SecProbe.io

June 9, 2025
Sally Outlaw
Chief Executive Officer
Worthy Wealth Realty, Inc.
One Boca Commerce Center
551 NW 77 Street, Suite 212
Boca Raton, FL 33487
Re:Worthy Wealth Realty, Inc.
Amendment No. 4 to
Offering Statement on Form 1-A
Filed May 20, 2025
File No. 024-12536
Dear Sally Outlaw:
            We have reviewed your amended offering statement and have the following
comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our May 13, 2025 letter.
Amendment No. 4 to Offering Statement on Form 1-A
Offering Circular Summary, page 4
We note your response to prior comment 1 and the revised disclosure that you will
rely on interest from publicly traded government securities until "sufficient proceeds
have been received" to make initial real-estate investments. We also note that there is
no minimum offering amount, and that you deleted the narrative and quantitative
disclosure about relying on short-term investments and WWI in the event you do not
raise the $1 million required for 12 months of operations. Please revise to quantify the
minimum amount of proceeds from this offering you believe is required to begin
making real-estate related investments consistent with your plan of operations. Please 1.

June 9, 2025
Page 2
provide similar disclosure in the Plan of Operations section on page 28.
2.We note your response to prior comments 2 and 3 and the statement that you will be
paid interest at a rate "more than sufficient for the Company to satisfy the Company’s
periodic interest obligations to the investors." Given the 9% to 10% interest rate of the
bonds, please revise to disclose the rate or approximate interest rate your business
model targets for the mortgage loans and co-ownership interests you plan to invest in.
In this regard, it appears from your response to prior comment 3 that you seek to
invest in mortgage loans that pay approximately 14% to 17% annual interest.
However, it is unclear what interest rate or return on investment your business plan
targets for the co-ownership interests of underlying real estate. Please revise
accordingly.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Plan of Operations, page 28
3.It appears from your response to prior comment 3 that you currently target 2 types of
investments that are expected to provide periodic interest and eventual principal
payments: (1) mortgage loans and (2) co-investments in real estate secured by first
mortgages. Please revise to disclose the approximate percentage of each type of
investment you are targeting. For example, it is unclear if you anticipate investing the
proceeds equally in each type of investment. Please reconcile with the disclosure on
page 4 indicating that you expect 95% of your investments to be co-investments with
developers, with the other 5% reserved for working capital. Additionally, specifically
regarding the property interests made through co-investments, please revise to clarify
the anticipated terms of these investments. For example, do you expect these to be
minority interests, equal investments with the co-investors, or otherwise? To what
extent do you expect to be actively involved in the developments or passive co-
investors? If you do not know the expected terms of these co-investments, provide
Risk Factor disclosure addressing the lack of information available to the potential
investor regarding what appears to be a key component of your plan of operations.
            Please contact Aisha Adegbuyi at 202-551-8754 or James Lopez at 202-551-3536
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Clint J. Gage, Esq.