SecProbe.io

Mail Stop 4561

October 16, 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 response letter  dated September 21, 2007 and have the
following additional comments.  If you disagr ee with our comments, we will consider
your explanation as to why our comments are not applicable.  Pleas e be as detailed as
necessary in your explanation.

 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.

Form 10-K for the fiscal year ended December 31, 2006

Financial Statements

Investment Securities Available for Sale, page F-15

1. We note your response to prior comment 4 and your indication that the $23.9
million of NYMT Retained Securities as  of December 31, 2006 was comprised of
$21.9 million of securities rated BBB or higher and $2.0 million of non-investment grade securities.  Please help us to better understand the quality of the

Mr. Steven Mumma
New York Mortgage Trust, Inc.
October 16, 2007 Page 2
dealer quotes which you utilize for purposes  of valuing your securities.  In your
response, please tell us for both the i nvestment grade portion and for the non-
investment grade portion of your securitie s whether the dealer quotes you obtain
represent unadjusted price quotes for identical securitie s in active markets and to
what degree such dealer quotes were available to price your NYMT Retained
Securities as of December 31, 2006.  If such “high quality ” dealer quotes were not
available to price a portion of your  NYMT Retained Securities, please
quantify/segregate that portion of your secu rities for us and desc ribe the quality of
the quotes which were used in such ci rcumstances and how you generally utilize
such quotes to make valuations on your s ecurities.  For instance, tell us if you are
using dealer quotes on similar assets, wh ether or not these quotes are based on
active markets and whether the quotes are current.

General

2. We note your response to prior comment 5.  In future filings, please include the reconciliation of the carrying amount of mortgage loans de scribed in footnote 6 to
Schedule IV –  Mortgage Loans on Real Estate .

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 response to our comments 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 response to our comments.

 You may contact Howard Efron, Sta ff Accountant, at (202) 551-3439 or the
undersigned at (202) 551-3629 if you have questions regarding the comments on the
financial statements and related matters.

       S i n c e r e l y ,

Kevin Woody
Branch Chief