126 East King Street Lancaster, PA 17602 Tel (717) 299-5201 Fax (717) 291-4660 www.barley.com			Kimberly J. Decker, Esquire Direct Dial Number: 717-399-1506 E-mail: kdecker@barley.com

May 31, 2018

Via EDGAR

Jennifer Gowetski

Senior Counsel of Real Estate and Commodities

United States Securities and Exchange Commission

Division of Corporation Finance

450^th Street, N.W.

Washington, D.C. 20549-1004

Dear Ms. Gowetski:

We hereby submit for filing Amendment No. 2 to the Noble Advisors, LLC Form 1-A offering statement originally filed with the Securities and Exchange Commission on December 1, 2017 (the “Offering Statement”). The enclosed amended Offering Statement relates to the proposed offering by Noble of up to $20.0 million of subordinated, unsecured, interest only promissory notes in an offering intended to qualify for exemption from registration as a Tier 1 offering pursuant to Regulation A. The changes made to this version of the Offering Statement reflect responses made by the issuer to comments from state securities commission reviews, and comments received from the Commission in a letter dated April 2, 2018. All changes made since Amendment No. 1 was filed have been marked. The offering has been qualified in both Delaware and Pennsylvania. We hereby request you to qualify this offering, effective as of May 28, 2018.

Barley Snyder

Lancaster  ●  York  ●  Reading  ●  Hanover  ●   Malvern  ●  Hunt Valley  ●  Harrisburg

If you have any questions, please feel free to contact the undersigned.

Respectfully,

/S/ KIMBERLY J. DECKER

Kimberly J. Decker

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