United States securities and exchange commission logo





                              March 2, 2022

       Abbott Cooper
       Managing Member
       Driver Management Company LLC
       250 Park Avenue
       7th Floor
       New York, NY 10177

                                                        Re: REPUBLIC FIRST
BANCORP INC
                                                            PRRN14A filed
February 23, 2022
                                                            Filed by Driver
Management Company LLC, et al.
                                                            SEC File No.
0-17007

       Dear Mr. Cooper:

              We have reviewed your revised 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 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 to these comments, we may have additional comments.

       Revised preliminary proxy statement filed February 23, 2022

       General

   1.                                                   We refer to comment 1
in our prior comment letter dated February 7, 2022 and your
                                                        response. We continue
to believe that each participant's plans for Republic First is
                                                        material information.
To the extent that participants do not have specific plans, please
                                                        disclose this fact in
the revised proxy statement. Please revise to describe, as previously
                                                        requested.
   2.                                                   Refer to comment 2 in
our prior comment letter dated February 7, 2022. We continue to
                                                        believe that a
participant's recent statements advocating for a sale of Republic First are
                                                        material and should be
included in the proxy statement. Your revised disclosure can
                                                        explain the
circumstances under which those statements were made, and may limit their
                                                        scope with additional
explanation. Your statements (and explanation) may be particularly
 Abbott Cooper
Driver Management Company LLC
March 2, 2022
Page 2
         helpful to shareholders, since after they were made, the Braca Group
filed beneficial
         ownership reports indicating that it has engaged a financial advisor
to make contact with
         Republic First's financial advisor. Please revise your proxy
statement, as previously
         requested.
        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

         Please direct any questions to Christina Chalk at (202) 551-3263.



FirstName LastNameAbbott Cooper                               Sincerely,
Comapany NameDriver Management Company LLC
                                                              Division of
Corporation Finance
March 2, 2022 Page 2                                          Office of Mergers
& Acquisitions
FirstName LastName