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                             June 8, 2022

       Jon Gloeckner
       Senior Vice President, Treasurer & Financial Reporting
       Impac Mortgage Holdings, Inc.
       19500 Jamboree Road
       Irving, California 92612

                                                        Re: Impac Mortgage
Holdings, Inc.
                                                            Form 10-K for the
fiscal year ended December 31, 2021
                                                            Filed March 11,
2022
                                                            File No. 001-14100

       Dear Mr. Gloeckner:

               We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment. In our comment, we may ask
you to provide us
       with information so we may better understand your disclosure.

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

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

       Form 10-K filed March 11, 2022

       Item 7. Management discussion and analysis of financial condition and
results of operations
       Non-GAAP financial measures, page 29

   1.                                                   We note your disclosure
of core (loss) earnings before tax. This non-GAAP measure
                                                        includes adjustments
for various changes in fair value of financial assets and liabilities
                                                        such as mortgage
servicing rights, long-term debt, and net trust assets. As a residential
                                                        mortgage lender which
originates, sells and services residential mortgage loans, it appears
                                                        such fair value
adjustments are central to the nature of your business operations. Please
                                                        tell us how you
determined it was appropriate to label such a measure as "core" earnings.
                                                         In addition, please
tell us and expand upon your existing disclosures to further describe
                                                        the usefulness of and
how management utilizes this measure to assess performance.

              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
 Jon Gloeckner
Impac Mortgage Holdings, Inc.
June 8, 2022
Page 2

absence of action by the staff.

       You may contact Peter McPhun at 202-551-3581 or Wilson Lee at
202-551-3468 with
any questions.



FirstName LastNameJon Gloeckner                        Sincerely,
Comapany NameImpac Mortgage Holdings, Inc.
                                                       Division of Corporation
Finance
June 8, 2022 Page 2                                    Office of Real Estate &
Construction
FirstName LastName