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                             July 14, 2020

       Jarett S. Levan
       Chief Executive Officer and President
       BBX Capital Florida LLC
       401 East Las Olas Boulevard, Suite 800
       Fort Lauderdale, Florida 33301

                                                        Re: BBX Capital Florida
LLC
                                                            Registration
Statement on Form 10-12G
                                                            Filed June 17, 2020
                                                            File No. 000-56177

       Dear Mr. Levan:

              We have reviewed your filing 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response and any amendment you may file in
response to these
       comments, we may have additional comments.

       Registration Statement on Form 10 filed June 17, 2020

       Risk Factors
       Other Risk Factors
       New BBX Capital or its subsidiaries may incur additional indebtedness,
page 32

   1.                                                   We note your disclosure
that in connection with the spin-off, Parent will enter into a $75
                                                        million promissory note
in favor of New BBX Capital. Please disclose here, as you do on
                                                        page 55, that payments
of interest for the promissory note may be deferred at the option of
                                                        the Parent.
 Jarett S. Levan
FirstName   LastNameJarett
BBX Capital   Florida LLC S. Levan
Comapany
July        NameBBX Capital Florida LLC
     14, 2020
July 14,
Page  2 2020 Page 2
FirstName LastName
The Spin-Off
Separation and Distribution Agreement, page 51

2.       We note your disclosure that    New BBX Capital will retain or assume
the liabilities
         identified in the Separation and Distribution Agreement relating to
the businesses and
         subsidiaries of New BBX Capital, including the approximately $41.9
million of
         indebtedness of or related to the subsidiaries transferred to it in
connection with the spin-
         off    and that Parent will contribute to New BBX Capital all of
Parent   s cash and cash
         equivalents other than the cash and cash equivalents of Bluegreen
Vacations to New BBX
         Capital. Please quantify such cash and cash equivalents, as you do
your indebtedness.
Unaudited Pro Forma Financial Information
Unaudited Pro Forma Statement of Financial Position as of March 31, 2020, page
71

3.       Referencing the adjustment (A) to cash and cash equivalents for the
contribution of
         $112.8 million to New BBX Capital, it appears New BBX Capital's
historical cash and
         cash equivalents balance of $17.6 million at March 31, 2020 is
included in BBX Capital
         Corporation's cash and cash equivalents balance at that date and
should not be included in
         the $112.8 million pro forma adjustment. Please revise or advise us.
Audited Combined Carve-Out Financial Statements for the Years Ended December
31, 2019,
2018 and 2017
Combined Carve-Out Statements of Operations and Comprehensive Income (Loss),
page F-3

4.       Please tell us your consideration of providing separate financial
statements for significant
         equity method investees pursuant to Rule 3-09 of Regulation S-X for
any of the fiscal
         years in the three-year period ended December 31, 2019. Refer to Rule
1-02(w) of
         Regulation S-X for significance tests required under Rule 3-09 of
Regulation S-X.
Notes to the Combined Carve-Out Financial Statements
Note 1. Organization
Investments, Renin, page F-7

5.       You disclose that Renin had revenues of $36 million from two major
customers for the
         year ended December 31, 2019, but not if both customers exceeded 10%
of your
         combined revenues and/or receivables for each reporting period. If
revenues from
         transactions with a single external customer amount to ten percent or
more of revenues,
         disclose that fact, the total amount of revenues from each such
customer, and the identity
         of the segment or segments reporting the revenues. Refer to ASC
280-10-50-42.
 Jarett S. Levan
FirstName   LastNameJarett
BBX Capital   Florida LLC S. Levan
Comapany
July        NameBBX Capital Florida LLC
     14, 2020
July 14,
Page  3 2020 Page 3
FirstName LastName
Note 7. Investments in Unconsolidated Real Estate Joint Ventures, page F-22

6.       Please explain your methodology for determining which unconsolidated
real estate joint
         ventures accounted for on the equity method are material in relation
to the financial
         position or results of operations of the company for disclosure of
summarized financial
         information as to assets, liabilities, and results of operations of
the investees to be
         disclosed. For those investments in joint ventures which you determine
are material in
         relation to your financial position or results of operations, please
provide the disclosures
         pursuant to ASC 323-10-50-3c. Refer to Rule 1-02(w) and Rule 4-08(g)
of Regulation S-
         X, and ASC 323-10-50.
Note 12. Debt
Notes Payable Lines of Credit
Bank of America Revolving Line of Credit, page F-34

7.       You disclose in April 2020 a wholly-owned subsidiary of BBX Capital
Real Estate
         (BBXRE) purchased the Bank of America revolving line of credit and the
Banc of
         America equipment note from the respective lenders for the outstanding
principal balance
         of the loans, which were $4.0 million and $0.3 million, respectively,
at the time of the
         purchase, plus accrued interest. Please tell us how you intend to
account for the purchase
         of the Bank of America credit facilities in the second quarter of
2020.
Unaudited Combined Carve-Out Financial Statements for the Quarters Ended March
31, 2020
and 2019
Notes to Combined Carve-Out Financial Statements - Unaudited
Note 1. Organization
Impact of the COVID-19 Pandemic
BBX Sweet Holdings, page F-58

8.       BBX Sweet Holdings' IT'SUGAR and Hoffman's Chocolate reporting units
are
         negotiating rent abatements or deferrals with the landlords for their
retail locations which
         have been closed since March and started a phase reopening of certain
locations. You
         disclose "IT   SUGAR does not believe that it will have sufficient
liquidity to continue its
         full operations if it is unable to obtain significant rent abatements
and deferrals from its
         landlords and amended payments terms from vendors........pursue a
formal or informal
         restructuring." With the significant uncertainties related to the
impact of the COVID-19
         pandemic on the operations of IT'SUGAR and Hoffman's Chocolates,
please assess and
         evaluate the impact of COVID-19 in your disclosures for the following:

                how you expect COVID-19 to affect assets on your balance sheet
and your ability to
              timely account for these assets. For example, will there be
significant changes in
              judgments in determining the fair value of these assets,
including long-lived assets,
              right-of-use lease assets, and goodwill, in accordance with U.S.
GAAP.
                if you anticipate any material impairments (e.g. with respect
to goodwill, intangible
 Jarett S. Levan
BBX Capital Florida LLC
July 14, 2020
Page 4
              assets, long-lived assets, right-of-use assets), restructuring
charges, other expenses, or
              changes in accounting judgments that have had or are reasonably
likely to have a
              material impact on your financial statements.
                if you expect COVID-19 to materially affect the demand for your
products or
              services based on your business model.
                how you expect COVID-19 to affect your current manufacturing
and distribution
              processes for your chocolates and confectionary products,
including those produced
              and distributed by Las Olas Confections and Snacks.

         Refer to the Staff's Corporation Finance Disclosure Guidance: Topic 9
and Topic 9A.
BBX Capital Real Estate, page F-59

9.       Based on the impact of the COVID-19 pandemic, please explain your
consideration of
         whether there have been significant changes in the judgments to
determine the fair value
         of your real estate assets, including real-estate-held for sale and
real estate inventory,
         which would indicate a significant decline in their fair value which
should be reflected
         through an impairment charge in accordance with ASC 360. In your
response, please tell
         us your consideration of changes in economic factors, the housing
market, and real estate
         trends in the principal markets where you operate due the pandemic.
Refer to ASC 360-
         10-35 and the Staff's Corporation Finance Disclosure Guidance: Topic
9.
Future Adoption of Recently Issued Accounting Pronouncements
FASB Staff Q&A Accounting for Lease Concessions Related to the Effects of the
COVID-19
Pandemic (Topic 842), page F-61

10.    Please tell us and disclose your consideration of the impact of the FASB
Staff guidance on
       lease concessions related to the effects of COVID-19 for your existing
portfolio of
       operating leases for the BBX Sweet Holdings entities IT'SUGAR and
Hoffman's
       Chocolates for rent concessions negotiated with landlords. In your
response and
       disclosure, please explain if you have entered into lease concessions
for the above
FirstName LastNameJarett S. Levan
       businesses either at March 31, 2020 or subsequently, and the impact on
your accounting
Comapany    NameBBX
       and reporting  forCapital FloridaRefer
                          these leases. LLC to Question 4 of the FASB Staff Q&A
for Lease
July 14,Concessions
         2020 Page 4Related to the Effects of the COVID-19 Pandemic: ASC 842.
FirstName LastName
 Jarett S. Levan
FirstName   LastNameJarett
BBX Capital   Florida LLC S. Levan
Comapany
July        NameBBX Capital Florida LLC
     14, 2020
July 14,
Page  5 2020 Page 5
FirstName LastName
        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.

        You may contact Robert Shapiro, Staff Accountant at 202-551-3273 or Lyn
Shenk,
Accounting Branch Chief at 202-551-3380 if you have questions regarding
comments on the
financial statements and related matters. Please contact Scott Anderegg, Staff
Attorney at 202-
551-3342 or Jennifer L  pez, Staff Attorney at 202-551-3792 with any other
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services
