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                            December 21, 2020

       Luis Solorzano
       Chief Executive Officer
       Acamar Partners Acquisition Corp.
       1450 Brickell Avenue, Suite 2130
       Miami, Florida 33131

                                                        Re: Acamar Partners
Acquisition Corp.
                                                            Amendment No. 1 to
Registration Statement on Form S-4
                                                            Filed December 16,
2020
                                                            File No. 333-249723

       Dear Mr. Solorzano:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
November 25, 2020 letter.

       Amendment No. 1 to Registration Statement on Form S-4

       The Subscription Agreements include a jury trial waiver..., page 61

   1.                                                   We note your response
to comment 27 and the updated disclosure on pages 61-62 and
                                                        126. In particular, we
note the sentence, "No condition, stipulation or provision of the
                                                        Subscription Agreements
serves as a waiver by any Subscriber or by Acamar Partners of
                                                        compliance with the
federal securities laws." Please further revise this disclosure to
                                                        explicitly state
whether the provision serves as a waiver by any Subscriber or by Acamar
                                                        Partners of a jury
trial in any claims brought pursuant to the federal securities laws.
       Unaudited Pro Froma Combined Balance Sheet
       Pro Forma Adjustments to the Unaudited Combined Balance Sheet, page 71
 Luis Solorzano
FirstName  LastNameLuis  Solorzano
Acamar Partners Acquisition Corp.
Comapany21,
December   NameAcamar
              2020      Partners Acquisition Corp.
December
Page 2    21, 2020 Page 2
FirstName LastName
2.       Refer to footnote (6) - Based on your revised disclosures in footnote
(6), it is not clear
         how the pro forma adjustment to additional paid-in capital, common
stock, in the amount
         of $(39,984) was determined. Please revise footnote (6) to include a
tabular schedule
         showing the various components that were combined to arrive at the
amount of this pro
         forma adjustment.
Unaudited Pro Forma Statements of Operations
Pro Forma Adjustments to the Unaudited Combined Statements of Operations, page
75

3.       Refer to footnote (5) - Please revise to disclose the significant
terms of the stock-based
         compensation grants issued to certain members of management and
non-employee
         directors in connection with the merger. Also, please disclose the
significant assumptions
         that were used to determine the fair value of these stock-based
compensation grants and
         indicate the aggregate amount of compensation expense that you expect
to recognize in
         connection with these stock-based compensation grants.
Detailed chronology of events, page 88

4.       We note your response to comment 15 and reissue our comment. We note
your disclosure
         that the Boards of Directors of both Acamar Partners and CarLotz did
not obtain fairness
         opinions in connection with the business combination. Please expand
your disclosure,
         where applicable, to include the processes employed by the Boards of
Directors of both
         Acamar Partners and CarLotz to assess the value of the potential
transactions outlined in
         this section, including how each Board determined that the final
valuation, and
         consideration to be received in the transaction, was fair.
Inventory Sourcing, page 165

5.       Please revise your disclosure in this section to discuss the known
uncertainties you have
         disclosed in your risk factors on pages 34 and 36 regarding the
concentration of your
         corporate vehicle sourcing partners and the alternative fee
arrangements you may enter
         into with such partners from time to time that may affect your gross
profit per unit. Refer
         to Item 303(a)(3)(ii) of Regulation S-K.
Debt Obligations, page 177

6.       We note your disclosure on page 178 that, pursuant to a promissory
note issued to
         Automotive Finance Corporation (   AFC   ) in December, AFC agreed to
make one
         advance of $3M to CarLotz; however, the Amendment to Demand Promissory
Note and
         Security Agreement, filed as exhibit 10.21.1, provides that the
Aggregate Advance Limit
         is $12,000,000. Please reconcile or explain this disclosure. In
addition, please file the
         note purchase agreement and revolving floor plan facility agreements
with AFC as
         exhibits or tell us why they are not required to be filed.
CarLotz Condensed Consolidated Financial Statements for the Nine Months Ended
September
30, 2020 and 2019
 Luis Solorzano
Acamar Partners Acquisition Corp.
December 21, 2020
Page 3
Notes to Condensed Consolidated Financial Statements
Note 18 - Stock-Based Compensation Plan, page F-51

7.       Please tell us whether the announced merger agreement with Acamar
Partners represents a
         triggering event for vesting of stock options under the 2017 Stock
Option Plan.
Note 22 - Subsequent Events
Acamar Partners Acquisition Corp. Merger, page F-55

8.       Please revise to include disclosure of the key terms of the merger
with Acamar Partners
         and disclose how the transaction will be accounted for when
consummated. Refer to ASC
         805-10-50-1.
Acamar Partners Acquistition Corporation Condensed Financial Statements
For the Three and Nine Months Ended September 30, 2020 and 2019
Notes to Condensed Financial Statements
Note 8. Subsequent Events
Merger Agreement, page F-89

9.       Please revise your disclosure to include the terms and purpose of the
PIPE Investment to
         issue 12.5 million shares of Class A common stock at $10 per share to
raise proceeds of
         $12,500,000 to occur concurrently with the merger agreement.
       You may contact Robert Shapiro at 202-551-3273 or Linda Cvrkel at
202-551-3813 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at 202-551-4515 or Jacqueline Kaufman at 202-551-3797 with
any other
questions.



FirstName LastNameLuis Solorzano                             Sincerely,
Comapany NameAcamar Partners Acquisition Corp.
                                                             Division of
Corporation Finance
December 21, 2020 Page 3                                     Office of Trade &
Services
FirstName LastName