July 6, 2017

Sent by Email Only

Thomas Kluck, Legal Branch Chief

Office of Real Estate and Commodities

Securities and Exchange Commission

Washington, D.C. 20549

Email:  KluckT@sec.gov

Re:	Impact Housing REIT, LLC (the “Fund”)

Offering Statement on Form 1-A

Submitted December 1, 2016

File No. 024-10649

Dear Mr. Kluck:

This is in response to your letter of April 28, 2017. We have copied below the questions from your April 28th letter, and provided the Fund’s responses below each question. Also enclosed are blacklined versions of the Offering Circular reflecting the changes we have made in response to your letter, each of which is described below.

 

The revised Offering Circular (but not the blacklined version) has also been filed through EDGAR.

 

Your Question #1

 

We note your response to comment 1 of our letter dated March 10, 2017 and comments 2 and 8 of our letter dated December 29, 2016. We will continue to monitor for your response to our comments.

Thomas Kluck, Legal Branch Chief

Securities and Exchange Commission

June 21, 2017

Page 2

 

Your Question #2

 

Please update your financial statements to include audited financial statements as of December 31, 2016.

Your Question #3

 

Please update your prior performance tables, such as Table III, to include information as of December 31, 2016.

*      *      *

 

Thank you for your continued attention to this matter. Please let me know if you have further questions or need additional information.