July 3, 2024

Richard Bunch
Chief Executive Officer
TWFG, Inc.
1201 Lake Woodlands Drive, Suite 4020
The Woodlands, Texas 77380

       Re: TWFG, Inc.
           Registration Statement on Form S-1
           Filed June 24, 2024
           File No. 333-280439
Dear Richard Bunch:

       We have reviewed your registration statement and have the following
comments.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies to your facts
and circumstances
or do not believe an amendment is appropriate, please tell us why in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1 filed June 24, 2024
Management's Discussion and Analysis, page 101

1.     We note your response to prior comment 3. With a view towards
disclosure, please advise
       us of the approximate margins of Agency-in-a-Box compared to Corporate
Branches. To
       the extent that relative profitability is a significant factor in making
acquisitions or
       an underlying driver of any known trends or uncertainties, please revise
to provide
       explanatory disclosure. See Item 303(b)(2)(ii) of Regulation S-K.
2.     We note your response to prior comment 2. Where you identify multiple
factors partially
       offsetting the increase in your TWFG MGA offering on page 111, please
quantify the
       change attributed to each factor. Please refer to Item 303 of Regulation
S-K.
        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.
 July 3, 2024
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact John Spitz at 202-551-3484 or Marc Thomas at 202-551-3452
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Madeleine Joy Mateo at 202-551-3465 or James Lopez at 202-551-3536 with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Finance
cc:   Rob Shearer, Esq.