United States securities and exchange commission logo




                                                                                
                     June 20, 2024

       Joe Ragan
       Chief Executive Officer
       ExcelFin Acquisition Corp.
       100 Kingsley Park Dr.
       Fort Mill, SC 29715

                                                        Re: ExcelFin 
Acquisition Corp.
                                                            Preliminary Proxy 
Statement on Schedule 14A
                                                            Filed June 12, 2024
                                                            File No. 001-40933

       Dear Joe Ragan:

              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 Real Estate & Construction
       cc:                                              Bill Nelson, Esq.