January 13, 2025 Terry L. Schmidt Chief Executive Officer Guild Holdings Company 5887 Copley Drive San Diego, CA 92111 Re: Guild Holdings Company Registration Statement on Form S-3 Filed January 7, 2025 File No. 333-284165 Dear Terry L. Schmidt: 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 Robert Arzonetti at 202-551-8819 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: April Hamlin