Exhibit 21

TO FORM 10-K OF
SEA PINES ASSOCIATES, INC.

Subsidiaries of Sea Pines Associates, Inc.

     Sea Pines Company, Inc., a South Carolina corporation, and Sea Pines Associates Trust I, a Delaware business trust, are wholly owned direct subsidiaries of Sea Pines Associates, Inc. Sea Pines Company, Inc. has one significant subsidiary, Sea Pines Real Estate Company, Inc., a South Carolina corporation doing business as Sea Pines Real Estate Company.