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                               November 1, 2021

       Anthony Leo
       Chief Executive Officer
       BayFirst Financial Corp.
       700 Central Avenue
       St. Petersburg, FL 33701

                                                        Re: BayFirst Financial
Corp.
                                                            Amendment No. 2 to
Registration Statement on Form S-1
                                                            Filed October 1,
2021
                                                            File No. 333-256009

       Dear Mr. Leo:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 28, 2021 letter.

       Amendment No. 2 to Registration Statement on Form S-1

       General

   1.                                                   We note that you are
registering, among others, the resale of fractional shares of your
                                                        common stock by the
Registered Stockholders, as referenced in the fee table, the
                                                        prospectus cover page
and the "Principal and Registered Stockholders" section. Please
                                                        disclose the material
impacts of owning fractional shares of your common stock,
                                                        including, without
limitation:
                                                            whether fractional
share investors will receive dividend, voting, and other rights
                                                             associated with
whole-share ownership and, if so, explain how fractional share
                                                             investors are
entitled to these rights, whether by contract, applicable law (including
                                                             Article 8 of the
UCC), or both;
 Anthony Leo
BayFirst Financial Corp.
November 1, 2021
Page 2
             whether fractional share investors have the right to receive
confirmations, proxy
           statements and other documents required by law to be provided to
security holders;
             the treatment of fractional shares by your transfer agent and
brokers; and
             the extent to which fractional shares purchased by investors in
this offering may be
           subsequently traded on the OTCQX, Nasdaq or other public exchanges
or alternative
           trading venues.
Risk Factors
Risks Related to Our Securities, page 18

2.    Please expand your risk factor disclosure to address any material risks
of owning
      fractional shares of your common stock (e.g., any liquidity risks
associated with owning
      fractional shares of a potentially thinly-traded company). In this
regard, we note your
      disclosure on page 25 that your common stock is currently quoted and
traded on the
      OTCQX, which has resulted in a minimal level of trading.
Principal and Registered Stockholders, page 71

3.    We note your revised disclosure in response to comment 4 that to the best
of your
      knowledge, no affiliate of any broker-dealer owns shares of your common
stock or
      warrants. Please revise to explain the basis for your knowledge (e.g.,
whether you
      received representations regarding broker-dealer affiliations from each
of the Registered
      Stockholders and warrant holders referenced in the "Principal and
Registered
      Stockholders" section).
       You may contact William Schroeder at (202) 551-3294 or Benjamin Phippen
at (202)
551-3697 if you have questions regarding comments on the financial statements
and related
matters. Please contact Jessica Livingston at (202) 551-3448 or David Lin at
(202) 551-3552
with any other questions.



                                                           Sincerely,
FirstName LastNameAnthony Leo
                                                           Division of
Corporation Finance
Comapany NameBayFirst Financial Corp.
                                                           Office of Finance
November 1, 2021 Page 2
cc:       Richard Pearlman, Esq.
FirstName LastName