SecProbe.io

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 First Community Corporation

 5455 Sunset Blvd.

 Lexington, South Carolina 29072

 September 23, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attn: Robert Arzonetti

 Re:
 First
Community Corporation

 Registration Statement on Form S-4

 File No. 333-290152

 Ladies and Gentlemen:

 In accordance with Rule 461 under
the Securities Act of 1933, as amended (the "Securities Act"), we hereby request that the effective date for the above-referenced
Registration Statement be accelerated so that it will be declared effective under the Securities Act at 10:00 a.m., Eastern Time, on Wednesday,
September 24, 2025, or as soon as practicable thereafter.

 Please contact our counsel, Brittany
M. McIntosh of Nelson Mullins Riley & Scarborough LLP, by email at brittany.mcintosh@nelsonmullins.com or by phone at (864) 373-2326,
with any questions you may have concerning this letter, or if you require any additional information. Please notify Ms. McIntosh when
this request for acceleration of effectiveness of the Registration Statement has been granted.

 Very truly yours,

 /s/ D. Shawn Jordan

 D. Shawn Jordan

 Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 17, 2025

Michael C. Crapps
Chief Executive Officer
First Community Corporation
5455 Sunset Blvd.
Lexington, SC 29072

 Re: First Community Corporation
 Registration Statement on Form S-4
 Filed September 10, 2025
 File No. 333-290152
Dear Michael C. Crapps:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Robert Arzonetti at 202-551-8819 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Brittany M. McIntosh
</TEXT>
</DOCUMENT>

December 20, 2024
Michael C. Crapps
Chief Executive Officer
First Community Corporation
5455 Sunset Blvd.
Lexington, South Carolina 29072
Re:First Community Corporation
Registration Statement on Form S-3
Filed December 18, 2024
File No. 333-283896
Dear Michael C. Crapps:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Robert Arzonetti at 202-551-8819 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Brittany M. McIntosh

CORRESP
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First Community Corporation

5455 Sunset Blvd.

Lexington, South Carolina 29072

December 19, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attn: Robert Arzonetti

  Re:
  First
Community Corporation

  Registration Statement on Form S-3

  File No. 333-283896

Ladies and Gentlemen:

In accordance with Rule 461 under
the Securities Act of 1933, as amended, we hereby request that the effective date for the above-referenced Registration Statement be accelerated
so that it will be declared effective under the Securities Act at 4:00 p.m., Eastern Time, on Friday, December 20, 2024, or as soon as
practicable thereafter.

Once the Registration Statement
has been declared effective, please confirm that event with our counsel, Brittany M. McIntosh of Nelson Mullins Riley & Scarborough
LLP, by email at brittany.mcintosh@nelsonmullins.com or by telephone at (864) 373-2326.

Very truly yours,

/s/ D. Shawn Jordan

D. Shawn Jordan

Chief Financial Officer

United States securities and exchange commission logo
December 28, 2023
D. Shawn Jordan
Chief Financial Officer
First Community Corporation
5455 Sunset Boulevard
Lexington, SC 29072
Re:First Community Corporation
Form 10-K for Fiscal Year Ended December 31, 2022
File No. 000-28344
Dear D. Shawn Jordan:
            We have completed our review of your filing. We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Finance

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First Community Corporation

5455 Sunset Blvd.

Lexington, SC 29072

December 22, 2023

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Michael Henderson and Robert Klein

  Re:
  First Community Corporation

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

  Form 8-K filed October 18, 2023

  File No. 000-28344

Dear Messrs. Henderson and Klein,

This letter is being submitted
in response to the comment letter dated December 21, 2023 (the “Comment Letter”) from the staff of the Division of
Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
relating to First Community Corporation’s (the “Company’s”) Annual Report on Form 10-K for the fiscal year
ended December 31, 2022 and Current Report on Form 8-K furnished to the Commission on October 18, 2023.

For your convenience, the text
of the Staff’s comments is set forth in italics followed by the Company’s responses. The headings and numbered responses below
correspond to the headings and numbered comments in the Comment Letter.

Form 8-K filed October 18, 2023

Exhibit 99.1

 1. We note your response to prior comment 1. Your presentation of tangible common equity per common share
excluding accumulated other comprehensive loss and tangible common equity to tangible assets excluding accumulated other comprehensive
loss represents individually tailored accounting measures given that the adjustment to exclude accumulated other comprehensive loss has
the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove
the presentation of these non-GAAP measures from your future filings. Refer to Question 100.04 of the Division of Corporation Finance’s
Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.

Response

The Company acknowledges the Staff’s comment
and confirms that in future filings, it will remove both (i) tangible common equity per common share excluding accumulated other comprehensive
loss and (ii) tangible common equity to tangible assets excluding accumulated other comprehensive loss.

***

If you have any questions regarding this letter, please
do not hesitate to contact me at (803) 951-0516.

Sincerely,

First Community Corporation

/s/ D. Shawn Jordan

D. Shawn Jordan

Chief Financial Officer

United States securities and exchange commission logo
December 21, 2023
D. Shawn Jordan
Chief Financial Officer
First Community Corporation
5455 Sunset Boulevard
Lexington, SC 29072
Re:First Community Corporation
Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K filed October 18, 2023
Response dated November 20, 2023
File No. 000-28344
Dear D. Shawn Jordan:
            We have reviewed your November 20, 2023 response to our comment letter and have the
following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe the
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our November 8, 2023
letter.
Form 8-K filed October 18, 2023
Exhibit 99.1
1.We note your response to prior comment 1. Your presentation of tangible common equity
per common share excluding accumulated other comprehensive loss and tangible common
equity to tangible assets excluding accumulated other comprehensive loss represents
individually tailored accounting measures given that the adjustment to exclude
accumulated other comprehensive loss has the effect of changing the recognition and
measurement principles required to be applied in accordance with GAAP. Therefore,
please remove the presentation of these non-GAAP measures from your future filings.
Refer to Question 100.04 of the Division of Corporation Finance’s Compliance
& Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of
Regulation G.

 FirstName LastNameD. Shawn Jordan
 Comapany NameFirst Community Corporation
 December 21, 2023 Page 2
 FirstName LastName
D. Shawn Jordan
First Community Corporation
December 21, 2023
Page 2
            Please contact Michael Henderson at 202-551-3364 or Robert Klein at 202-551-3847 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Finance

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First Community
Corporation

5455 Sunset Blvd.

Lexington, SC
29072

November 20,
2023

United States Securities and Exchange
Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Michael Henderson and Robert
Klein

    Re:
    First Community Corporation

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

    Form 8-K filed October 18, 2023

    File No. 000-28344

Dear Messrs. Henderson and Klein,

This
letter is being submitted in response to the comment letter dated November 8, 2023 (the “Comment Letter”) from
the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”) relating to First Community Corporation’s (the “Company’s”)
Annual Report on Form 10-K for the fiscal year ended December 31, 2022 and Current Report on Form 8-K furnished to the Commission
on October 18, 2023.

For
your convenience, the text of the Staff’s comments is set forth in italics followed by the Company’s responses. The
headings and numbered responses below correspond to the headings and numbered comments in the Comment Letter.

Form 8-K
filed October 18, 2023

Exhibit 99.1

 1. We
                                         note your presentation of the Non-GAAP measure for tangible common equity per common
                                         share excluding accumulated other comprehensive loss and tangible common equity to tangible
                                         assets excluding accumulated other comprehensive loss. Please address the following:

 · Revise
                                         your future filings to include a calculation and full reconciliation of this non-GAAP
                                         measure to GAAP financial information, quantifying each individual adjustment component
                                         to the numerator and denominator. In your response, provide us with a reconciliation
                                         for the period ended September 30, 2023.

Response:

We
respectfully acknowledge the Staff’s comment and if these measures are included in future filings, we will provide a calculation
and full reconciliation of such non-GAAP measures to GAAP financial information, quantifying each individual adjustment component
to the numerator and denominator for all applicable periods. Further, we note that, consistent with past practice, we do not intend
to include these measures in our Forms 10-K and 10-Q.

Please
see the following reconciliation for (1) tangible book value per common share excluding accumulated other comprehensive loss and
(2) tangible common equity to tangible assets excluding accumulated other comprehensive loss (collectively, the “Non-GAAP
Measures Excluding AOCL”) for the period ended September 30, 2023, which line items are derived from the Company’s
balance sheet as of September 30, 2023, as an illustration of the calculation and full reconciliation format that we intend to
include in future filings if these measures are included in a future filing:

      $
                                         in thousands except per common share data
    September
    30,

    2023

      A
    Total
    shareholders' equity (GAAP)
    $ 123,601

      B
    Intangible
    assets (GAAP)
      643

      C
    Goodwill
    (GAAP)
      14,637

      D
    Accumulated
    other comprehensive loss (GAAP)
      (33,057
    )

      E
    Total
    shareholders' equity excluding accumulated other comprehensive loss (non-GAAP)
    $ 141,378
      E
                                         = A - B - C - D

      F
    Total
    assets (GAAP)
      1,793,722

      G
    Intangible
    assets (GAAP)
      643

      H
    Goodwill
    (GAAP)
      14,637

      I
    Accumulated
    other comprehensive loss (GAAP)
      (33,057
    )

      J
    Total
    assets excluding accumulated other comprehensive loss (non-GAAP)
    $ 1,811,499
      J
                                         = F - G - H - I

      K
    Common
    Stock, par value $1.00 per share (GAAP)
    $ 7,600

      L
    Book value per common
    share (GAAP)
    $ 16.26
      L
                                         = A / K

      M
    Tangible
    book value per common share excluding accumulated other comprehensive loss (non-GAAP)
    $ 18.60
      M
                                         = E / K

      N
    Equity
    to assets (GAAP)
      6.89
    % N
                                         = A / F

      O
    Tangible
    common equity to tangible assets excluding accumulated other comprehensive loss (non-GAAP)
      7.80
    % O
                                         = E / J

 · Tell
                                         us and revise your disclosures, in future filings, to more fully explain what this measure
                                         represents and how it is used to analyze and evaluate financial condition and capital
                                         strength.

Response:

We
respectfully acknowledge the Staff’s comment and if included in future filings, we will more fully explain the Non-GAAP
Measures Excluding AOCL, what it represents and how such measures are used to analyze and evaluate financial condition and capital
strength.

The
Company’s management concluded that it was appropriate to include the Non-GAAP Measures Excluding AOCL for the Company’s
financial performance measures in its earnings release furnished to the Commission because this information is useful for shareholders,
current and potential investors, and financial industry analysts (collectively, the “Stakeholders”). The Company
provided these Non-GAAP Measures Excluding AOCL in response to Stakeholders’ request for such information, and the Company
has received feedback from its Stakeholders that it is beneficial information in comparing the Company to other companies and
in assessing the Company in light of metrics that Stakeholders view as important.

The
Company’s management believes that these Non-GAAP Measures Excluding AOCL are relevant measures to provide because accumulated
other comprehensive income (loss) fluctuates on a quarterly and yearly basis based on changes in fair market values on the Company’s
securities primarily due to change in market interest rates. The Company’s change from accumulated other comprehensive income
to accumulated other comprehensive loss has been due to increases in market interest rates, which has a temporary negative impact
on the fair value of the investment securities portfolio and on accumulated other comprehensive income (loss), which is included
in shareholders’ equity. Providing the Non-GAAP Measures Excluding AOCL enhances Stakeholders’ ability to evaluate
how the Company’s tangible book value per common share and tangible common equity to tangible assets have changed exclusive
of the changes in accumulated other comprehensive income (loss) (i.e., the impact of subtracting GAAP net unrealized gains net
of deferred taxes and adding back GAAP net unrealized losses net of deferred taxes on the investment securities portfolio.)

The
Company will continue to note for Stakeholders that “Non-GAAP measures have limitations as analytical tools, and investors
should not consider them in isolation or as a substitute for analysis of the company’s results as reported under GAAP.”

 · Tell
                                         us how you determined the adjustment to exclude accumulated other comprehensive income
                                         (loss) is appropriate, including your consideration of whether the adjustment relates
                                         to normal, recurring activities of the Company or if it results in individually tailored
                                         accounting. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance
                                         & Disclosure Interpretations on Non-GAAP Financial Measures.

Response:

The
Company’s management maintains that changes in the interest rate environment, which are affected by many factors beyond
the Company’s control (including inflation, recession, unemployment, money supply, domestic and international events and
changes in the United States and other financial markets) and affect others in the banking industry, can temporarily affect the
market value of its available-for-sale investment securities and temporarily impact accumulated other comprehensive income (loss),
which temporarily can impact shareholders’ equity. The Company does not believe that the disclosure of the Non-GAAP Measures
Excluding AOCL, which are derivable directly from individual line items on the balance sheet, constitutes individually tailored
accounting referred to in Question 100.04. The Company’s management believes that providing non-GAAP financial measures
excluding accumulated other comprehensive income (loss) is a commonly used approach within the banking industry and is not an
individually tailored accounting referred to in Question 100.04 given this commonality.

The
Company’s management understands the need for transparent disclosure and will include all applicable reconciliations.

 · Tell
                                         us whether you will continue to present this measure and adjustment during periods where
                                         there is an accumulated other comprehensive gain rather than a loss, which would result
                                         in a reduction to these non-GAAP measures excluding AOCI. Refer to Question 100.03 of
                                         the Division of Corporation Finance’s Compliance & Disclosure Interpretations
                                         on Non-GAAP Financial Measures.

Response:

We
respectfully acknowledge the Staff’s comment. Subject to the Staff’s position and continuing Stakeholder interests
in this measure and adjustment, we intend to present this measure and adjustment in future earnings releases during periods where
there is an accumulated other comprehensive gain or loss.

 · Tell
                                         us whether you also add back the impact of AOCI to the denominator (total tangible assets)
                                         so that both the numerator and denominator would be calculated on a consistent basis,
                                         where applicable. To the extent that you do not, explain how you concluded it is appropriate.

Response:

We
respectfully acknowledge the Staff’s comment and refer the Staff to the full reconciliation above that indicates when calculating
the non-GAAP measure, we adjust both the numerator and denominator for the impact of accumulated other comprehensive income (loss)
so that both are calculated on a consistent basis.

***

We
hope the foregoing information addresses the Staff’s comments regarding the referenced filing. If you have any questions
regarding this letter, please do not hesitate to contact me at (803) 951-0516.

    Sincerely,

    First Community Corporation

    /s/ D.
    Shawn Jordan

    D. Shawn Jordan

    Chief Financial Officer

United States securities and exchange commission logo
November 8, 2023
D. Shawn Jordan
Chief Financial Officer
First Community Corporation
5455 Sunset Boulevard
Lexington, SC 29072
Re:First Community Corporation
Form 10-K for Fiscal Year Ended December 31, 2022
Form 8-K filed October 18, 2023
File No. 000-28344
Dear D. Shawn Jordan:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 8-K filed October 18, 2023
Exhibit 99.1
1.We note your presentation of the Non-GAAP measure for tangible common equity per
common share excluding accumulated other comprehensive loss and tangible common
equity to tangible assets excluding accumulated other comprehensive loss. Please address
the following:
•Revise your future filings to include a calculation and full reconciliation of this non-
GAAP measure to GAAP financial information, quantifying each individual
adjustment component to the numerator and denominator. In your response, provide
us with a reconciliation for the period ended September 30, 2023.
•Tell us and revise your disclosures, in future filings, to more fully explain what
this measure represents and how it is used to analyze and evaluate financial condition
and capital strength.
•Tell us how you determined the adjustment to exclude accumulated other
comprehensive income (loss) is appropriate, including your consideration of whether

 FirstName LastNameD. Shawn Jordan
 Comapany NameFirst Community Corporation
 November 8, 2023 Page 2
 FirstName LastName
D. Shawn Jordan
First Community Corporation
November 8, 2023
Page 2
the adjustment relates to normal, recurring activities of the Company or if it results in
individually tailored accounting. Refer to Question 100.04 of the Division of
Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP
Financial Measures.
•Tell us whether you will continue to present this measure and adjustment during
periods where there is an accumulated other comprehensive gain rather than a loss,
which would result in a reduction to these non-GAAP measures excluding
AOCI. Refer to Question 100.03 of the Division of Corporation Finance’s
Compliance & Disclosure Interpretations on Non-GAAP Financial Measures.
•Tell us whether you also add back the impact of AOCI to the denominator (total
tangible assets) so that both the numerator and denominator would be calculated on a
consistent basis, where applicable. To the extent that you do not, explain how you
concluded it is appropriate.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Michael Henderson at 202-551-3364 or Robert Klein at 202-551-3847
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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First Community Corporation

5455 Sunset Blvd.

Lexington, South Carolina 29072

July 12, 2017

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

    Attention:
    Dietrich A. King

    Assistant Director

    Office of Financial Services

    Re:
    First Community Corporation (the “Registrant”)

    Registration Statement on Form S-4 (File No. 333-218564)

Ladies and Gentleman:

Pursuant to Rule 461 under
the Securities Act of 1933 (the “Securities Act”), the Registrant hereby requests that the effective
date for the above-referenced Registration Statement be accelerated so that it will be declared effective under the Securities
Act at 4:00 p.m., New York City time, on Friday, July 14, 2017, or as soon thereafter as possible.

	In connection with
this request, the Registrant hereby acknowledges that:

 1. should the Securities and Exchange Commission (the “Commission”) or the
staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration
Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 2. the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring
the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy
of the disclosure in the Registration Statement; and

 3. the Registrant may not assert Staff comments and the declaration of effectiveness as a defense
in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    First Community Corporation

    By:
    /s/ Michael C. Crapps

    Michael C. Crapps

    President and Chief Executive Officer

Mail Stop 4720
June 14 , 2017
Michael C. Crapps
President and Chief Executive Officer
First Community Corporation
5455 Sunset Blvd.
Lexington, SC  29072

Re:  First Community Corporation
 Registration Statement on Form S -4
Filed  June 7 , 2017
File No. 333-218564

Dear M r. Crapps :

This is to advise you that we have not reviewed and will not review your registration
statement s.

Please refer to Rule s 460 and  461 regarding requests for  acceleration .  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

You may contact  Jessica Livingston , Staff Attorney,  at 202-551-3448  with any questions.

Sincerely,

 /s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Servi ces

cc:   John M. Jennings , Esq.

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First Community Corporation

5455 Sunset Boulevard

Lexington, South Carolina 29072

December 27, 2013

Ms. Kathryn McHale

Senior Staff Attorney

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:                               First Community Corporation (the “Registrant”)

Registration Statement on Form S-4 (File No. 333-191652)

Dear Ms. McHale:

Pursuant to Rule 461 under the Securities Act of 1933 (the “Securities Act”), the Registrant hereby requests that the effective date for the above-referenced Registration Statement be accelerated so that it will be declared effective under the Securities Act at 4:00 p.m., New York City time, on Monday, December 30, 2013, or as soon thereafter as possible.

In connection with this request, the Registrant hereby acknowledges that:

1.                                       should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

2.                                       the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

3.                                       the Registrant may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,

First   Community Corporation

By:

/s/   Joseph G. Sawyer

Joseph   G. Sawyer

Chief   Financial Officer

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Nelson

Mullins

Nelson Mullins Riley & Scarborough LLP

Attorneys and Counselors at Law

John M. Jennings

104 South Main Street / Ninth Floor / Greenville, SC 29601

(Admitted in IL NC & SC)

Tel: 864.250.2300 Fax: 864.232.2925

Tel: 864.250.2207

www.nelsonmullins.com

Fax: 864.232.2925

john.jennings@nelsonmullins.com

December 26, 2013

Via Electronic Mail

Ms. Kathryn McHale

Senior Staff Attorney

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:                        First Community Corporation

Amendment No. 2 to Registration Statement on Form S-4

Filed December 9, 2013

File No. 333-191652

Dear Ms. McHale:

This letter is provided on behalf of First Community Corporation (the “Company,” “First Community,” “we,” or “our”) in response to the comments of the Staff of the Securities and Exchange Commission (the “Commission”) dated December 24, 2013 (the “Comment Letter”) with respect to the Company’s Amendment No. 2 to Registration Statement on Form S-4 (the “Amendment No. 2”) filed December 9, 2013; File No. 333-191652.  This letter is being filed with the Commission electronically via EDGAR.

For ease of reference, we have repeated each of the Commission’s comments below, followed by the corresponding responses of First Community.

Comment Letter dated December 24, 2013

Form S-4

General

1.                                We acknowledge your response to comment one of our letter to you dated December 3, 2013.  However, it appears that Savannah provided First Community with budget projections for the current and future fiscal years.  The staff considers two years of projections material.  Please revise your disclosure to include any material projections presented to First Community or its agent, including revenue, income, and income per share data.

With offices in the District of Columbia, Florida, Georgia, Massachusetts, North Carolina, South Carolina, Tennessee and West Virginia

Response to Comment 1:

The Company has revised its disclosure in Amendment No. 3 to the Registration Statement on Form S-4 (“Amendment No. 3”) to include the requested disclosure. See pages 78 through 81 of Amendment No. 3.

2.                                We note that both Amendment No. 2 (page 66) and the fairness opinion of Ewing (page C-1) state that First Community provided Ewing with its Strategic Plan for the three year period ending December 31, 2014.  Please disclose any material projections contained in the First Community Strategic Plan.

Response to Comment 2:

The Company has revised its disclosure in Amendment No. 3 to include the requested disclosure. See pages 78 through 81 of Amendment No. 3.

If you have any questions or comments related to these responses, please contact me at (864) 250-2207.

Sincerely,

/s/   John M. Jennings

John   M. Jennings

cc:

Michael   C. Crapps, President and Chief Executive Officer

2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
  CORPORATION FINANCE

        December 24, 2013

Via E -mail
Mr. Michael C. Crapps
President and Chief Executive Officer
First Community Corporation
5455 Sunset Blvd.
Lexington, South Carolina 29072

Re: First Community Corporation
Amendment No. 2 to Registration Statement on Form S -4
Filed  December 9 , 2013
File No. 333-191652

Dear  Mr. Crapps :

We have reviewed your amended registration statement  and response  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.

Form S -4

General

1. We acknowledge your response to comment one of our letter to you dated December
3, 2013.  However, it appears that Savannah provided First Community with budget
projections for the current and future fiscal years.  The staff considers two years of
projections material.  Please revise your disclo sure to include any material projections
presented to First Community or its agent, including revenue, income, and income per
share data.

2. We note that both Amendment No. 2 (page 66) and the fairness opinion of Ewing
(page C -1) state that First Community p rovided Ewing with its Strategic Plan for the

Mr. Michael C. Crapps
First Community Corporation
December  24, 2013
Page 2

 three year period ending December 31, 2014.   Please disclose any material
projections contained in the First Community Strategic Plan.

We urge all persons who are responsible for the accuracy and adequacy of  the
disclosure in the filing to be certain that the filing includes the information the Securities
Act of 1933 and all applicable Securities Act rules require.   Since the company and its
management are in possession of all facts relating to a company’s di sclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the
effective date of the pending regist ration statement please provide  a written stat ement
from the company acknowledging that:
 should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;
 the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and
 the company may not assert sta ff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will
consider a written request for acceleration of the effective date of the registration
statement as confirmation of the fact that those requesting acceleration are aware of their
respective responsibilities under the Securities Act of 1933 and the Secu rities Exchange
Act of 1934 as they relate to the proposed public offering of the securities specified in the
above registration statement.  Please allow adequate time  for us to review any
amendment prior to the requested effective date of the registration  statement.

Please  contact Jonathan E. Gottlieb at (202) 551 -3416 or me at (202) 551 -3464
with any questions.

Sincerely,

 /s/ Kathryn McHale

Kathryn McHale
Staff Attorney

CORRESP
1
filename1.htm

Nelson

Mullins

Nelson Mullins Riley & Scarborough LLP

Attorneys and Counselors at Law

104 South Main Street / Ninth Floor / Greenville, SC  29601

Tel: 864.250.2300    Fax: 864.232.2925

www.nelsonmullins.com

John M. Jennings

(Admitted in IL NC & SC)

Tel: 864.250.2207

Fax: 864.232.2925

john.jennings@nelsonmullins.com

December 9, 2013

Via Electronic Mail

Ms. Kathryn McHale

Senior Staff Attorney

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:                        First Community Corporation

Amendment No. 1 to Registration Statement on Form S-4

Filed November 15, 2013

File No. 333-191652

Dear Ms. McHale:

This letter is provided on behalf of First Community Corporation (the “Company,” “First Community,” “we,” or “our”) in response to the comments of the Staff of the Securities and Exchange Commission (the “Commission”) dated December 3, 2013 (the “Comment Letter”) with respect to the Company’s Amendment No. 1 to Registration Statement on Form S-4 (the “Amendment No. 1”) filed November 15, 2013; File No. 333-191652.  This letter is being filed with the Commission electronically via EDGAR.

For ease of reference, we have repeated each of the Commission’s comments below, followed by the corresponding responses of First Community.

Comment Letter dated December 3, 2013

Form S-4

General

1.                                We note that Savannah have provided projections of revenue, income, and income per share to FCCO.  The staff considers two years of these projections material.  Please revise your disclosure to include these projections.

With offices in the District of Columbia, Florida, Georgia, Massachusetts, North Carolina, South Carolina, Tennessee and West Virginia

Response to Comment 1:

The Company confirms that neither the Company nor its financial advisor, FIG Partners, LLC (“FIG”), received financial projections from Savannah River Financial Corporation (or its banking subsidiary Savannah River Banking Company).

The Company and FIG have revised the disclosure under the heading “Discounted Cash Flow Analysis” on page 77 of Amendment No. 2 to Registration Statement on Form S-4 (“Amendment No. 2”) to clarify that such analysis reflected FIG projections and estimates, rather than projections and estimates prepared by Savannah River, as well as cost savings estimates from First Community.  The Company notes that such costs savings estimates are quantified on page 75 of Amendment No. 2 and also that the credit marks referenced on page 75 of Amendment No. 2 are quantified on page 78 of Amendment No. 2 under the heading “Franchise Valuation”.  The opinion of FIG has also been revised to clarify that FIG received cost savings estimates and credit mark estimates from First Community.  See pages D-2 and D-3 of Annex D.

Interests of Directors and Officers of Savannah River, page 9

2.                                We acknowledge your response to comment 4 of our letter to you dated November 6, 2013.  Please add disclosure regarding the interests of officers and directors in severance benefits and any other compensation from Savannah relating to the merger.

Response to Comment 2:

The Company has confirmed with Savannah River that, except as disclosed and quantified under “Interests of Directors and Officers of Savannah River that Differ from Your Interests” on pages 9-11 and 91-96 of Amendment No. 2, no severance benefits or other compensation relating to the merger will be paid by Savannah River to its directors or officers.

Risk Factors, page, page 33

Risks Related to the Merger, page 33

3.                                We acknowledge your response to comment 12 of our letter to you dated November 6, 2013.  Please revise to explain that the risk to shareholders (and the amount that may be subject to tax) depends on the extent to which each shareholder has a gain on the exchange of their stock in Savanah for cash and/or stock in First Community.

Response to Comment 3:

The Company has revised the first risk factor on page 33 of Amendment No. 2 to explain that the risk to shareholders (and the amount that may be subject to tax) depends on the extent to which each shareholder has a gain on the exchange of their stock in Savannah River for cash and/or stock in First Community, as requested by the Staff.

2

Important Federal Income Tax Consequences, page 86

4.                                Please revise your disclosure in the first sentence to state the discussion constitutes the opinion of Nelson Mullins and Bryan Cave, rather than merely summarizes the tax consequences.

Response to Comment 4:

The Company has revised its disclosure in the first sentence of the Important Federal Income Tax Consequences section beginning on page 86 of Amendment No. 2 to state that the discussion constitutes the opinion of Nelson Mullins and Bryan Cave, rather than merely summarizes the tax consequences.

Exhibit 8.1 Tax Opinion

5.                                We acknowledge your response to comment 24 of our letter to you dated November 6, 2013.  As we requested, please direct counsel, Nelson Mullins Riley & Scarborough LLP, to revise its opinion as follows:

·                  state clearly that the disclosure in the tax consequences section of the prospectus is the opinion of Nelson Mullins (not just that it is accurate); and

·                  revise the last paragraph so that it does not limit reliance except as permitted by Staff Legal Bulletin 19 (October 14, 2011).

Response to Comment 5:

Nelson Mullins has revised its tax opinion as requested by the Staff.  The revised tax opinion is filed as Exhibit 8.1 to Amendment No. 2.  In response to the first bullet point above, please note that the requested disclosure is provided in the fourth paragraph of the tax opinion.   The last paragraph has been revised so that it does not limit reliance except as permitted by Staff Legal Bulletin 19 (October 14, 2011).

Exhibit 8.2 Tax Opinion

6.                                We acknowledge your response to comment 25 of our letter to you dated November 6, 2013. As we requested, please direct counsel, Bryan Cave LLP, to revise its opinion to state clearly that the disclosure in the tax consequences section of the prospectus is the opinion of Bryan Cave LLP (not just that it is accurate).

Response to Comment 6:

Bryan Cave has revised its tax opinion as requested by the Staff in the first bullet point of Comment 5 above.  The revised tax opinion is filed as Exhibit 8.2 to Amendment No. 2.  In response to Comment 6, please note that the requested disclosure is provided in the fifth paragraph of the tax opinion.

If you have any questions or comments related to these responses, please contact me at (864) 250-2207.

Sincerely,

/s/   John M. Jennings

John   M. Jennings

cc:   Michael   C. Crapps, President and Chief Executive Officer

3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
  CORPORATION FINANCE

        December 3, 2013

Via E -mail
Mr. Michael C. Crapps
President and Chief Executive Officer
First Community Corporation
5455 Sunset Blvd.
Lexington, South Carolina 29072

Re: First Community Corporation
Amendment No. 1 to Registration Statement on Form S -4
Filed  November 15, 2013
File No. 333-191652

Dear  Mr. Crapps :

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.

Form S -4

General

1. We note that Savannah has provided projections of revenue, income, and income per
share to FCCO.  The staff considers two years of these projections material.  Please
revise your disclosure to include these projections.

Interests of Directors and Office rs of Savannah River, page 9

2. We acknowledge your response to comment 4 of our letter to you dated November 6,
2013.  Please add disclosure regarding the interests of officers and directors in
severance benefits and any other compensation from Savannah rel ating to the merger.

Mr. Michael C. Crapps
First Community Corporation
December  3, 2013
Page 2

 Risk Factors, page, page 33
Risks Related to the Merger, page 33

3. We acknowledge your response to comment 12 of our letter to you dated November
6, 2013.  Please revise to explain that the risk to shareholders (and the amount that
may be subject to tax) depends on the extent to which each shareholder has a gain on
the exchange of their stock in Savanah for cash and/or stock in First Community.

Important Federal Income Tax Consequences, page 86

4. Please revise your disclosure in the first sentence to state the discussion constitutes
the opinion of Nelson Mullins and Bryan Cave, rather than merely summarizes the
tax consequences .

Exhibit 8.1 Tax Opinion

5. We acknowledge your response to comment 24 of our letter to you dated November
6, 2013.  As we requested, please direct counsel, Nelson Mullins Riley &
Scarborough LLP, to revise its opinion as follows:
 state clearly that the disclosure in the tax consequences section of the
prospectus is the opinion of Nelson Mullins (not just that i t is accurate); and
 revise the last paragraph so that it does not limit reliance except as permitted
by Staff Legal Bulletin 19 (October 14, 2011).

Exhibit 8.2 Tax Opinion

6. We acknowledge your response to comment 25 of our letter to you dated November
6, 2013.  As we requested, please direct counsel, Bryan Cave LLP, to revise its
opinion to state clearly that the disclosure in the tax consequences section of the
prospectus is  the opinion of Bryan Cave LLP (not just that it is accurate).

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Act of 1933 and all  applicable Securities Act rules require.   Since the company and its
management are in possession of all facts relating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the
effective date of the pending regist ration statement please provide  a written statement
from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

Mr. Michael C. Crapps
First Community Corporation
December  3, 2013
Page 3

  the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve th e company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and
 the company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any pers on under
the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will
consider a written request for acceleration of the effective date of the registration
statement as confirmation of the fact that those requesting acceleration are aware of their
respective responsibilities under the Securities Act of 1933 and the Securities Exchange
Act of 1934 as they relate to the proposed public offering of the securities specified in the
above regi stration statement.  Please allow adequate time  for us to review any
amendment prior to the requested effective date of the registration statement.

You may contact William Schroeder at (202)  551-3294  or Michael Volley  at (202)
551-3437 if you have questions regarding comments on the financial statements and
related matters.  You may contact either Jonathan E. Gottlieb at (202) 551 -3416 or Kate
McHale at (202) 551 -3464 with any other questions.

Sincerely,

/s/ Kathryn McHale

Kathryn McHale
Staff Attorney

CORRESP
1
filename1.htm

Nelson

Mullins

Nelson Mullins Riley & Scarborough LLP

Attorneys and Counselors at Law

104 South Main Street / Ninth Floor / Greenville, SC  29601

Tel: 864.250.2300    Fax: 864.232.2925

www.nelsonmullins.com

John M. Jennings

(Admitted in IL NC & SC)

Tel: 864.250.2207

Fax: 864.232.2925

john.jennings@nelsonmullins.com

November 15, 2013

Via Electronic Mail

Ms. Kathryn McHale

Senior Staff Attorney

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:                        First Community Corporation

Registration Statement on Form S-4

Filed October 10, 2013

File No. 333-191652

Dear Ms. McHale:

This letter is provided on behalf of First Community Corporation (the “Company,” “First Community,” “we,” or “our”) in response to the comments of the Staff of the Securities and Exchange Commission (the “Commission”) dated November 6, 2013 (the “Comment Letter”) with respect to the Company’s Registration Statement on Form S-4 (the “Form S-4”) filed October 10, 2013; File No. 333-191652.  This letter is being filed with the Commission electronically via EDGAR.

For ease of reference, we have repeated each of the Commission’s comments below, followed by the corresponding responses of First Community.

Comment Letter dated November 6, 2013

Form S-4

General

1.                                Please revise to include updated financial statements noting the updating requirements of Rule 8-08 of Regulation S-X.  Please also provide an updated consent from your independent accountant in your next pre-effective amendment.

Response to Comment 1:

The Company has updated the financial statements and related disclosures in the Amendment No.1 to the Registration Statement on Form S-4 filed October 10, 2013 (“Amendment No.1”) as of and for the nine and three month periods ended September 30, 2013, in accordance with the updating requirements of Rule 8-08 of Regulation S-X.  The Company has also provided updated consents from its and Savannah River Financial Corporation’s independent accountants as Exhibits 23.1 and 23.2 to Amendment No.1.

With offices in the District of Columbia, Florida, Georgia, Massachusetts, North Carolina, South Carolina, Tennessee and West Virginia

2.                                Please provide us with copies of the board books that were provided to the respective boards of directors and any additional financial projections, reports, or presentations that may have been exchanged.

Response to Comment 2:

The Company is providing supplementally to the Staff under separate cover copies of the board books and any additional financial projections, reports, or presentations provided by FIG Partners, LLC to the Company’s board of directors.  The Company understands that Savannah River Financial Corporation (“Savannah River”) will also be providing supplementally to the Staff under separate cover copies of the board books and any additional financial projections, reports, or presentations provided by Allen C. Ewing & Co. to Savannah River’s board of directors.

Front Cover Page of Prospectus/Proxy Statement

3.                                Please indicate the number of securities offered.  See Item 501(b)(2) of Regulation S-K.

Response to Comment 3:

The Company has revised the front cover page of Amendment No.1 to include the requested disclosure.

Summary, Page 6

Interests of Directors and Officers of Savannah River that Differ from Your Interests, page 10.

4.                                Please revise to quantify the aggregate interest in the transaction of each Director and Officer.

Response to Comment 4:

In response to the Staff’s comment, the disclosure under this heading has been revised to quantify the aggregate interest in the transaction of each director and officer other than, in accordance with the Instruction to Paragraph (a) of Item 5 of Schedule 14, any interest arising from the ownership of securities of the registrant where the security holder receives no extra or special benefit no shared on a pro rata basis by all other holders of the same class.

2

5.                                Please revise your disclosure to identify the three Directors who have been identified to serve on the Board (Messrs. Potter, Reynolds, and Simon).  In addition, with regard to these Directors and any executive officer who will serve after the merger, please provide the information required by Item 18(a)(7) of Form S-4.

Response to Comment 5:

In response to the Staff’s comment, the disclosure has been revised to specifically identify Messrs. Potter, Reynolds and Simon as the Savannah River directors who will be appointed to the board of First Community following the merger.  The information required by Item 18(a)(7) with respect to these appointees appears under the heading “Management of First Community—Directors and Executive Officers—Directors” and “—Information Regarding Director Nominees.”  In addition, information regarding their beneficial ownership of First Community common stock after the effective time of the merger appears under the heading “Security Ownership of Certain Beneficial Owners and Management of First Community.”  None of Messrs. Spears, Lewis and Wahl will be executive officers of First Community after the effective time of the merger.

Federal Income Tax Consequences, page 10

6.                                Please summarize the reasons why your counsel cannot opine on whether or not the merger qualifies as reorganization.

Response to Comment 6:

We have revised the Federal Income Tax Consequences section on page 11 of Amendment No.1 to summarize the reason (the facts are currently unknown) that counsel cannot opine on whether or not the merger qualifies as a reorganization.

Comparative Rights of Shareholders, page 11

7.                                As required by Item 4(a)(4) of Form S-4, provide an explanation of any material differences between the rights of security holders of the company being acquired and the rights of holders of the securities being offered.  In addition, provide a cross-reference to the more detailed section discussing comparative rights.

Response to Comment 7:

The Company has revised the disclosure on pages 11-12 of Amendment No.1 to provide a more detailed explanation of the material differences between the rights of shareholders of Savannah River and the rights of shareholders of First Community.  In addition, a cross-reference to the more detailed section discussing comparative rights has been added at the end of this section.

Dissenters’ Rights, page 14

8.                                Please remove the qualification in the last sentence of the first paragraph of this section and the same qualification on page 82.

Response to Comment 8:

The Company has revised the disclosure regarding dissenters’ rights on pages 15 and 85-86 of Amendment No.1 to remove the qualification noted by the Commission.

3

9.                                Please revise the second paragraph in this section and the last paragraph on page 82 to state, consistent with Instruction to Item 3 of Schedule 14A, whether a security holder’s failure to vote against the merger will constitute a waiver of his dissenters’’ rights and if the Sate law is unclear, state what position will be taken in regard to these matters.

Response to Comment 9:

The Company has also revised the disclosure regarding dissenters’ rights on pages 15 and 85-86 of Amendment No.1 to state that a Savannah River shareholder’s failure to vote against the merger will not constitute a waiver of his or her dissenters’ rights but to clarify that a vote against the merger alone is not sufficient to perfect such shareholder’s dissenters’ rights under the Georgia Business Corporation Code.

Unaudited Pro Forma Condensed Combined Financial Information, page 20

10.                         Please revise to present the unaudited pro forma consolidated statements of income dated June 30, 2013 as if the merger had been consummated on January 1, 2012 as opposed to January 1, 2013 as described on page 20.  Refer to Rule 11-02(b)(6) of Regulation S-X for guidance.

Response to Comment 10:

The Company has revised the unaudited pro forma condensed combined financial information included in Amendment No.1 to be as of and for the nine month period ended September 30, 2013 and for the year ended December 31, 2012.  In addition, the unaudited pro forma consolidated statements of income dated September 30, 2013, have been revised to present such information as if the merger had been consummated on January 1, 2012, as opposed to January 1, 2013, as previously described.

11.                         Please revise Note 5 to present the calculation of the purchase price in a tabular format that clearly shows how each component is calculated.

Response to Comment 11:

The Company has revised Note 5 to the unaudited pro forma condensed combined financial information included in Amendment No.1 to present the calculation of the purchase price in a tabular format that more clearly shows how each component has been calculated.

Risk Factors, page 32

Risks Related to the Merger, page 32

12.                        Please add a new first risk factor addressing the tax consequences.

Response to Comment 12:

The Company has added a new first risk factor addressing the tax consequences of the merger on page 33 of Amendment No.1.

4

13.                         Please add a risk factor relating to the fairness opinion of Ewing to address risks that Ewing may have been influenced by the benefits it will receive from the merger since it has a conflict of interest since a fund it operates has held 50,000 shares of Savannah stock since 2005, a public market for the stock has not developed and the merger will allow its investors to cash out of the investment.

Response to Comment 13:

The Company has added a risk factor on page 37 of Amendment No.1 to address the risk that Ewing may have been influenced by the benefits one of its affiliates would have received upon consummation of the merger prior to an in-kind distribution of the shares to the limited partners of the affiliate.

Risks Related to First Community — the Combined Company, page 35

14.                         Please revise the two risk factors on page 37 (relating to construction, commercial mortgage and commercial loans and loans secured by real estate) and the two risk factors on page 38 (relating to commercial real estate loans and commercial business loans) to address how each of these four risks will be increased or decreased by the merger including the extent to which the amount and percentage of the respective types of loans would be increased by the merger.

Response to Comment 14:

The Company has revised the two risk factors previously on page 37 of the Form S-4 (relating to construction, commercial mortgage and commercial loans and loans secured by real estate), which are now on page 39 of Amendment No.1, and the two risk factors on page 38 of the Form S-4 (relating to commercial real estate loans and commercial business loans), which are now on pages 40-41 of Amendment No.1, to address how each of these risks will be increased or decreased by the merger, including to the extent to which the amount and percentage of the respective types of loans will be increased by the merger.

15.                         Please revise the first risk factors on page 41 (relating to changes in prevailing interest rates) to include risks relating to the amount and percentage of your loan portfolio that is adjustable and that may result in higher rates of delinquency and default if interest rates rise.  Address how this risk will be increased or decreased by the merger including the extent to which the amount and percentage of adjustable loans would be increased by the merger.

Response to Comment 15:

The Company has revised the first risk factor on page 41 of the Form S-4 (relating to changes in prevailing interest rates), which is now on page 43 of Amendment No.1, to include risks relating to the amount and percentage of your loan portfolio that is adjustable and that may result in higher rates of delinquency and default if interest rates rise.  In addition, the Company has addressed how this risk will be increased or decreased by the merger, including the extent to which the amount and percentage of adjustable loans would be increased by the merger.

5

Background of the merger, page 55

16.                         Please revise this section as follows:

·                  revise the fifth paragraph on page 56 to identify the “selected comparable company transactions” that your CEO and the CEO of Savannah reviewed and on which you proposed the initial terms of the merger.

·                  revise the fourth paragraph on page 57, the eight paragraph in page 58 and the first paragraph on page 59 to disclose more detail regarding the proposals and counterproposals for employment and compensation of directors and officers of Savannah; and

·                  revise the fourth paragraph on page 59 to disclose more detail regarding the term of the various drafts and the “various areas of disagreement” and “compromises on both sides” to which you refer and to explain the basis on which counsel advised Messrs Potter and Spears to abstain but did not advise Chairman of the Board Mr. Simon to abstain.

Response to Comment 16:

Response to First Bullet Comment

The disclosure on page 58 of Amendment No.1 has been revised to state (new language underlined, deleted language in <strikethrough>):  “Mr. Crapps and Mr. Potter met on May 13, 2013.  They discussed <reviewed information regarding selected comparable company transactions> the market with respect to community bank mergers and First Community’s proposal that the companies consider a strategic combination in which Savannah River’s shareholders would receive merger consideration with a value of $10.00 per share of Savannah River stock, consisting of 50% cash and 50% First Community common stock.”

In the May 13, 2013 meeting, Mr. Crapps and Mr. Potter discussed many aspects of the proposed business combination and the potential merger consideration.  Mr. Crapps provided to Mr. Potter a list of 51 community bank transactions, and they discussed, among many other matters discussed during this meeting, these transactions generally. Mr. Crapps and Mr. Potter did not focus on individual community bank transactions on the list.

The transactions in the list provided by First Community on May 13, 2013 were provided with a view toward negotiations.  Savannah River did not rely on the transactions provided by First Community.  After this meeting, Savannah River held discussions with Allen C. Ewing & Co., its financial advisor, and Savannah River subsequently negotiated proposed merger consideration of $11.00 per share, compared to the $10.00 per share that was proposed by First Community at the May 13 meeting. Savannah River relied on the analysis, advice and fairness opinion of Allen C. Ewing & Co., which is summarized in the Form S-4.  First Community relied on the analysis, advice and fairness opinion of FIG, which is summarized in the Form S-4.

As a result, First Community believes that it would be unusual, confusing and potentially misleading to identify in the Background of the Merger section 51 transactions that were provided by First Community to Savannah River. Accordingly, First Community has revised the disclosure as set forth on page 58 of Amendment No.1.

The list of transactions provided on May 13, 2013 is being provided by First Community to the Staff supplementally under separate cover.

6

Response to Second Bullet Comment

The Company has revised pages 59-62 of Amendment No.1 to include the requested disclosure.

Response to Third Bullet Comment

The analysis of counsel to Savannah River is as follows.

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
  CORPORATION FINANCE

        November 6 , 2013

Via E -mail
Mr. Michael C. Crapps
President and Chief Executive Officer
First Community Corporation
5455 Sunset Blvd.
Lexington, South Carolina 29072

Re: First Community Corporation
Registration Statement on Form S -4
Filed  October 10, 2013
File No. 333-191652

Dear  Mr. Crapps :

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 yo ur response.

After reviewing any amendment to your registration statement and the
information you provide in response to these  comments, we may have  additional
comments.

Form S -4
General
1. Please revise to include updated financial statements noting the updating
requirements of Rule 8 -08 of Regulation S -X. Please also provide an updated consent
from your independent accountant in your next pre -effective amendment.

2. Please provide us with c opies of the board books that were provided to the respective
boards of directors and any additional financial projections, reports, or presentations
that may have been exchanged.

Mr. Michael C. Crapps
First Community Corporation
November  6, 2013
Page 2

 Front Cover Page of Prospectus/Proxy Statement

3. Please indicate the number  of securities offered.  See Item 501(b)(2) of Regulation S -
K.

Summary, page 6

Interests of Directors and Officers of Savannah River the Differ from Your Interests,
page 10

4. Please revise to quantify the aggregate interest in the transaction of each Dir ector and
Officer.

5. Please revise your disclosure to identify the three Directors who have been identified
to serve on the Board (Messrs. Potter, Reynolds, and Simon).  In addition, with regard
to these Directors and any executive officer who will serve a fter the merger, please
provide the information required by Item 18(a)(7) of Form S -4.

Federal Income Tax Consequences, page 10

6. Please summarize the reasons why your counsel cannot opine on whether or not the
merger qualifies as reorganization.

Comparative Rights of Shareholders, page 11

7. As required by Item 4(a)(4) of Form S -4, provide an explanation of any material
differences between the rights of security holders of the company being acquired and
the rights of holders of the securities being offered.  In addition, provide a cross -
reference to the more detailed section discussing comparative rights.

Dissenters Rights, page 14

8. Please remove the qualification in the last sentence of the first paragraph of this
section and the same qualificati on on page 82.

9. Please revise the second paragraph in this section and the last paragraph on page 82 to
state, consistent with Instruction to Item 3 of Schedule 14A, whether a security
holder's failure to vote against the merger will constitute a waiver of  his dissenters’
rights and if the State law is unclear, state what position will be taken in regard to
these matters.

Mr. Michael C. Crapps
First Community Corporation
November  6, 2013
Page 3

 Unaudited Pro Forma Condensed Combined Financial Information, page 20

10. Please revise to present the unaudited pro forma consolidated stat ements of income
dated June 30, 2013 as if the merger had been consummated on January 1, 2012 as
opposed to January 1, 2013 as described on page 20.  Refer to Rule 11 -02(b)(6) of
Regulation S -X for guidance.

11. Please revise Note 5 to present the calculation  of the purchase price in a tabular
format that clearly shows how each component is calculated.

Risk Factors, page, page 32

Risks Related to the Merger, page 32

12. Please add a new first risk factor addressing the tax consequences.

13. Please add a risk fact or relating to the fairness opinion of Ewing to address risks that
Ewing may have been influenced by the benefits it will receive from the merger since
it had a conflict of interest since a fund it operates has held 50,000 shares of
Savannah stock since 20 05, a public market for the stock has not developed and the
merger will allow its investors to cash out of the investment.

Risks Related to First Community – the Combined Company, page 35

14. Please revise the two risk factors on page 37 (relating to constr uction, commercial
mortgage and commercial loans and loans secured by real estate) and the two risk
factors on page 38 (relating to commercial real estate loans and commercial business
loans) to address how each of these four risks will be increased or dec reased by the
merger including the extent to which the amount and percentage of the respective
types of loans would be increased by the merger

15. Please revise the first risk factors on page 41 (relating to changes in prevailing
interest rates) to include ri sks relating to the amount and percentage of your loan
portfolio that is adjustable and that may result in higher rates of delinquency and
default if interest rates rise.   Address how this risk will be increased or decreased by
the merger including the ex tent to which the amount and percentage of adjustable
loans would be increased by the merger.

Mr. Michael C. Crapps
First Community Corporation
November  6, 2013
Page 4

 Background of the merger, page 55

16. Please revise this section as follows:
 revise the fifth paragraph on page 56 to identify the “selected comparable
company transactions” that your CEO and the CEO of Savannah reviewed and on
which you proposed the initial terms of the merger;
 revise  the fourth paragraph on page 57, the eighth paragraph in page 58 and the
first paragraph on page 59 to disclose more detail regar ding the proposals and
counterproposals for employment and compensation of directors and officers of
Savannah; and
 revise the fourth paragraph on page 59 to disclose more detail regarding the term
of the various drafts and the “various areas of disagreemen t” and “compromises
on both sides” to which you refer and to explain the basis on which counsel
advised Messrs Potter and Spears to abstain but did not advise Chairman of the
Board Mr. Simon to abstain.

Opinion of Savannah River’s Financial Advisor, page  62

17. Please revise this section as follows:
 revise the last paragraph on page 68 to quantify the  total amount of fees to be paid
 disclose detail regarding the indemnification including whether it would cover
issues relating to conflict of interest;
 revise the first paragraph on page 69 to disclose all economic interests of Ewing
in the Fund and the percent of Funds assets represented by the 50,000 shares of
Savannah River stock.

Opinion of Firs t Community's Financial Advisor, page 71

18. Please disclose the fees paid and to be paid to FIG by First Community.

Interests of Directors and Officers of Savannah River the Differ from Your Interests,
page 83

19. As required by Item 5 of Schedule 14A, please revise this section to identify and
quantify any substantial interest, direct or indirect, by each person who has been a
director or executive officer of Savannah River.

Mr. Michael C. Crapps
First Community Corporation
November  6, 2013
Page 5

 Important Federal Income Tax Conseq uences, page 83

20. Please revise the first sentence of this section to clearly state that counsel is unable to
opine as to the tax consequences of the merger rather than stating the summary of
anticipated considerations is the opinion of counsel.  See Staff Legal Bulletin 19 (Oct
14, 2011).

Exhibits

21. In accordance with Item 601(b)(10) of Regulation S -K, please file all material
agreements, including the employment, consulting and retention agreements
referenced on pages 89 -90.

Exhibit 5.1 Opinion

22. Please  revise the last paragraph.  You may limit your opinion as to subject but not as
to who may rely upon it.

Fairness Opinions, Appendix C

23. We note the opinion of Allen S. Ewing requires their consent to be included in a
proxy statement.  Please revise you r disclosure to confirm that they have prepared or
approved the inclusion and summary of their opinion.

Exhibit 8.1 Tax Opinion

24. Please revise your opinion to clearly state that the discussion in the registration
statement constitutes your opinion (not just that it is accurate) and revise the last
paragraph so that it does not limit reliance except as permitted by Staff Legal Bulletin
19 (October 14, 2011).

Exhibit 8.2 Tax Opinion

25. Please revise your opinion to clearly state that the discussion in the registration
statement constitutes the opinion of counsel and revise the last paragraph so that it
does not limit reliance except as permitted by Staff Legal Bulletin 19 (October 14,
2011).

Mr. Michael C. Crapps
First Community Corporation
November  6, 2013
Page 6

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Act of 1933 and all applicable Securities Act rules require.   Since the company and its
management are in possession of all facts relating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the
effective date of the pending regist ration statement please provide  a written statement
from the company acknowledging that:
 should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commissio n from taking any
action with respect to the filing;
 the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy and accur acy of the disclosure in the filing; and
 the company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will
consider a written request for acceleration of the effective date of the registration
statement as confirmation of the fact that those requesting acceleration are aware of their
respective responsibilities under the Securities Act of 1933 and the Securities Exchange
Act of 1934 as they relate to the proposed public offering of the securities specified in the
above registration statement.  Please allow adequate time  for us to review any
amendment prior to the requested effective date of the registration statement.

You may contact William Schroeder at (202)  551-3294  or Michael Volley  at (202)
551-3437 if you have questions regarding comments on the financial statements and
related matters.  You may contact either Jonathan E. Gottlieb at (202) 551 -3416 or Kate
McHale at (202) 551 -3464 with any other questions.

Sincerely,

 /s/Mark Webb for

Kathryn McHale
Senior Staff Attorney

Mr. Michael C. Crapps
First Community Corporation
November  6, 2013
Page 7

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Nelson

Mullins

Nelson Mullins Riley & Scarborough LLP

Attorneys and Counselors at Law

John M. Jennings

104 South Main Street / Ninth Floor / Greenville, SC 29601

Tel: 864.250.2207

Tel: 864.250.2300 Main Fax: 864.232.2925

Fax: 864.250.2349

www.nelsonmullins.com

john.jennings@nelsonmullins.com

October 9, 2013

Mr. Mark S. Webb, Esq.

Legal Branch Chief

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

RE:                           First Community Corporation

Registration Statement on Form S-4

Registration No. 333-

Dear Mr. Webb:

On behalf of First Community Corporation (“First Community”), I am transmitting for filing under the Securities Act of 1933 (the “Act”), a Registration Statement on Form S-4 relating to the merger involving First Community, Savannah River Financial Corporation and each companies’ respective banking subsidiaries.

In connection with the review of this filing, we would like to advise the Staff that, as disclosed in the Form S-4, certain of the named executive officers of Savannah River Financial Corporation will receive “golden parachute” compensation as described in Item 402(t) of Regulation S-K.  However, pursuant to guidance we received from the Staff of the Office of Mergers & Acquisitions, First Community is not required to hold a say-on-golden parachute vote in connection with these payments and the merger.  In this regard, we note that Savannah River Financial Corporation is not subject to Section 13 or 15(d) of the Exchange Act, and no “golden parachute” compensation is to be received by the named executive officers of First Community.

Please direct any questions or comments regarding this filing to the undersigned at (864) 250-2207.

Very   truly yours,

/s/   John M. Jennings

John   M. Jennings

CORRESP
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FIRST COMMUNITY CORPORATION

5455 Sunset Boulevard

Lexington, South Carolina 29072

(803) 951-2265

August 17, 2012

Michael Clampitt

Senior Attorney Advisor

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street NE

Washington, D.C. 20549

Re:          First Community Corporation (the “Registrant”)
  Registration Statement on Form S-1 (File No. 333-182938)

Dear Mr. Clampitt:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Registrant hereby requests that the effective date for the above-referenced Registration Statement be accelerated so that it will be declared effective under the Securities Act at 9:00 a.m., New York City time, on Tuesday, August 21, 2012.

In connection with this request, the Registrant hereby acknowledges that:

1.             should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

2.             the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

3.             the Registrant may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[Remainder of the Page Intentionally Left Blank]

Very   truly yours,

First   Community Corporation

By:

/s/   Joseph G. Sawyer

Name:

Joseph   G. Sawyer

Title:

Chief   Financial Officer

August 17, 2012

Michael Clampitt
 Division of Corporation Finance
 Securities and Exchange Commission
 Washington, D.C. 20549

Re:          First Community Corporation

Registration Statement on Form S-1 (SEC File No. 333-182938)

Dear Mr. Clampitt:

In connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), we hereby join in the request of First Community Corporation that the effective date of the Registration Statement be accelerated so that it will be declared effective at 9:00 a.m., Eastern Time, on August 21, 2012 or as soon thereafter as practicable.

Pursuant to Rule 460 under the Act, please be advised the undersigned intends to effect the following approximate distribution of copies of the Preliminary Prospectus to be dated August 21, 2012:

No. of Copies

Institutions

850

Others

100

Total

950

[SIGNATURE PAGE FOLLOWS]

Very truly yours,

MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED
 SANDLER O’NEILL & PARTNERS, L.P.

By:

MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED

By:

/s/ William D. Hobbs

Name: William D. Hobbs

Title: Managing Director

By:

SANDLER O’NEILL & PARTNERS, L.P.

By:

Sandler O’Neill & Partners Corp.,

the sole general partner

By:

/s/ Robert A. Kleinert

Name: Robert A. Kleinert

Title: An Officer of the Corporation

For themselves and as Representatives of the other Underwriters

CORRESP
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Nelson

Mullins

Nelson Mullins Riley & Scarborough LLP

Attorneys and Counselors at Law

104 South Main Street / Ninth Floor /   Greenville, SC  29601

Tel: 864.250.2300  Fax: 864.232.2925

www.nelsonmullins.com

Nikki Lee

Tel: 864.250.2367

Nikki.Lee@nelsonmullins.com

August 14, 2012

Mr. Michael Clampitt

Senior Attorney Advisor

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:

First Community Corporation

Registration Statement on   Form S-1

Amended August 8, 2012

File No. 333-182938

Dear Mr. Clampitt:

This letter is provided on behalf of First Community Corporation (the “Company,” “we,” or “our”) in response to the comment letter from the Securities and Exchange Commission (the “SEC” or the “Commission”), dated August 13,  2012 (the “Comment Letter”), related to its review of the Company’s Registration Statement on Form S-1 amended on August 8,  2012 (File No. 333-182938) (the “Registration Statement”).  This letter and the Company’s Pre-Effective Amendment No. 3 to the Form S-1 are being filed with the Commission electronically via EDGAR.

This letter sets forth the Company’s responses to the SEC’s Comment Letter.  For your convenience, we have also restated the SEC’s comment prior to our response.

Prospectus Cover Page

1.                                      The principal underwriter must be named on the cover.  In addition, the minimum price must also be disclosed.  Please confirm that the registrant will file a pre-effective amendment naming the underwriters and disclosing the minimum price.

RESPONSE:

We will include the names of the underwriters and disclose the minimum price in a pre-effective amendment to the Registration Statement.

Incorporation, page S-4

2.                                      Update to include your latest Form 10-Q, for the quarter ended June 30, 2012, filed August 10, 2012.

RESPONSE:

We have updated the registration statement to incorporate by reference the Form 10-Q for the quarter ended June 30, 2012 and to include financial information as of June 30, 2012.

3.                                      If there are specific suitability standards for bidders, such as a minimum net worth, please summarize these factors under appropriate subheading, with quantification.  If there are none, so state.

RESPONSE:

We advise the Staff that as disclosed on page S-40 of the Registration Statement, each auction agent, network broker and any other broker that submits bids through the auction agents or any network broker will individually apply its own suitability standards in accordance with the applicable requirements and guidelines of FINRA in evaluating whether an investment in the Preferred Shares is appropriate for any particular investor.  No minimum net worth standard is being required of such auction agents or brokers in individually setting and applying their own suitability standards in accordance with applicable laws and regulations.

Auction Process, page S-7

4.                                      At the first paragraph on page S-8, for the first and second set of capital ratios, please clarify that you are assuming that you acquire all of the preferred shares.  Note also for the next table.

RESPONSE:

The requested disclosure has been added to page S-8 of the Registration Statement.

Bid Submission Deadline, page S-9

5.                                      Please disclose that bidders using brokers who are not a “network broker” for the offering may have less time to submit a bid.  Taking into account that the bidding period is only two days, quantify the impact of this situation, both here and at the related risk factor on page S-32.  As a result, you may also want to encourage investors to use a network broker to place their bids.

RESPONSE:

We advise the Staff that as described in the risk factor, placing bids with an auction agent is the most efficient approach to place bids since both network brokers and non-network  brokers impose earlier deadlines, as much as one day, to allow time to aggregate the customers’ bids and transmit them to the

auction agents.  In response to the Staff’s comment, the Company has revised the disclosure on pages S-40 and S-43 of the Registration Statement and the risk factor on page S-32 of the Registration Statement informing investors of the potential for delay which we believe could be up to a day and that investors concerned with timely submission should place bids with the auction agents.

General Underwriting

6.                                      Supplementally advise the staff if any of the underwriters who have participated in developing the minimum price for this offering, or who have assisted your company in any capital raising activities in the last year, have any affiliates or other related parties that intend to participate in the bidding.

RESPONSE:

We advise the Staff that the underwriters do not develop the minimum price.  The underwriters and the Treasury’s advisors, if and to the extent requested by the Treasury, may each provide their independent views on the minimum price for the Treasury to consider.  The minimum price is ultimately independently determined by the Treasury based on its own pricing model.  In addition, the Company advises the Staff that the underwriters have not assisted the Company in capital raising activities in the past 12 months and that entities that are affiliates or related parties of the respective underwriters may or may not participate in the bidding; however none of the underwriters share any non-public information, including any views on the minimum price, with such affiliates or related parties.

If you have any questions or comments related to our responses, please contact me at (864) 250-2367 or nikki.lee@nelsonmullins.com.  Please copy Joseph G. Sawyer, Chief Financial Officer of the Company, at jsawyer@firstcommunitysc.com on any written comments regarding our responses.

Sincerely,

/s/ Nikki Lee

Nelson Mullins Riley & Scarborough   LLP

cc:

Joseph G. Sawyer, Chief Financial Officer

First Community Corporation

August 13 , 2012

Via Email
Mr. Michael C. Crapps
President and Chief Executive Officer
First Community Corporation
5455 Sunset Boulevard
Lexington, South Carolina  29072

Re:  First Community Corporation
        Registration Statement on Form S-1
        Amended August 8 , 2012
        File number 333 -181437

Dear Mr. Crapps :

We have  limited our review of your  registration statement  to those issues we have
addressed in our 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 informat ion.  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
provi de in response to these  comments, we may have  additional comments.

Prospectus Cover Page

1. The principal underwriter must be named on the cover. In addition, the minimum price
must also be disclosed. Please confirm that the registrant will file a pre -effective
amendment naming the underwriters and disclosing the minimum price.

Incorporation, page S -4

2. Update to include your latest Form 10 -Q, for the quarter ended June 30, 2012, filed
August 10, 2012.

3. If there are specific suitability standards for bidd ers, such as a minimum net worth, please
summarize these factors under appropriate su bheading, with quantification. If there are
none, so state.

Mr. Michael C. Crapps
First Community Corporation
August 13, 2012
Page 2

Auction Process, page S -7

4. At the first paragraph on page S -8, for the first  and second set of capital  ratios, please
clarify that you are assum ing that you acquire s all of the preferred shares.  Note also for
the next table.

Bid Submission Deadline, page S -9

5. Please disclose that bidders using brokers who are not a “network broker” for the offering
may have less time to submit a bid.  Taking into account that the bidding period is only
two days, quantify the impact of this situation, both here and at the relate d risk factor on
page S -32.  As a result, you may also want to encourage investors to use a network
broker to place their bids.

General
Underwriting

6. Supplementally advise the staff  if any of the  underwriters  who have  participate d in
developing the minim um price  for this offering,  or who have  assisted your company  in
any capital raising activities in the last year, ha ve any affiliates or other related parties
that intend to participate in the bidding .

We urge all persons who are responsible for the acc uracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relat ing to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please p rovide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filin g;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

Mr. Michael C. Crapps
First Community Corporation
August 13, 2012
Page 3

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Secu rities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested eff ective date of the
registration statement.

 Please contact David Lyon  at 202-551-3421 or me  at 202-551-3434 wi th any questions.

Sincerely,

 /s/ Michael R. Clampitt

 Michael Clampitt
Senior Attorney Advisor

By Email to: Nikki Lee
                      Neil.Gray son@NelsonMullins.com

CORRESP
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First Community Corporation

5455 Sunset Blvd.

Lexington, South Carolina 29072

July 19, 2012

Via Facsimile and EDGAR

Mr. Michael Clampitt

Senior Attorney Advisor

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:                                                                             First Community Corporation

Registration Statement on Form S-1

Filed May 15, 2012, as amended

SEC File No. 333-181437

Dear Mr. Clampitt:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Registrant hereby requests that the effective date for the above-referenced Registration Statement be accelerated so that it will be declared effective under the Securities Act at 2:00 p.m., New York City time, on Monday, July 23, 2012, or as soon thereafter as may be practicable.

In connection with this request, the Registrant hereby acknowledges that:

1.                                       should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

2.                                       the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

3.                                       the Registrant may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please call Chad Lott of Nelson Mullins Riley & Scarborough LLP, counsel to the Registrant, at (864) 250-2323 as soon as the Registration Statement has been declared effective.

Very   truly yours,

First   Community Corporation

By:

/s/   Joseph G. Sawyer

Name:

Joseph   G. Sawyer

Title:

Chief   Financial Officer

Raymond James & Associates, Inc.

880 Carillon Parkway

St. Petersburg, Florida 33716

July 19, 2012

Via Facsimile and EDGAR

Mr. Michael Clampitt

Senior Attorney Advisor

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:                                                                             First Community Corporation

Registration Statement on Form S-1

Filed May 15, 2012, as amended

SEC File No. 333-181437

Dear Mr. Clampitt:

The undersigned hereby joins First Community Corporation in requesting that the effective date for the above-referenced Registration Statement be accelerated so that it will be declared effective at 2:00 p.m., New York City time, on Monday, July 23, 2012, or as soon thereafter as may be practicable, pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”).

Pursuant to Rule 460 under the Securities Act, in connection with the foregoing, please be advised that the undersigned has effected approximately the following distribution of copies of the Preliminary Prospectus dated July 13, 2012:

No. of Copies

Institutions

0

Others

45

Total

45

Very truly yours,

Raymond   James & Associates, Inc.

By:

/s/ Douglas F. Secord

Name:

Douglas F. Secord

Title:

Senior Vice President

CORRESP
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Nelson

Mullins

Nelson   Mullins Riley & Scarborough LLP

Attorneys   and Counselors at Law

John   M. Jennings

104   South Main Street / Ninth Floor / Greenville, SC 29601

Tel:   864.250.2207

Tel:   864.250.2300 Fax: 864.232.2925

John.jennings@nelsonmullins.com

www.nelsonmullins.com

June 22, 2012

Mr. Michael Clampitt

Senior Attorney Advisor

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

Re:                             First Community Corporation

Registration Statement on Form S-1

Filed May 15, 2012

File No. 333-181437

Dear Mr. Clampitt:

This letter is provided on behalf of First Community Corporation (the “Company,” “we,” or “our”) in response to the comment letter from the Securities and Exchange Commission (the “SEC” or the “Commission”), dated June 11, 2012 (the “Comment Letter”), related to its review of the Company’s Registration Statement on Form S-1 filed on May 15, 2012 (File No. 333-181437).  This letter sets forth the Company’s responses to the SEC’s Comment Letter.  For your convenience, we have also restated the SEC’s comment prior to our response.

Form S-1 filed May 15, 2012

Prospectus Cover Page

1.                                      Disclose the number of shares being offered. See Item 501(b)(2) of Regulation S-K.

RESPONSE:

Prior to circulating a preliminary prospectus and beginning the road show for the offering, we will file a pre-effective amendment to the registration statement that includes the number of shares to be offered.

2.                                      Disclose how the share price will be determined. See Instruction 2 to Item 501(b)(3) of Regulation S-K.

RESPONSE:

We have revised the cover page of the prospectus in accordance with the SEC’s comment.

3.                                      Revise the cover page to describe the nature of the underwriting commitment. We note from later disclosure in the prospectus that this is apparently to be a firm commitment offering. See Item 501(b)(8) of Regulation S-K.

RESPONSE:

We have revised the cover page of the prospectus in accordance with the SEC’s comment.

The Company, page 1

4.                                      Please disclose that you are operating under an MOU and an OCC regulatory agreement.

RESPONSE:

We have revised page 1 of the prospectus to disclose that First Community Bank, N.A. is currently operating under a formal written agreement with the Office of the Comptroller of the Currency and a memorandum of understanding with the Federal Reserve.

5.                                      Please disclose that over 70% of your loans are collateralized with commercial real estate. We note the related risk factor information at the bottom of page 19.

RESPONSE:

We have revised page 1 of the prospectus to disclose that approximately 70.7% of our outstanding loans as of March 31, 2012 were secured by commercial real estate.

Planned Repurchase of Our Preferred…, page 6

6.                                      Please disclose that, if completed, these repurchases will require the use of all or nearly all the proceeds of this offering.

RESPONSE:

We have revised page 6 of the prospectus to disclose that, if we repurchase the Series T Preferred Stock and the Warrant issued to the U.S. Treasury Department, these repurchases will require the use of all or substantially all of the net proceeds of this offering.

7.                                      Please update this section as of the most recent practicable date.

RESPONSE:

We have updated this section of the prospectus as of the most recent practicable date.

8.                                      Indicate the TARP related consequences for the company, e.g., less interest expense, and, what you will do with the offering proceeds if you are not allowed to pursue these repurchases.

RESPONSE:

We have updated this section of the prospectus in accordance with the SEC’s comments.

Regulatory Agreements, page 6

9.                                      Please revise to disclose if any of the terms of the MOU may have a material impact on your business operations and financial performance. Please also revise to disclose the terms of the agreement with the OCC. If you have already done this, please confirm supplementally.

RESPONSE:

We have revised this section of the prospectus in accordance with the SEC’s comments.

Exhibit Index

10.                               You will need to file any underwriting agreement as an exhibit. See Item 601 of Regulation S-K. Please revise.

RESPONSE:

We will file a copy of the underwriting agreement in a pre-effective amendment to the registration statement.

The Company acknowledges that:

·                  should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·                  the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·                  the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under federal securities laws of the United States.

If you have any questions or comments related to our responses, please contact me at (864) 250-2207 or john.jennings@nelsonmullins.com.  Please copy Joseph G. Sawyer, Chief Financial Officer of the Company, at jsawyer@firstcommunitysc.com on any written comments regarding our responses.

Sincerely,

/s/ John M. Jennings

Nelson Mullins Riley & Scarborough   LLP

cc:                                Joseph G. Sawyer, Chief Financial Officer

First Community Corporation

June 11, 2012
 Via Email

Mr. Michael C. Crapps President and Chief Executive Officer First Community Corporation 5455 Sunset Boulevard Lexington, South Carolina  29072
Re:  First Community Corporation
        Registration Statement on Form S-1         Filed May 15, 2012                                      File number 333-181437

Dear Mr. Crapps:

We have limited our review of your registra tion statement to those issues we have
addressed in our 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 re gistration statement and the information you
provide in response to these comments , we may have additional comments.

Prospectus Cover Page

1. Disclose the number of shares bei ng offered.  See Item 501(b)(2) of
            Regulation S-K
2. Disclose how the share price will be determin ed.  See Instruction 2 to Item 501(b)(3) of
Regulation S-K.

3. Revise the cover page to describe the natu re of the underwriting commitment.  We note
from later disclosure in the prospectus that this is apparently to be a firm commitment
offering.  See Item 501(b)(8) of Regulation S-K.

Mr. Michael C. Crapps First Community Corporation June 11, 2012 Page 2
 The Company, page 1

4. Please disclose that you are operating under an  MOU and an OCC regulatory agreement.

5. Please disclose that over 70% of your loan s are collateralized w ith commercial real
estate.  We note the relate d risk factor information at the bottom of page 19.
 Planned Repurchase of Our Preferred…, page 6

6. Please disclose that, if completed, these repurchases will require the use of all or nearly
all the proceeds of this offering.

7. Please update this section as of th e most recent practicable date.

8. Indicate the TARP rela ted consequences for the company, e.g., less interest  expense, and,
what you will do with the offering proceeds if you are not allowed to pursue these
repurchases.
 Regulatory Agreements, page 6

9. Please revise to disclose if any of the term s of the MOU may have a material impact on
your business operations and financial performan ce.  Please also revise to disclose the
terms of the agreement with the OCC.  If you have already done this, please confirm
supplementally.
 Exhibit Index

10. You will need to file any underwriting agr eement as an exhibit.  See Item 601 of
Regulation S-K.  Please revise.
  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:
 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

Mr. Michael C. Crapps First Community Corporation June 11, 2012 Page 3

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.            Please contact David Lyon at 202-551-3421 or  me at 202-551-3434 with any questions.

Sincerely,
   /s/ Michael R. Clampitt    Michael Clampitt
Senior Attorney Advisor
By Email to: Neil Grayson                       Neil.Grayson@NelsonMullins.com

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      September 9, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (803) 951-1722

Joseph G. Sawyer
Chief Financial Officer
First Community Corporation
5455 Sunset Boulevard
Lexington, South Carolina 29072

Re:	First Community Corporation
	Form 10-K filed March 25, 2005
	File No. 0-28344

Dear Mr. Sawyer:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K for the Year ended December 31, 2004

Description of Business, General, page 1

1. Please tell us and revise to state if you continue to qualify
as a
Small Business filer under the requirements of Item 10(a) and (b)
of
Regulation S-B after the acquisition of DutchFork Bancshares
("Dutchfork") in October 2004.  In this regard we note you filed a
10-KSB for the year ended December 31, 2004 but filed Form 10-Qs
for
the three and six month periods ended March 31, 2005 and June 30,
2005, respectively.

Provision and Allowance for Loan Losses, page 22

2. We refer to the statement that as of December 31, 2003
management
implemented a system for allocating the allowance for loan losses
to
specific components of the loan portfolio and that prior to that
date
the allowance was allocated on an overall portfolio basis.  In
this
regard, provide us with the following information:

* The authoritative accounting or regulatory basis you relied upon
prior to December 31, 2003 to use the overall portfolio basis for
allocating the loan loss allowance;

* The factors that prompted the Company to change its methodology
for
allocating the loan loss allowance in 2004.

* The effects on the allowance for loan losses due to the changes
in
the allocation methodology in 2004 as compared to prior periods.

3. We refer to the following statements by the Company regarding
how
it determined its loan loss allowance:

* The provision of $245,000 in 2004 maintained the allowance for
loan
loss within management`s desired levels.

* It was the objective of management to fund the allowance at
approximately 1.1% to 1.5% of total loan until a tested historical
experience has been established.

In this regard, please tell us the methodology that management
uses,
considering the requirements of SFAS 5 and SFAS 114, to determine
the
adequacy of the loan loss allowance.  Refer in your response to
how
you considered paragraph 9.19 of the AICPA Audit and Accounting
Guide
for Depository and Lending Institutions which states the allowance
for loan losses should be established in conformity with generally
accepted accounting principles rather than in accordance with
specified percentages.

4. We refer to the statement that the Company as of December 31,
2004
had no loans on a non-accrual status.   Please tell and revise to
explain the basis for this statement considering the following
factors:

* The Company recorded write-offs of $294,000 in 2004 and $235,000
in
2003 that appear to relate to non-performing loans that developed
in
2004 considering you only had $80,000 of non-performing loans in
2003.

* The large loan recovery in 2003 was due to a loan charged off
prior
to 2003 that was recovered during that year.  Refer to the
"Results
of Operations" section of MD&A on page 18.

* The apparent acquisition of $550,000 of non-performing loans as
part of the purchase of DutchFork in 2004.  Refer in your response
to
the status of the non-accrual loans described in Note 4, "Loans
Receivable" of the financial statements of DutchFork as of
September
30, 2003 in the Form S-4 filed on July 7, 2004.

5. Please tell us and revise to include the following information
regarding the increase in the allowance for loan losses of
$995,000
in 2004 resulting from the acquisition of DutchFork in October
2004:

* Explain how you determined the amount of the allowance for loan
losses of $995,000 acquired as a result of the merger with
DutchFork
in October 2004.

* Reconcile the $995,000 allowance carried over when you acquired
DutchFork to the allowance for loan losses for $153,000 of
DutchFork
stated in the unaudited pro forma balance sheet at March 31, 2004
on
page 21 of the Form S-4.

* Discuss how you considered Staff Accounting Bulletin Topic 2:A.5
regarding adjustments to the allowance for loan losses related to
business acquisitions.

6. Please tell us and revise to disclose the following information
regarding the non-performing assets totaling $749,000 disclosed on
page 13 of MD&A in the Form 10-Q for the period ended March 31,
2005:

* Explain why nonaccrual loans totaling $383,000 and foreclosed
real
estate for $346,000 were not described as potential problem loans
in
the Form 10-K for the year ended December 31, 2004.  Refer to
Section
III.C.2 of Industry Guide 3.

* Discuss the reasons for the significant increase in non-
performing
assets during the three-month period ended March 31, 2005
considering
the Company had no non-performing loans as of December 31, 2004.

* Discuss in MD&A if this increase in non-performing assets is
related to the acquisition of DutchFork Bancshares and if is
indicative of a trend that is expected to affect future operating
periods.

7. Tell us for each period presented the factors that influenced
management`s judgment in determining the amount of the additions
to
the allowance charged to operating expense.  Refer to Instruction
(2)
to Section IV.A of Industry Guide 3.

8. Tell us and revise to describe any concentrations of loans
exceeding 10% of the total loans which are not disclosed
separately
as a category of loans.  Refer to Item III.C.4 of Industry Guide
3.

9. Tell us and revise to discuss your consideration of SOP 03-3,
"Accounting for certain loans or debt securities acquired in a
transfer" which includes the prohibition of "carrying over" or
creation of valuation allowance in the initial accounting of loans
acquired in a purchase business combination.

MD&A, Loans, page 26

10. Revise to present the table of the loan portfolio by loan
category for each of the last five fiscal years.  Refer to
Instruction 3(b) of Industry Guide 3.

Report of Independent Auditor, page 33

11. We note you have not filed the Accountants report on
management`s
assessment of internal control over financial reporting and
Management`s annual report on internal control over financial
reporting required by PCAOB Auditing Standards No. 2.  In this
regard, tell us and revise to state if you qualify for the
extended
compliance period in SEC Release 33-8392 for small business
issuers
or non-accelerated filers for implementing Section 404 of the
Sarbanes Oxley Act.

Note 2, Summary of Significant Accounting Policies, page 38

Mortgage Origination Fees

12. We refer to the mortgage origination fees of $268,000 in 2004.
Please tell us and revise to describe your accounting policies
with
respect to mortgage origination fees on loans held for resale and
loans held for investment.  Refer to paragraph 20 of SFAS 65 as
amended by paragraph 27(c) of SFAS 91.

13. Tell us and revise to discuss in MD&A the reasons for the 22%
decrease in mortgage origination fees in 2004.

Note 4, "Investment Securities", page 42

14. We refer to the "Equity and other securities" investments
available for sale for $55.1 million which had gross unrealized
losses of $1.136 million as of December 31, 2004.   Considering
you
had no investments in equity securities in 2003, please tell us
and
revise to provide the following information:

* Describe the major types of equity investments and their risk
characteristics, including the unsold portion of the investments
in
preferred stock of $106.3 million with a gross unrealized loss of
$1.8 million that were acquired from DutchFork.  Refer to Note 3,
"Investments and Mortgage Backed Securities" of the DutchFork
financial statements for the fiscal year ended September 30, 2003
on
page 30 of the Form S-4 filed on July 8, 2004.

* Discuss the basis for considering that the gross unrealized
losses
of $1.136 million related to these equity investments are other
than
temporary impairments.

* State the amount of preferred stock sold, the gain or loss
recognized on their sale and if the sale was made on a recourse or
non-recourse basis.  For sales made on a recourse basis, state the
amount of recourse liability recorded as required by paragraph 11
of
SFAS 140.

15. We refer to the "Investment Securities" section of MD&A on
page
27 that states the Company sold available-for-sale securities in
2004
for $57 million and acquired mortgage backed securities and
collateralized mortgage obligations ("CMOs").   In this regard,
please tell us and revise to disclose:

* The nature, terms, risk characteristics and dollar amount of
collateralized mortgage obligations acquired.

* Discuss any material acquisitions of high risk tranches in CMOs
and
their expected effects on operations assuming changes in future
interest rates.

Note 13, Commitments, Concentration of Credit Risk and
Contingencies,
page 49

16. We refer to the interest rate swap agreements with notional
amounts totaling $110 million disclosed in Note 4, "Interest Rate
Risk" on page 44 of the financial statements of DutchFork as of
September 30, 2003 in the Form S-4 filed on July 7, 2004.
Considering the Company acquired DutchFork in October 2004 and
that
the interest rate swaps agreements expire on November 15, 2004 and
March 18, 2005, please tell us and revise to provide the following
disclosure:

* Provide the information required by paragraphs 44 to 47 of SFAS
133
for the interest rate swaps acquired by the Company as part of the
acquisition of DutchFork.

* State the terms and market values of the floors and caps
included
in the interest rate swap agreements.

* Describe the accounting for interest rate swaps that were
terminated prior to the expiration date, in accordance with
paragraphs 32 and 33 of SFAS 133.

* Tell us and revise the footnote or MD&A, as appropriate to
discuss
how the derivative instruments qualified for hedge accounting
under
SFAS 133 and how your accounting policies comply with that
standard,
including the following:

o The specific nature of the hedged assets and liabilities and if
the
hedge is a fair value or cash flow hedge.
o Describe your formal documentation of the hedging relationships.
o How you identify the hedge item or transaction and the hedge
instrument.
o Describe the quantitative measures of correlation you use to
assess
effectiveness of each hedge both at inception and on an ongoing
basis.
o Describe how you assess the ineffectiveness of the hedge.
o Disclose when you perform these assessments.
o Disclose where you present the gains and losses relating to
hedge
ineffectiveness in the statements of income and explain why that
presentation is appropriate.
o Describe the quantitative measures you use to assess
effectiveness
of each hedge both at inception and on an ongoing basis.
o Explain how often you assess and how often you back test and how
these determinations have resulted in no hedge ineffectiveness for
the periods presented.
o Describe and quantify the impact of your use of derivatives on
interest income and expense.

*	*	*

Closing Comments

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with any amendment that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing any amendment and responses to our comments.

        In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

* The company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* Staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and

* The company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

        In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

      You may contact Edwin Adames (Senior Staff Accountant) at
(202)
551-3447 or me at  (202) 551-3492 if your have any questions
regarding these comments.

						Sincerely,

						John P. Nolan
						Accounting Branch Chief

First Community Corporation
Joseph G. Sawyer
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December 2, 2005

Via Edgar

John P. Nolan
Accounting
Branch Chief
Securities and Exchange Commission
Division of Corporate
Finance, Office of Financial Services
450 Fifth Street, N.W.

Washington, D.C. 20549

        Re:
First Community Corporation
                    Amendment to Form 10-K filed
on March 23, 2005
                    File No. 0-28344

Dear Mr. Nolan:

        On
behalf of First Community Corporation (the “Company”), the undersigned is hereby
transmitting this letter in response to the Staff’s request for additional
information with respect to the comment letter dated September 9, 2005. The information
provided should be included as supplemental disclosure to the Staff’s numbered
comments in our previous response letter dated November 16, 2005.

Form 10-K for the Year
ended December 31, 2004

The following should be included as
supplemental response to comment 14:

In future filings, the Company
will provide additional detail as to the amounts included in equity and other securities.
This category will be segregated to reflect each major category of investment as outlined
in our previous response dated November 16, 2005.

The Company will also will provide
disclosure in future filings, including 10-Q filings, for each category of securities
relative to consideration as to impairment on an other-than-temporary basis. Sample
disclosure related to the preferred stock was provided in our response dated November 16,
2005. The disclosures will comply with the guidance provided in the recent FASB Staff
Position FAS 115-1 and FAS 124-1.

The following should be included as
supplemental response to comment 16:

The Company will include the
following disclosure in its 10-K filing for the year ended December 31, 2005 and future
filings as appropriate:

DutchFork had entered into several
interest rate cap agreements prior to the date of acquisition. These included two
agreements with notional amounts of $40.0 million and $20.0 million with one month LIBOR
cap rates of 3.5% and 3.0%, respectively. These agreements expired on November 15, 2004.
In addition, they had two agreements with notional amounts of $25.0 million each with a
one month LIBOR cap rate of 7.0%. These agreements expired on March 18, 2005. Due to the
cap rate and the short period to expiration, these interest rate caps had no market value
at the date of acquisition. The Company received no payments on these agreements and
recorded no change in value during any period as they never regained any value from the
date of acquisition until expiration.

        In
addition, on behalf of the Company, the undersigned hereby acknowledges that:

•

the Company is responsible for the accuracy of the disclosure in the filings;

•

staff comments or changes to disclosure in response to staff comments in the filings
reviewed by the staff do not foreclose the Commission from taking any action with respect
to the filing; and

•

the Company may not assert staff comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

First Community Corporation

By:   /s/  Joseph G. Sawyer

Joseph G. Sawyer

Chief Financial Officer

CORRESP
1
filename1.htm

First Community
Corporation
First Community Bank, N.A.
5455 Sunset Boulevard

Lexington, South Carolina 29072

November 16, 2005

Via EDGAR

John P. Nolan
Accounting
Branch Chief
Securities and Exchange Commission
Division of Corporate
Finance, Office of Financial Services
450 Fifth Street, N.W.
Washington, D.C. 20549

     Re:

     First Community Corporation

     Amendment to Form 10-K filed on March 23, 2005

     File No. 0-28344

Dear Mr. Nolan:

        On
behalf of First Community Corporation (the “Company”), the undersigned is hereby
transmitting this response to the Staff’s comment letter dated September 9, 2005. The
paragraphs below respond to the Staff’s numbered comments.

Form 10-K for the Year
ended December 31, 2004

Description of Business,
General, page 1

          1.

          Please tell us and revise to state if you continue to qualify as a Small
          Business filer under the requirements of Item 10(a) and (b) of Regulation S-B
          after the acquisition of DutchFork Bancshares (“DutchFork”) in October
          2004. In this regard we note you filed a 10-KSB for the year ended December 31,
          2004 but filed Form 10-Qs for the three and six month periods ended March 31,
          2005 and June 30, 2005, respectively.

As
of December 31, 2005, the Company no longer met the requirements to qualify as a small
business  issuer. The Company exceeded the public float limitation for each of the
fiscal years ended December  31, 2003 and 2004. As a result, we do not believe an
amendment to the 10-KSB is necessary.

Disclosure that the Company no longer qualifies as a Small Business filer will be made in future
filings  beginning with the September 30, 2005 10-Q.

Provision and Allowance
for Loan Losses, page 22

          2.

          We refer to the statement that as of December 31, 2003 management implemented a
          system for allocating the allowance for loan losses to specific
          components of the loan portfolio and that prior to that date the allowance
          was allocated on an overall portfolio basis. In this regard, provide us
          with the following information:

•

The authoritative accounting or regulatory basis you relied upon prior to December 31,
2003 to use the overall portfolio basis for allocating the loan loss allowance;

•

The factors that prompted the Company to change its methodology for allocating the loan
loss allowance in 2004.

•

The effects on the allowance for loan losses due to the changes in the allocation
methodology in 2004 as compared to prior periods.

The statement referred to in the comment above was not based on authoritative accounting or
regulatory  guidance. The statement was made to inform the reader as to the basis
for not including the table in  the format outlined in the Securities Act Industry
Guide for bank holding companies (Guide 3) prior to  December 31, 2003. Footnote 2
of the Guide 3 instructions to the table provide that “In lieu of the
breakdown of the allowance for loan losses by loan category called for, the registrant
may furnish a  narrative discussion of the risk elements in the loan portfolio and
the factors considered in  determining the amount of the allowance for loan
losses.”

In all filings prior to December 31, 2003, the Company disclosed that management evaluated
the allowance  on an overall portfolio basis and would implement and allocate the
allowance to various loan categories  at the time the size and mix of the portfolio
supported a meaningful allocation system. Because the  bank was formed in August
1995 and had limited historical loss experience during the initial years of
operation, past due statistics and historical migration analysis and other factors that
assist in  developing the allocation were not supportive of a meaningful allocation
system.

The change to allocating the allowance for loan losses to loan categories and presenting the
table as  per the instructions to Guide 3 had no financial statement effect on the
allowance for loan losses.  Management has consistently applied the methodology,
whether reviewing portfolio segments or the  portfolio as a whole, used to develop
the estimation of credit losses by evaluating all of the factors  available. The
process includes detailed and regular analyses of the loan portfolio including a review
 of large loans and groups of loans. Management estimates the credit losses by
evaluating all of the  factors and utilizing the common elements outlined in
paragraph 9.05 of the AICPA Audit and Accounting  Guide for
Depository and Lending Institutions.

A sample of the disclosure that will be included in future filings is shown in response to
question  number 3. The table outlined in Guide 3 has been included in the filings
since December 31, 2003 and  will be included in future filings.

          3.

          We refer to the following statements by the Company regarding how it determined
          its loan loss allowance:/FONT>

•

The provision of $245,000 in 2004 maintained the allowance for loan loss within
management’s desired  levels.

•

It was the objective of management to fund the allowance at approximately 1.1% to
1.5% of total loan until a tested historical experience has been established.

In this regard, please tell us the methodology that management uses, considering the
requirements of SFAS 5 and SFAS 114, to determine the adequacy of the loan loss allowance.
Refer in your response to how you considered paragraph 9.19 of the AICPA Audit and
Accounting Guide for Depository and Lending  Institutions which states the
allowance for loan losses should be established in conformity with generally accepted
accounting principles rather than in accordance with specified percentages.

To determine the adequacy of the allowance for loan losses, a formal analysis is completed
quarterly to  assess the risk within the loan portfolio. The portfolio is
segregated into similar risk components for  which historical loss ratios are
calculated and adjusted for identified changes in current portfolio
characteristics. Historical loss ratios are calculated by product type and by

 regulatory credit risk classification. The allowance for loan losses consists of an
allocated and unallocated allowance. The  allocated portion is determined by types
and ratings of loans within the portfolio. The unallocated  portion of the
allowance is established for losses that exist in the remainder of the portfolio. This
 also compensates for uncertainty in estimating the loan losses. Nonperforming
commercial loans (both  real estate and non real estate) are reviewed for
impairment. Impairment is measured in accordance with  SFAS 114, “Accounting
by Creditors for Impairment of a Loan” and loans are either assigned a specific
allocation or charged-off if deemed uncollectible. Substantially all loans historically
identified as  impaired have been collateral dependent and the fair value of the
underlying collateral has been used to  determine the amount of impairment.

The
statement that the provision of $245,000 maintained the allowance within management’s
desired levels  was made to reinforce that this was the estimated provision to
maintain the allowance at the appropriate  level based on management’s
analysis of estimated losses inherent in the portfolio.

In addition, the reference to the ratio of the allowance to loan loss relates to historical
percentages  rather than a specific target.

The Company has access to all of the GAAP and supervisory guidance referred to in paragraph
9.19 of  AICPA Audit and Accounting Guide for Depository and Lending
Institutions. Management has and will  continue to:

•

Maintain adequate controls to ensure ALLL is consistent in accordance with GAAP, stated
policies and  procedures, and relevant supervisory guidance.

•

Develop, maintain and document a comprehensive, and consistently applied process to
determine the  amounts of the ALLL and provision for loan losses.

•

Maintain the ALLL at a level that is appropriate to absorb estimated credit losses
inherent in the loan  portfolio, consistent with long-standing supervisory
guidance.

•

Utilize prudent, conservative, but not excessive, judgment to determine that the ALLL
represents  management’s best estimate from within an acceptable range of
estimated losses.

Provided below is a revised supplemental disclosure that describes the process management uses to
 determine its loan loss allowance. The required tables were included in the 10-KSB
and have not been  included. The process described has been included in the 10-Q
filed for September 30, 2005. Future  filings will clearly reflect the methodology
that management uses to determine the adequacy of the  allowance for loan losses,
considering the requirements of SFAS 5 and SFAS 114. The reference to “fund
the allowance at approximately 1.1% to 1.5% of total loans” has been deleted from
the discussion.

At December 31, 2004, the allowance for loan losses amounted to $2.8 million, or 1.48% of
total  loans, as compared to $1.7 million, or 1.41% of total loans, at December 31,
2003. Included in  the allowance for loan losses at December 31, 2004 is the amount
of $995,000 purchased in the  merger, with DutchFork. The company’s provision
for loan loss was $245,000 for the year ended  December 31, 2004 as compared to
$167,000 and $677,000 for the years ended December 31, 2003  and 2002. Due to
declining economic conditions and increased charge-offs the in 2001 and 2002  the
allowance was funded at higher amounts for these periods. During the first six months of
 2003, the company experienced a recovery on a loan charged off in a prior period
which resulted  in the allowance being funded at a lower amount during this period.

Management has established loan policies and review processes to ensure that its loan loss
allowance is adequate. The provision is made based on management’s assessment of
general loan  loss risk and asset quality. The allowance for loan losses represents
an amount which we  believe will be adequate to absorb probable losses on existing
loans that may become  uncollectible. Our judgment as to the adequacy of the
allowance for loan losses is based on a  number of assumptions about future events,
which we believe to be reasonable, but which may or  may not prove to be accurate.
Our determination of the allowance for loan losses is based on  evaluations of the
collectibility of loans, including consideration of factors such as the  balance of
impaired loans, the quality, mix, and size of our overall loan portfolio, economic
conditions that may affect the borrower’s ability to repay, the amount and quality
of  collateral securing the loans, our historical loan loss experience, and a
review of specific  problem loans. All loan relationships with aggregate credit of
$500,000 or more are reviewed  annually and loans regardless of amount criticized
or classified by management in accordance  with regulatory guidelines are reviewed
quarterly. We also consider subjective issues such as  changes in the lending
policies and procedures, changes in the local/national economy, changes  in volume
or type of credits, changes in volume/severity of problem loans, quality of loan
review, board of director oversight, and concentrations of credit. Periodically, we
adjust the  amount of the allowance based on changing circumstances. We charge
recognized losses to the  allowance and add subsequent recoveries back to the
allowance for loan losses.

Management performs an analysis quarterly to assess the risk within the loan portfolio. The
portfolio is segregated into similar risk components for which historical loss ratios
are  calculated and adjusted for identified changes in current portfolio
characteristics.  Historical loss ratios are calculated by product type and by
regulatory credit risk  classification. The allowance consists of an allocated and
unallocated allowance. The  allocated portion is determined by types and ratings of
loans within the portfolio. The  unallocated portion of the allowance is
established for losses that exist in the remainder of  the portfolio and
compensates for uncertainty in estimating the loan losses.

There
can be no assurance that charge-offs of loans in future periods will not exceed the
allowance for loan losses as estimated at any point in time or that provisions for loan
losses  will not be significant to a particular accounting period. The allowance is
also subject to  examination and testing for adequacy by regulatory agencies, which
may consider such factors as  the methodology used to determine adequacy and the
size of the allowance relative to that of  peer institutions. Such regulatory
agencies could require us to adjust our allowance based on  information available
to them at the time of their examination.

At December 31, 2004, 2003 and 2002 the company had $19,000 in loans delinquent more than 90
 days and still accruing interest. There were loans totaling $411,000, $96,000 and
$340,000 in  loans that were delinquent 30 days to 89 days at December 31, 2004,
2003 and 2002,  respectively. The company had no loans in a nonaccrual status at
December 31, 2004 and $80,000  and $144,000 at December 31, 2003 and 2002,
respectively. Loans are generally placed in a  non-accrual status when they become
90 day delinquent. The charge-offs experienced in 2004 and  2003 related to loans
that were identified and charged-off within those respective periods.  Management
continuously monitors non-performing, classified and past due loans to identify
deterioration regarding the condition of these loans. Management has not identified any
 classified loans that are not included in non-performing assets that could are
considered to be  potential problem loans as of December 31, 2004.

          4.

          We refer to the statement that the Company as of December 31, 2004 had no
          loans on a non-accrual  status. Please tell and revise to explain the basis
          for this statement considering the following factors:

•

The Company recorded write-offs of $294,000 in 2004 and $235,000 in 2003 that appear to
relate to non-performing loans that developed in 2004 considering you only had $80,000 on
non-performing loans in 2003.

•

The large loan recovery in 2003 was due to a loan charged off prior to 2003 that
was recovered during that year. Refer to the “Results of Operations” section of
MD&A on page 18.

•

The apparent acquisition of $550,000 of non-performing loans as part of the purchase of
DutchFork in 2004. Refer in your response to the status of the non-accrual loans described
in Note 4, “Loans Receivable” of the financial statements of DutchFork as of
September 30, 2003 in the Form S-4 filed on July 7, 2004.

The Company had no nonaccrual loans at December 31, 2004. As stated in the MD&A, a loan is
generally  placed in nonaccrual status when it becomes 90 days or more past due.

The $80,000 in non-accrual loans at December 31, 2003 relates to two credits that were
subsequently  collected in full during 2004. The $294,000 in write-offs in 2004
relate to loans that became a problem  in 2004 and were timely charged-off. The
Company has continually maintained a policy to recognize  charge-offs timely. If a
loan is recognized as uncollectible prior to becoming 90 days delinquent, it  is
charged-off prior to the 90 day period.

Similar to the circumstances in 2004, subsequent to December 31, 2004, the Company had total
charge-offs  of approximately $280,000 of which approximately $270,000 represented
two credits that were identified  as problems in the first quarter of 2005. The
circumstances underlying these credits are discussed in  response to your comment
number 6.

The recovery referred to in your comment above related to an insurance settlement on a loan
charged off  in 2001. The charge off in 2001 was made and it was not anticipated
that the Compan