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    Dechert
    LLP

    1900
    K Street, N.W.

    Washington, DC 20006-1110

    +1
    202 261 3300 Main

    +1
    202 261 3333 Fax

                                               Brenden
    Carroll

    Partner

    brenden.carroll@dechert.com

    +1
    202 261 3458 Direct

    +1
    202 261 3333 Fax

October
23, 2025

Securities
and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Ms. Chritina DiAngelo Fettig

Re: AFL-CIO
                                            Housing Investment Trust (the “Registrant” or the “Fund”)

  (File
                                            Nos. 811-03493; 333-59672)

Dear
Ms. DiAngelo Fettig:

This
letter responds to comments that you conveyed to Jonathan Blaha and me via telephone on September 18, 2025. These comments pertain to
your review pursuant to the Sarbanes-Oxley Act of 2002 of the annual report filed on Form N-CSR for the Fund, relating to the fiscal
year ended December 31, 2024 (the “Form N-CSR”).

For
your convenience, the substance of those comments has been restated below. The Fund’s response to each comment is set out immediately
under the comment. Capitalized terms used in this letter and not otherwise defined herein shall have the meaning specified on the Form
N-CSR.

COMMENTS
TO THE TAILORED SHAREHOLDER REPORT

 Comment
                                            1. For the Fund’s costs for the past twelve months based on a hypothetical $10,000 investment,
                                            please confirm that you are calculating the costs in accordance with Form N-1A Item 27A(c),
                                            Instruction 2(a).

Response
1.          The Registrant confirms that the costs were calculated
in accordance with Form N-1A Item 27A(c), Instruction 2(a).

 Comment
                                            2. For the average annual total returns chart, you have included gross returns. That is neither
                                            required nor permitted by Form N-1A Item 27A. Please remove the gross return in future filings.

Response
2.          The Registrant acknowledges the Staff’s comment
and will update the disclosure in future filings.

 Comment
                                            3. In the fund holdings section, in future filings, please disclose whether the charts are based
                                            on net assets, total investments, or total exposure.

Response
3.          The Registrant acknowledges the Staff’s comment
and will update the disclosure in future filings.

COMMENTS
REGARDING THE FINANCIAL STATEMENTS AND THE FUND’S INVESTMENT IN HIT ADVISERS

 Comment
                                            4. Please provide a consolidation analysis regarding the Fund’s investment in HIT Advisers.

Response
4.          The Registrant has reviewed the relevant guidance and
concluded that consolidating the financial statements of HIT Advisers with the Fund is neither required, nor appropriate, under current
regulations applicable to investment companies.

There
are two relevant sources of accounting guidance on consolidation. The Registrant has reviewed Topic 810 Consolidation and specifically
guidance for 946 Financial Services—Investment Companies. Paragraph 810-10-15-10(a)(3) states that consolidation by an investment
company of a non-investment-company investee is not appropriate. ASU 2013-08, specifically ASC 946-10-15-6, states that an investment
company has the following basic characteristics:

 ● It
                                            is an entity that: 1) obtains funds from one or more investors and provides the investors
                                            with investment management services; and 2) commits to its investors that its only business
                                            purpose and only substantive activities are investing the funds solely for returns from capital
                                            appreciation, investment income, or both.

 ● The
                                            entity or its affiliations do not obtain or have the objective of obtaining return or benefits
                                            from an investee or its affiliates that are not normally attributable to ownership interests
                                            or that are other than capital appreciation or investment income.

Under
the above guidance, HIT Advisers is not an investment company. ASC 946-810-45-3 provides an exception to the principles stated in ASC
946-10-15-6 if the investment company has an investment in an operating entity that provides services to the investment company (e.g.,
investment adviser or transfer agent services). In those cases, if the purpose of the investment is the provision of services to the
investment company rather than to realize a gain on the sale of the investment, and the investment company holds a controlling interest
in such an operating entity, consolidation is deemed appropriate. The Fund has been and will continue to be internally managed and HIT
Advisers has not and will not serve as a registered investment adviser to the Fund. Therefore, the exception provided in ASC 946-810-45-3
is not applicable with respect to HIT Advisers.

    2

The
Registrant has also reviewed the SEC Division of Investment Management’s 2014 release related to investment company consolidation
(IM Release No. 2014-11). This release notes that, “[i]n deciding upon consolidation policy, the registrant must consider
what financial presentation is most meaningful in the circumstances and should follow in the consolidated financial statements principles
of inclusion or exclusion which will clearly exhibit the financial position and results of operations of the registrant.”

The
Registrant has concluded that it would not be appropriate for the Fund to consolidate the financial statements of the Fund and HIT Advisers.
Such consolidation would not be permitted as HIT Advisers is not an investment company and consolidation would not provide the most meaningful
picture of the Fund and its operations. Moreover, HIT Advisers is not a service provider to the Fund within the meaning of ASC 946-810-45-3.

 Comment
                                            5. Please supplementally explain in correspondence how the disclosure requirements in (a)
                                            Reg. S-X Rule 12-14 have been met. Please also supplementally explain how the requirements
                                            of (b) Reg. S-X Rule 6-04.2, (c) Rule 6-07.1, and (d) Rule 6-07.7 have
                                            been addressed.

Response
5.

a.          Reg. S-X Rule 12-14: The Registrant acknowledges the Staff’s comment and submits that the disclosure requirements of Reg.
S-X Rule 12-14 are met in Note 3 to the Financial Statements (Transactions with Related Entities).

b.          Reg. S-X Rule 6-04.2: The Registrant acknowledges the Staff’s comment and submits that, because the investment in HIT Advisers
is less than 0.01% of the Fund’s net assets, listing its value on the balance sheet would be immaterial and could be severely distorted
due to rounding. Therefore, the Registrant has included it as part of “Other Assets” in the Statement of Assets and Liabilities
and provides a further explanation of the holding in Footnote 8 to the Schedule of Investments, which the Registrant submits provides
a more complete explanation of the investment to Shareholders than to list it as a separate line item in the Statement of Assets and
Liabilities. The Registrant will amend future filings to include a disclosure in Note 3 stating that such balances are reported under
“Other Assets” on the Statement of Assets and Liabilities.

    3

c.          Reg. S-X Rule 6-07.1: The Registrant acknowledges the Staff’s comment and submits that, because any income received from
HIT Advisers does not exceed five percent of the total investment income of the Fund, it does not require a separate disclosure in the
Statement of Operations under Reg. S-X 6-07.1 and, therefore, the disclosure requirement has been met.

d.          Reg. S-X Rule 6-07.7: The Registrant acknowledges the Staff’s comments and notes that the required disclosure is provided
in Note 3 to the Financial Statements (Transactions with Related Entities). The Registrant submits that, due to the size of the
investment in HIT Advisers, including the information in the Statement of Operations would be immaterial and that including the
disclosure in the Note 3 to the Financial Statements, alongside further disclosure regarding the Fund’s investment in HIT
Advisers, provides shareholders with a more complete explanation of the investment. The Registrant will amend future filings to include
a disclosure in Note 3 stating that such balances are reported within the applicable line items on the Statement of Operations.

 Comment
                                            6. Please supplementally confirm in correspondence that the significance tests of Reg. S-X Rule
                                            1-02(w)(2) have been performed.

Response
6.          The Registrant confirms that the significance tests of
Reg. S-X Rule 1-02(w)(2) have been performed.

 Comment
                                            7. Note 3 to the Financial Statements (Transactions with Related Entities) discloses an ending
                                            balance of advances to the HIT Advisers. Please clarify how this relates back to the balance
                                            sheet and where this would be disclosed on the balance sheet.

Response
7.          The Registrant confirms that this ending balance is included
as part of “Other Assets” in the Statement of Assets and Liabilities. The Registrant will include additional disclosure
in Note 3 to the Financial Statements to clarify this information in future filings.

    4

 Comment
                                            8. Note 3 to the Financial Statements (Transactions with Related Entities) also discloses that
                                            the Fund maintains an allowance for doubtful receivable due to aging balances. Please explain
                                            what this is.

Response
8.          In addition to its interest in HIT Advisers, the Fund
provides HIT Advisers advances to assist with its operations and cash flow management as needed. Advances are expected to be repaid as
cash becomes available. As with many start-up operations, however, when the Fund first took its interest in HIT Advisers, there was no
certainty that HIT Advisers would generate sufficient revenue to cover its operations and liabilities and the Fund determined an allowance
for doubtful receivables due to an aging balance under Generally Accepted Accounting Principles. As of December 31, 2024, the Fund maintains
an allowance for doubtful receivables for HIT Advisers of $600,000. The Fund will provide additional disclosure in future filings to
explain this allowance.

COMMENTS
REGARDING THE BALANCE SHEET

 Comment
                                            9. Please confirm whether there are any open payables to directors or trustees. If so, please
                                            disclose these open payables separately per Reg. S-X, Rules 6-04(12) and 6-03(l).

Response
9.          The Registrant confirms that there are no open payables
to directors or trustees.

 Comment
                                            10. The Schedule of Portfolio Investments – Short Term Investments discloses a holding
                                            in Blackrock Federal Funds. If this is a multiple-class fund, please disclose the class of
                                            shares of the Fund in future filings.

Response
10.        The Registrant acknowledges the Staff’s comment and will update
the disclosure in future filings.

COMMENTS
REGARDING THE NOTES TO FINANCIAL STATEMENTS

 Comment
                                            11. Note
                                            1 to Financial Statements – Investment Valuation – Last Paragraph: FASB ASC
                                            820-10-50-2(g) requires a narrative description of the uncertainty of fair value measurements.
                                            The disclosures states that “[a] change in unobservable inputs may impact the value
                                            of the loans.” This disclosure is vague and generic in nature. Please review the disclosure
                                            requirements and consider updating the disclosure in future filings.

Response
11.        The Registrant acknowledges the Staff’s comment and will consider
updating the disclosure in future filings when assessing the unobservable inputs relevant to the Fund’s holdings during the fiscal
period.

    5

 Comment
                                            12. Note
                                            1 to Financial Statements – Investment Valuation – Last Paragraph: This paragraph
                                            discloses the weighted average lives of the investments. FASB ASC 820-10-50-8 requires:

 (a) that
these quantitative disclosures be presented in a tabular format; and

 (b) disclosure
of the weighted average and an explanation of how the weighted average was calculated.

Response
12.        The HIT acknowledges the Staff’s comment and will update the
disclosure in future filings.

 Comment
                                            13. Note
                                            1 to Financial Statements – Investment Valuation – Last Paragraph: The Fund’s
                                            investment in HIT Advisers was not specifically referenced in the disclosure identifying
                                            the Level 3 securities held by the Fund. Please ensure that this disclosure includes required
                                            disclosure for the investment in HIT Advisers.

Response
13.        The Registrant acknowledges the Staff’s comment and respectfully
notes that HIT Advisers is noted to be a Level 3 investment in the Schedule of Portfolio Investments and the valuation methodology
for HIT Advisers is provided the eighth paragraph of Note 1 to the Financial Statements – Investment Valuation.

 Comment
                                            14. Note
                                            1 to Financial Statements – Investment Valuation – Second Paragraph – Second
                                            Sentence: FASB ASC 946-320-40-1 requires disclosing whether gains and losses are calculated
                                            by specific identification or average cost method. Please make this disclosure in future
                                            filings. The current disclosure states that “[g]ains and losses on securities sold
                                            are determined on the basis of amortized cost.”

Response
14.        The Registrant acknowledges the Staff’s comment and will update
the disclosure in future filings.

    6

 Comment
                                            15. Note
                                            8 to Financial Statements – Paragraph Immediately Following Bullet Point c: The
                                            disclosure states that, “[m]ost recent PPA zone status is for 2022 Plan Year….”
                                            FASB ASC 715-80-50-3 defines “most recently available information” as the date
                                            through which subsequent events have been evaluated. Please confirm that the most recent
                                            zone status was evaluated as of the date through which the subse