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April 29, 2022
David Bryant
Chief Financial Officer
ACRES Commercial Realty Corp.
390 RXR Plaza
Uniondale, NY 11556
Re:ACRES Commercial Realty Corp.
Form 10-K for fiscal year ended December 31, 2021
Filed March 9, 2022
File No. 001-32733
Dear Mr. Bryant:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for fiscal year ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Core Earnings, page 62
1.We note your disclosure of non-GAAP financial measures of Core Earnings and Core
Earnings per common share - diluted, which include adjustments for various realized and
unrealized gains (losses) and provision for (reversal of) CRE credit losses.  In light of
these and other reconciling items, please tell us how you determined it was appropriate to
title these measures as Core Earnings and Core Earnings per common share - diluted.
Further, given your response dated December 15, 2017 and consistent with other
mortgage REITs, tell us whether you continue to use these measures as distributable
earnings metrics; if so, revise your filing to disclose that purpose.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or

 FirstName LastNameDavid Bryant
 Comapany NameACRES Commercial Realty Corp.
 April 29, 2022 Page 2
 FirstName LastName
David Bryant
ACRES Commercial Realty Corp.
April 29, 2022
Page 2
absence of action by the staff.
            You may contact Mark Rakip, Staff Accountant at 202.551.3573 or Shannon Menjivar,
Accounting Branch Chief at 202.551.3856 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction