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Mailstop 3233
April  29, 201 6

VIA E -MAIL
Mr. Donald W. Barney
Chief Financial Officer
First Real Estate Inves tment Trust of New Jersey
505 Main Street
Hackensack, NJ  07601

Re: First Real Estate Investment Trust of New Jersey
 Form 10-K for the  fiscal year e nded October  31, 201 5
Filed January  14, 2016
File No. 000 -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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believ e our
comments apply to your facts and circumstances, please tell us why in your response.

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

Form 10 -K for  the fiscal year ended October  31, 2015

Item 7. Management’s Di scussion and Analysis of Financial Condition and Results of
Operations

Development Activities, page 25

1. We note your  disclosure regarding the Rotunda redevelopment  and the costs incurred as
of the period end date. In future periodic filings please expand your disclosures to discuss
the anticipated completion dates  and the estimated costs to completion for  the Rotunda
property and any other significant material development and/or redevelopment projects.

Mr. Donald W. Barney
First Real Estate Inves tment Trust of New Jersey
April  29, 201 6
Page 2

 Note 16. Pathmark Stores, Inc. Bankruptcy Filing,  page 62

2. We note your disclosure of the loss provision  related to  the straight line rent receivable
balance for Pathmark and how the provision had no impact on funds from operations.
Since the straight line rent adjustment is a part of calculating net inc ome and ultimately
funds from operations , it appears that the loss provision did impact funds from
operations. Please clarify a nd/or revise future periodic filings to adequately reflect what
is being presented.

We urge 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 a ll 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 as sert 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 Jeffrey Lewis, Staff Accountant, at (202) 551 -6216 or the undersigned
at (202) 551 -3468 wi th any questions.

Sincerely,

        /s/ Wilson K. Lee

 Wilson K. Lee
Senior Staff Accountant
Office of Real Estate and
Commodities