December 13, 2019 George A. Mangiaracina Chief Executive Officer Impac Mortgage Holdings, Inc. 19500 Jamboree Road Irvine, California 92612 Re: Impac Mortgage Holdings, Inc. Registration Statement on Form S-3 Filed December 6, 2019 File No. 333-235405 Dear Mr. Mangiaracina: 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 Ronald (Ron) Alper at 202-551-3329 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Craig Miller