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                       May 4, 2021

       Anastasia Shishova
       Chief Executive Officer
       Graystone Company, Inc.
       401 E. Las Olas Blvd #130-321
       Fort Lauderdale, FL 33301

                                                        Re: Graystone Company,
Inc.
                                                            Post Qualification
Amendment No. 1 to Offering Statement on Form 1-A
                                                            Filed April 21,
2021
                                                            File No. 024-11421

       Dear Ms. Shishova:

                                                        We have reviewed your
amendment and do not have any comments.

               We will consider qualifying your offering statement at your
request. If a participant in
       your offering is required to clear its compensation arrangements with
FINRA, please have
       FINRA advise us that it has no objections to the compensation
arrangements prior to
       qualification.

               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 Taylor Beech at 202-551-4515 or Erin Jaskot at
202-551-3442 with any
       questions.




                       Sincerely,


                       Division of Corporation Finance

                       Office of Trade & Services