December 18, 2024

Sean Sievers
Chief Financial Officer
Merchants Bancorp
410 Monon Blvd.
Carmel, IN 46032

        Re: Merchants Bancorp
            Form 10-K for the Fiscal Year Ended December 31, 2023
            Form 10-Q for the Quarterly Period Ended September 30, 2024
            File No. 001-38258
Dear Sean Sievers:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Loans Receivable, Net, page 52

1.     Please revise your disclosures, in future filings, to present loan
maturity information
       as of the end of the latest reported period for each loan category
(e.g., Residential real
       estate, Multi-family financing, Healthcare financing, etc.) for which
disclosure is
       required in the financial statements. Please also disclose, in further
filings, the
       amounts due after one year for each loan category that have
pre-determined interest
       rates and adjustable interest rates, respectively. We note Item 1404 of
Regulation S-K.
2.     We note your disclosure that Multi-family financing loans and Healthcare
financing
       loans comprised approximately 40% and 23%, respectively, of your total
loans held
       for investment as of December 31, 2023. Given the significance of these
loans in your
       total loan portfolio, including the national scope of this lending,
please revise future
       filings to further disaggregate the composition of these loans to
address geographic
 December 18, 2024
Page 2

       and any industry concentrations to the extent material to an investor
s understanding
       of these portfolio types. We note Item 303 of Regulation S-K.
Note 14-Credit Linked Notes, page 110

3.     We note your disclosure of the credit linked notes issued in 2023.
Please tell us how
       you considered the disclosures required under ASC 815-10-50-4K regarding
any
       credit derivatives or embedded credit derivatives, such as the maximum
potential
       amount of future payments (undiscounted) that you could be required to
make under
       the credit derivative and the fair value of the credit derivative as of
the balance sheet
       date. Please also revise future filings, if necessary.
Form 10-Q for the Quarterly Period Ended September 30, 2024
Condensed Consolidated Statements of Income, page 4

4.     We note you disclosed $16.1 million in losses on derivative put options
in Note 8 for
       the quarter ended September 30, 2024. In future filings, please
separately disclose this
       loss on the face of the consolidated statements of income in the other
income
       section. We note Item 14 of Rule 9-04 of Regulation S-X.
Noninterest Income, page 60

5.     Please more fully disclose and discuss in future filings, the existence
of and reasons
       for the quarterly loss on derivative put options ($16.1 million) and
interest rate floors
       ($7.7 million), which comprise the majority of the $27 million quarterly
loss on
       derivatives as noted in Note 8 on page 31. We note Item 303(b) of
Regulation S-K.
        In closing, 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.

       Please contact Mengyao Lu at 202-551-3471 or John Nolan at 202-551-3492
with any
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Finance