United States securities and exchange commission logo

                               December 3, 2020

       William A. Newman
       Chief Executive Officer
       Home Point Capital Inc.
       2211 Old Earhart Road, Suite 250
       Ann Arbor, MI 48105

                                                        Re: Home Point Capital
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted November
6, 2020
                                                            CIK No. 0001830197

       Dear Mr. Newman :

              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 Submitted November 6, 2020

       Industry and Market Data, page iii

   1.                                                   We note references to
third-party information and industry research throughout the
                                                        prospectus, beginning
with your reference to Inside Mortgage Finance on page iii. Please
                                                        advise us as to whether
any of these reports were commissioned or prepared for this
                                                        filing. If any of these
reports were prepared for use in connection with this registration
                                                        statement, please file
a consent acknowledging the use of the information in the
       Company Overview, page 1

   2.                                                   Please briefly explain
the term Wholesale lender the first time you use it, in order to
 William A. Newman
Home PointLastNameWilliam     A. Newman
            Capital Inc.
December  NameHome
             2020       Point Capital Inc.
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         distinguish that business from other forms of mortgage origination.
Clarify your
         disclosure that you are "the third largest wholesale lender by
origination volume in 2020
         through June 30" by explaining the relationship between the wholesale
channel and other
         forms of residential loan origination. Also, please clarify the
distinction between your
         wholesale channel and the overall wholesale channel.
3.       Please substantiate that you are currently the third largest and
fastest growing wholesale
         lender as of June 30, 2020.
4.       We note statements throughout the summary regarding your plans and
expectations for
         continued growth. Please discuss in greater detail any additional
funding needs you will
         have to drive this growth, where you expect to source the funding, and
the time frame and
         any material milestones.
5.       Please provide support for the statement on page 16 that the wholesale
channel is
         fragmented below the top three participants. Explain why you believe
that this creates
         substantial opportunity to gain market share.
6.       Please provide more detail regarding the reasons that you believe that
growth in the
         company's platforms implies that they are scalable. Balance disclosure
         scalability by referencing factors that would inhibit scalability,
such as the considerations
         that appear in the risk factor on page 31.
Risk Factors, page 27

7.       In the risk factor that discusses financing arrangements, please
disclose the number of
         warehouse lenders on which your business relies, as well as the number
of funding
         facilities that expire in 2021 and the terms of the uncommitted
facilities. Explain your
         plans, if any, to replace the expiring facilities.
8.       Please expand the risk factor on page 52 to state explicitly the risks
associated with a
         falling interest rate environment. We note in this regard the
disclosure on page 75 of the
         impact of changes in interest rates on your business.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page

9.       Please expand your discussion of the proprietary Home Ownership
Platform to explain
         how the platform differs from those of your competitors and what
aspects of the platform
         cause increased customer retention. Quantify the impact of the
platform on customer
         retention and disclose the time period over which such retention has
10.      Please disclose here the number of loans enrolled in forbearance plans
and the percentage
         of loans in your total serving portfolio this represents. Please
continue to update this and
         your related liquidity disclosure as of the most recent practicable
 William A. Newman
Home Point Capital Inc.
December 3, 2020
Page 3
Business, page 91

11.   Please discuss how your highly componentized, flexible technology
infrastructure allows
      you to "leverage nimble internal development teams and market leading
      systems to provide a best-in-class experience for our partners and
customers." To the
      extent that you believe that this infrastructure distinguishes you from
your competitors,
      explain why.
12.   Please expand your discussion of your broker partners on page 95 to
explain the
      relationship between those partners and the company, particularly whether
the company
      retains any liability for the actions of the brokers.
Description of Capital Stock, page 130

13.   Please clarify, here or in a risk factor, that the distribution of any of
the convertible
      preferred stock the board will be authorized to issue could be dilutive
to stockholders.
Exclusive Forum, page 135

14.   You state that the exclusive forum provision will not apply to claims
under the federal
      securities law. Please confirm that this will be explicitly stated in
your certificate of
      incorporation or, alternatively, tell us how you plan in future filings
to make investors
      aware that the provision is not applicable to these claims.

15.   Please provide us with copies of all written communications, as defined
in Rule 405 under
      the Securities Act, that you, or anyone authorized to do so on your
behalf, have presented
      or expect to present to potential investors in reliance on Section 5(d)
of the Securities Act,
      whether or not you retained, or intend to retain, copies of those
communications. Please
      contact Julia Griffith at 202-551-3267 to discuss how to submit the
materials, if any, to us
      for our review.
       You may contact William Schroeder at 202-551-3294 or Amit Pande at
202-551-3423 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Julia Griffith at 202-551-3267 or J. Nolan McWilliams at 202-551-3217
with any other

FirstName LastNameWilliam A. Newman
                                                             Division of
Corporation Finance
Comapany NameHome Point Capital Inc.
                                                             Office of Finance
December 3, 2020 Page 3
cc:       Joe Kauffman
FirstName LastName