SecProbe.io

March 21, 2013

Via U.S. Mail
Donald W. Barney
President, Treasurer and Chief Financial Officer
First Real Estate Investment Trust of New Jersey
505 Main Street
Hackensack, N J  07601

Re: First Real Estate Investment Trust of New Jersey
Form 10 -K for fiscal y ear ended October 31, 2012
  Filed January 14, 2013
  File No. 0-25043

Dear Mr. Barney :

We have reviewed your filing an d 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 within ten business days by providing the requested
information  or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 10 -K for fiscal year en ded October 31, 2012

Item 1 Business, page 3

Commercial Shopping Center Properties …, page 8
 In future Exchange Act periodic reports, please disclose the percentage of revenue 1.
provided by each of your top tenants.

Item 2. Properties, page 15
 Please revi se your disclosure in future Exchange Act periodic reports to discuss whether 2.
you provide rent concessions or abatements and the impact of any concessions or
abatements.

Donald W. Barney
First Real Estate Investment Trust of New Jersey
March 21, 2013
Page 2

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 21

General
 In future Exchange Act periodic reports, for your commercial properties, please expand 3.
your disclosure of your leasing activities for the reported period to include a discussion of
the volume of new or renewed leases, tenant impr ovement costs, and leasing
commissions.   These should be presented on a per square foot basis .  Also, please
compare new rents on new and renewed leases to prior rent based on effective rent.   In
addition, to the extent you have material lease expirations in the next year, please include
disclosure regarding the relationship of rents on expiring leases to market rents.

Segment Information, page 24
 We note that you have provided disclosure regarding your net operating income.   In 4.
future Exchange Act periodic reports, please also provide disclosure regarding “same -
store” net operating income.   Please also include a clear description of how you calcula te
NOI.

Liquidity and Capital Resources, page 33

Contractual Obligations, page 34
 We note the disclosure of contractual obligations under your mortgage loans and 5.
construction loan as of October 31, 2012.  Please tell us, and provide disclosure in future
filings, your cash r equirements for interest on outstanding  long-term debt.  Refer to
footnote 46 of SEC  Interpretive Release 33 -8350.

Funds from Operations, page 35
 We note your disclosure of FFO.  Please address the following:  6.
a. It does not appear that yo u have presented FFO as defined by NAREIT.  Please
advise or revise future filings and provide us with an example of your proposed
disclosure to present FFO as defined by NAREIT.  You may present adjusted
FFO for any additional adjustments.  Adjusted FFO s hould be reconciled to FFO
as defined by NAREIT.
b. Please tell us how your disclosure complies with Item 10(e) of Regulation S -K.
Specifically, please tell us how you determined it was not necessary to provide a
statement disclosing the reasons why you believe the use of FFO provides useful
information.  Refer to Item 10(e)(1)(i)(C).

Donald W. Barney
First Real Estate Investment Trust of New Jersey
March 21, 2013
Page 3

 Item 15 . Exhibits, Financial Statements  and Schedules , page 40

(a) Financial Statements

Notes to Consolidated Financial Statements, page 47

Note 1 – Organization and significant accounting policies, page 47

Real estate development costs, page 48
 Please tell us how you account for costs capitalized where the underlying project is 7.
cancelled or postponed, and cite the applicable accounting literature relied upon.

We urg e all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and  its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from  taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at
202.551.3295  if you have questions regarding comments on the financial statements and related
matters.  Please contact  Stacie Gorman, Attorney -Adviser  at 202.551. 3585  or Tom Kluck, Legal
Branch Chief at 202.551.3233  with any other questions.

Sincerely,

 /s/ Jennifer Monick

Jennifer Monick
Senior Staff Accountant