United States securities and exchange commission logo February 7, 2024 Jay J. Jackson Chief Executive Officer Abacus Life, Inc. 2101 Park Center Drive, Suite 170 Orlando, FL 32835 Re: Abacus Life, Inc. Registration Statement on Form S-1 Filed January 31, 2024 File No. 333-276795 Dear Jay J. Jackson: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 John Stickel at 202-551-3324 with any questions. Sincerely, Division of Corporation Finance Office of Finance