United States securities and exchange commission logo March 24, 2022 Daniel M. Wallach Chief Executive Officer Shepherd's Finance, LLC 13241 Bartram Park Blvd., Suite 2401 Jacksonville, FL 32258 Re: Shepherd's Finance, LLC Registration Statement on Form S-1 Filed March 22, 2022 File No. 333-263759 Dear Mr. Wallach: 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 Sonia Bednarowski at 202-551-3666 with any questions. Sincerely, Division of Corporation Finance Office of Finance