SecProbe.io

Mail Stop 4561

July 26, 2007

Mr. Steven R. Mumma
President, Co-Chief Executive Officer and Chief Financial Officer
New York Mortgage Trust, Inc.
1301 Avenue of the Americas
New York, NY  10019

Re: New York Mortgage Trust, Inc.
Form 10-K for the fiscal year ended December 31, 2006
File No. 001-32216

Dear Mr. Mumma:

We have reviewed your filing and have the following comments.  We have
limited our review to only  your financial statements and related disclosures and do not
intend to expand our review to  other portions of your documents. Where indicated, we
think you should revise your document in response  to these comments in future filings.  If
you disagree with a comment, we will consider your explanation as to why our comment
is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Mumma
New York Mortgage Trust, Inc.
July 26, 2007 Page 2
Form 10-K for the fiscal year ended December 31, 2006

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Significance of Estimates and Critical Accounting Policies

Loan Loss Reserves on Mortgage Loans, page 34
1. We note from your disclosure on page 33 that you repurchased a total of $28.9 million of mortgage loans in 2006, that  sub-prime and Alternative-A loans
comprised approximately 10% and 26% of  your 2006 originations, respectively.
Additionally, we have noted disclosure , in your Form 8-K filed on April 3, 2007,
that repurchases in February and Marc h of 2007 led to an increase in your 2006
loan loss reserves by an additional $782,000.  In light of unfavorable market
conditions, recent downgrades of mortgage backed securities by credit agencies,
and the likelihood that climbing interests rate s will lead to higher default rates as
ARM and Hybrid ARM reset, please tell us how these negative trends and the
industry downturn has impacted your impa irment analyses and include discussion
of specific assumptions that have cha nged in connection with performing these
analyses.  In your response , please address both loan re purchases as well as loans
held for the purpose of generating net interest income.  Finally, please tell us the amount of loans, if any, that you have been  required to repurc hase related to your
origination business subsequent to  your most recent periodic filing.

Financial Statements

Consolidated Statements of Cash Flows, page F-7
2. We note that dividends paid have ex ceeded net cash pr ovided by (used in)
operating activities during two of the three periods provided in your consolidated
statements of cash flows.  Please discuss the source(s) of these excess distributions, within the Liquidity and Capital Resources  section of your
Management’s Discussion and Analysis of  Financial Condition and Results of
Operations , as dividends in excess of net cas h provided by operating activities
raise concerns about the sust ainability of dividend distri butions into the future.

1.  Summary of Significant Accounting Policies

Mortgage Loans Held in Securitization Trusts, page F-10
3. We note from your disclosure that your fourth securitiza tion in March 2006
(unlike the first three that were treated as financings) was treated as a sale for
accounting purposes.  Please tell us how you met all of the crite ria in paragraph 9
of SFAS 140 in order to qualif y for sales treatment.  A dditionally, please provide

Mr. Mumma
New York Mortgage Trust, Inc.
July 26, 2007 Page 3
the disclosures required by paragraph 17h of SFAS 140, including disclosure of
the gain or loss from the sale of assets in securitizations.

2.  Investment Securities Available For Sale, page F-15
4. We note that you have accounted for the retained interests from your
securitization transactions within Investment Securities Available For Sale .  Your
disclosure on page F-15 indicates that you determined the carrying value for the $23.9 million in retained interests by obtaining dealer quotes.  Given the nature of
the retained interests, plea se give us a detailed un derstanding of how you have
reached the determination that such secu rities have not been impaired under the
guidance in SFAS 115 and in light of r ecent in events in the market, which
include significant pricing pressure on lesser quality secu rities as well as
illiquidity.

General
5. Please provide Schedule IV –  Mortgage Loans on Real Estate as prescribed by
Rule 12-29 of Regulation S-X.

Exhibit 31.1 and 31.2
6. We noted that you have made certain m odifications to the exact form of the
required certifications incl uding the deletion of the la nguage “(the registrant’s
fourth fiscal quarter in the case of an  annual report)” in paragraph 4(d) and
changing the phrase “other certifying office r(s)” to “other certifying officers” in
paragraphs 4 and 5.  Please discontinue th e use of modifications in future filings
as certifications required under Excha nge Act Rules 13a-14(a) and 15d-14(a)
must be in the exact form set forth in  Item 601(b)(31) of Regulation S-K.

 As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please submit a response letter on EDGAR that keys your responses to our comment s and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please understa nd that we may have
additional comments after reviewin g your responses to our comments.

 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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed decision.  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.

Mr. Mumma
New York Mortgage Trust, Inc.
July 26, 2007 Page 4
 In connection with responding to our comments, please provide, in writing, a 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 You may contact Howard Efron, Staff Accountant, at  (202) 551-3439 or me at
(202) 551-3629 if you have questions regard ing comments on the financial statements
and related matters.

       S i n c e r e l y ,

Kevin Woody
Branch Chief