United States securities and exchange commission logo

                             November 9, 2020

       Patrick O. Zalupski
       President, Chief Executive Officer and Chairman
       Dream Finders Homes, Inc.
       14701 Philips Highway, Suite 300
       Jacksonville, FL 32256

                                                        Re: Dream Finders
Homes, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted October
13, 2020
                                                            CIK No. 0001825088

       Dear Mr. Zalupski:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement on Form S-1 filed October 13, 2020

       Non-GAAP Financial Measures, page 69

   1.                                                   We note your non-GAAP
measure of "adjusted gross margin." In this measure, we note
                                                        the adjustment for
commission expense. Please further clarify why you believe isolating
                                                        the impact of
commission expense and adjusting for it in arriving at adjusted gross margin
                                                        is meaningful to an
investor. Please revise to update your disclosure, as applicable.
                                                        Reference is made to
Item 10(e)(1)(i)(C) of Regulation S-K.
 Patrick O. Zalupski
FirstName  LastNamePatrick
Dream Finders   Homes, Inc. O. Zalupski
Comapany 9,
November   NameDream
              2020      Finders Homes, Inc.
Page  2    9, 2020 Page 2
FirstName LastName
Management's Discussion and Analysis
Off Balance Sheet Arrangements, page 95

2.       We note your disclosure stating there were $31.1 million in deposits
paid for your finished
         lot and land bank option contracts as of June 30, 2020. Please
reconcile this amount to
         your balance sheet of the same date, which reports lot deposits of
$24.6 million. Please
         revise your disclosure to provide further clarity, as needed.
Customer Relations, Quality Control and Warranty Program, page 144

3.       Please expand the disclosure related to your monitoring program for
         including whether you have a formal monitoring program and how you
ensure that your
         standards are met.
4.       You state that you    are constantly striving to earn a 100%
willingness to refer rate    in
         each of your markets. Please disclose your actual willingness to refer
rate for the periods
         in which it was measured.
Executive Compensation
Special Bonus, page 159

5.       We note your disclosure that your Board of Directors is expected to
approve a special
         bonus for Mr. Zalupski that will be payable upon the completion of
this offering. Given
         the potential conflict of interest that this represents, please add a
risk factor.
1. Nature of Business and Significant Accounting Policies
Inventories, page F-12

6.       We note your disclosure stating you periodically review the
performance and outlook of
         your inventory for indicators of potential impairment and you have no
         reported during the periods presented. Please tell us and expand your
         impairment disclosures to discuss more detailed aspects about your
impairment analysis.
         Such expanded discussion should include aspects such as frequency
(i.e., quarterly) and
         level (i.e., community) in which you perform impairment analysis, the
         impairment indicators you look for, and the key assumptions utilized
in your impairment
         analysis to determine whether impairment exists.
13. Segment Reporting, page F-31

7.       We note your disclosure stating that the revenues of each remaining
         segment were not material and are classified in the "Other" category.
Please tell us how
         you have addressed all quantitative thresholds in accordance with ASC
 Patrick O. Zalupski
FirstName  LastNamePatrick
Dream Finders   Homes, Inc. O. Zalupski
Comapany 9,
November   NameDream
              2020      Finders Homes, Inc.
Page  3    9, 2020 Page 3
FirstName LastName
       You may contact Babette Cooper at 202-551-3396 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ronald (Ron) Alper at 202-551-3329 or Maryse Mills-Apenteng at
202-551-3457 with
any other questions.


                                                        Division of Corporation
                                                        Office of Real Estate &
cc:      Tim Taylor