October 3, 2019 Neal J. Suit General Counsel and Secretary Legacy Housing Corp 1600 Airport Freeway, Suite 100 Bedford, Texas 76022 Re: Legacy Housing Corp Preliminary Proxy Statement on Schedule 14A Filed September 16, 2019 File No. 001-38761 Dear Mr. Suit: 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 Manufacturing cc: Spencer G. Feldman