Risk Factors, page 7
2.We refer to your revised disclosure on page 11 regarding the first position lien on the
optioned property held by Austin Bank, and your statement that approval of the sale of
such property may be required of Austin Bank "prior to the execution of the option."
Please revise to discuss this risk in a separate risk factor, and also expand your disclosure
to describe the circumstances when Austin Bank may need to provide its approval, and
whether this requirement may depend on the amount of proceeds you are able to raise.
No Guaranteed Preferred Return, page 7
3.We acknowledge your revised disclosure in response to prior comment 3, and note your
statements that the Company may not generate sufficient cash flows to distribute the
preferred return of 7% to investors "on a regular basis or at all."  Please further revise to
discuss the preferred return rate in light of the fact that you have a limited history and no
current operations, that your proposed operations involve the initial purchase of property
and construction of rental property, and that you may not raise sufficient funds to begin
the initial phases of your business plan.
4.We note your revised operating agreement, but reissue comment 5 as we are unable to
locate responsive disclosure in your offering circular, and that your offering circular
continues to state that profits are to be allocated among Class A and Class B members
with reference to their Invested Capital.  Please also revise to make clear the order of
allocation for the profits, so that investors understand when profits might be allocated to
the payment of their Preferred Return.
Officers and Significant Employees, page 22
5.We acknowledge your revised disclosures in response to comment 4.  However, as
previously stated, please revise the disclosure regarding the business experience of Brent
Beal and Brock Beal by discussing their experience in ETX Park Fund #1, LP.  In
addition, to the extent applicable, please revise to discuss any limitations with respect to
the access road, and clarify if the optioned property is currently landlocked.  Please also
revise in an appropriate section how access to the optioned property will take place if the
access road is not fully built, as we note your disclosure in the Use of Proceeds section
indicating that if you do not raise more than 50% of the maximum offering amount, you
anticipate that only half of the access road will be built.
General
6.Please note that the offering statement also must be signed by your principal accounting
officer and governing body, and revise accordingly.

 FirstName LastNameBrent Beal
 Comapany NameETX Park Fund #2, LLC
 July 26, 2023 Page 3
 FirstName LastName
Brent Beal
ETX Park Fund #2, LLC
July 26, 2023
Page 3
            You may contact Isabel Rivera at 202-551-3518 or Dorrie Yale at 202-551-8776 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Nicholas Antaki