SecProbe.io

November 23, 2011
 Via E-mail

Nicholas S. Schorsch Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. 405 Park Avenue 15
th Floor
New York, NY 10022

Re: American Realty Capital Global Daily Net Asset Value Trust, Inc.
Registration Statement on Form S-11 Filed October 27, 2011
  File No. 333-177563

Dear Mr. Schorsch:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe  our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

 1. We note your disclosure on page 181 regardi ng the share redemption program.  Please
provide us with a detailed legal analysis of  the applicability of the tender offer rules,
including Rule 13e-4 and Regulation 14E, to your share repurchase program.  We urge
you to consider all the elements of your  share repurchase program in determining
whether the program is consistent with re lief granted by the Division of Corporation
Finance in prior no action letters. See, for example, T REIT Inc. (Letter dated June 4, 2001) and Wells Real Estate I nvestment Trust II, Inc. (Le tter dated December 3, 2003).
To the extent you have questions as to whether the program is entirely consistent with the
relief previously granted by the Division of  Corporation Finance, you may contact the
Division’s Office of Mergers and Acquisitions.  Please note  that we will refer your
response to the Office of Mergers an d Acquisitions for further review.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 2
 2. Please submit all written sales materials pr oposed to be transmitted to prospective
investors, orally or in writing, including that  intended for broker-dealer use only.  Please
be aware that we will need time to review th ese materials.  In addition, note that sales
materials must set forth a balanced presentati on of the risks and rewards to investors and
should not contain any informati on or disclosure that is not contained in or derived from
the prospectus.  For guidance, refe r to Item 19.D of Industry Guide 5.

3. Please provide us with copies of any graphi cs, maps, photographs, and related captions or
other artwork including logos th at you intend to use in the pr ospectus.  Such graphics and
pictorial representations should not be included in any prelim inary prospectus distributed
to prospective investor s prior to our review.

4. We note that you may conduct the share repurch ase program during the offering period of
the shares being registered under this registra tion statement.  Please be advised that you
are responsible for analyzing the applicabil ity of Regulation M to your share repurchase
program.  We urge you to consider all the el ements of your share repurchase program in
determining whether the program is consis tent with the class relief granted by the
Division of Market Regulation in the class ex emptive letter granted Alston & Bird LLP
dated October 22, 2007.  To the extent you have questions as to whether the program is
entirely consistent with that class exemp tion you may contact the Division of Market
Regulation.

5. Please advise us whether the independent valu er will file a Rule 436 consent with respect
to the disclosure of the property portfolio and liability values.  We note that you have
identified the valuer as an “expert” on page 211.

6. Please add disclosure in the summary section that the NAV calculation is an estimate and
that organizational and offering cost s are amortized over five years.

Cover Page

 7. Please ensure that your cover page does not  exceed one page in length as required by
Item 501(b) of Regulation S-K.  The cove r page should be limited to information
required by Item 501 and other information that is key to an investment decision.  Some
of the details of the offering may be more a ppropriate for the prosp ectus summary or the
body of the prospectus.
8. Please add a cover page and summary risk f actor relating to the competing time demands
imposed on the sponsor by all the other publ ic programs it is currently managing.
 9. Please clarify that the shares sold pursuant to the dividend reinvestment  plan will also be
based on your net asset value.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 3
 Investment Objectives, page 2

 10. We note your disclosure in this section that you will seek to invest 25% of your capital in
Europe.  However, on page 62 and elsewhere,  you indicate that you may invest up to
40% of your capital in Europe. Further, you in dicate that up to 10% of your investments
may be made elsewhere internationally.  Pl ease revise your disclo sure as appropriate.
 How is an investment in shares of your co mmon stock different from listed REITs?, page 2

 11. Please provide a more balanced comparison with listed REITs.  For example, please
disclose that common stock in a listed RE IT is more liquid than your common stock.

Who are your advisor and service provide rs and what will they do?, page 3

 12. Please revise to identify the European  service provider you intend to use.

How will your advisor calculate NAV per share?, page 6

 13. Please revise to clarify that the independent va luer will also value the liabilities.  Please
also provide more detailed disclosure of a ny adjustments the advisor might make to the
values calculated by th e independent valuer.
 Who should buy shares?, page 9

 14. We note that you refer to yourself as a finite -life entity.  However,  we note that you are
not required to liquidate by a specific date and that your board may determine when you
should commence a liquidity event.  Please revi se your disclosure to clarify this point.
 Will you use debt borrowing to finance your investments?, page 11

 15. Please revise to disclose the amount of leverage you are permitted to incur under your
charter.
 What are your exit strategies?, page 11

 16. We note your disclosure that you intend to begi n a liquidity event in three to six years
after the offering.  However, on page 114 and elsewhere, you state that you intend to
begin a liquidity event in six to eight y ears. Further, on page 130, you state that you
intend to begin a liquidity event in three to fi ve years.  Please revi se your disclosure as
appropriate to clarif y this discrepancy.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 4
 17. Please revise to disclose that your intended liquidity events are subject to the board
determining it is appropriate to commence a li quidity event and that  shareholders must
approve a proposed liquidity event.  Please revise to clarify, if true, that you may
continue indefinitely if your shareholde rs do not approve your proposed liquidity
transactions.
 What conflicts of interest will your advisor …?, page 12

 18. Please disclose the respective interest held  in your sponsor by Messrs. Schorsch and
Kahane.
 What are the fees that you will pay …?, page 14

19. Please clarify how your advisors and sub-adviso rs will be compensated if you enter into a
joint venture with an affiliate.
Selling Commissions, retail shares, page 15

 Platform Fee …, page 16

20. Please disclose the maximum platform fee to  be paid assuming you sell the total amount
of institutional shares being registered in th is offering.  Please make similar revisions in
the table on page 62 and in the table starting on page 84.
 Operating Expenses, page 19

 21. We note that you intend to reimburse your advisor for personnel costs.  Please
specifically state whether you w ill reimburse your advisor for th e salaries and benefits to
be paid to your named executive officers.  Please tell us what consideration you have
given to providing the disclosure requir ed by Item 402 of Regulation S-K regarding
compensation of your named executive officers.  Refer to Item 402(a)(2), which requires
disclosure of compensation paid “by any person for all services rendered in all capacities
to the registrant.”  Please make similar revi sions to your disclosure in the table starting on
page 84.
 Compensation and Restricted Stock Award s to Independent Directors, page 21

 22. We note your disclosure on page 70 regarding a per transaction fee that may be paid to
the directors.  Please provide disclosure regard ing this fee here and in the table starting on
page 84.
 Subordinated Distribution upon Termination of the Advisory Agreement, page 24

 23. Please revise to clarify how the amounts are determined.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 5
 Risk Factors, page 28

 It may be difficult to acc urately reflect…, page 32

 24. It appears that there may be material information known by the company regarding
changes in the NAV per share that may not be pr ovided to an investor prior to his or her
investment decision.  Please advise us why the company does not believe this creates a
significant liability issue.  Refer to Secti on 12(a)(2) and Rule 159 of the Securities Act.
 The management of multiple REITs…, page 34

 25. In this risk factor or the preceding risk factor, please identify the programs currently
publicly raising proceeds for investment a nd the aggregate dollar amount of securities
offered.
 We may not be able to sell our properties …, page 45

 26. We note your disclosure that “[m]any of [your ] leases will not contain rental increases
over time.”  However, on page 2, you indica te that your investme nt objective is “to
generate cash flow that will s upport a stable distribution to investors with potential for
growth through leases that link the rent to the change in the Cons umer Price Index, or
CPI, or other forms of lease increases.”  Pl ease revise you disclosure , as appropriate, to
address this discrepancy.
 Subordinated Participation in Net Sale Proceeds, page 84

 27. Please define the term “Net Sale Proceeds.”
 Valuation Policies, page 121

 28. Please provide a more detailed discussion of the process by which the advisor will
evaluate the independent valu er’s calculations and the ot her matters the advisor will
consider in making any adjustments.

Adverse Business Developments and Conditions, page 143

 29. Please provide more detail regarding the cumulative distributions and sources of
distributions of ARCT  since its inception.
 Plan of Distribution, page 199

 30. Please advise us whether the REIT intends to  conduct a follow-on offering.  If so, please
revise accordingly.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 6
 Subscription Process, page 204

 31. Please disclose whether a potential investor  can withdraw its subscription agreement
between the time of submission and time of accep tance.  Please also clarify whether the
purchase price is based on the NAV on the day of submission or acceptance.

Financial Statements and Notes

 Note 3 – Related Party Transacti ons and Arrangements, page F-10

 32. We note your advisor and its affiliates will receive compensation and reimbursement for
services relating to the offering and the inve stment and management of your assets.
Please expand your note disclosures to in clude significant terms relating to your
agreement with these entities.  Expanded disclosures should include information related to fees and compensation to be paid.

Table I, page A-2

 33. Please advise why the percentage leverage fo r ARC New York is ne gative.  In addition,
please confirm that the leverage ratios disclo sed in the footnotes ar e calculated in the
same manner as those in the table.

Table III: Operating Results of P ublic Program Properties, page A-10

34. We note footnote (5) of the table which states that Federal tax results for the year ended
December 31, 2010 are not available as of the da te of the filing.  Please advise us why
these are not available and revise to include  estimated information along with a footnote
noting the source of the data and whether the data is s ubject to adjustment.

Table V, page A-16
 35. Many of these properties appear to have been  purchased and sold at the same time.
Please advise.

Part II, page II-1

 Item 37. Undertakings, page II-3

 36. Please revise paragraph (A) clause (ii) to in clude the entire undert aking required by Item
512(a)(1)(ii) of Regulation S-K.

Exhibits

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 7
 37. Please file all required exhibits as promptly as  possible.  If you are not  in a position to file
your legal and tax opinions with the next am endment, please provide a draft copy for us
to review.

38. Please tell us why you are filing the “Form of ” various agreements.  Explain why you are
not able to file final, executed agreements  prior to effectiveness of the registration
statement.

39. We note that you filed an unexecuted versi on of your articles of amendment and
restatement as exhibit 3.1.  Please note that  the final executed version of this document
must be filed prior to effec tiveness.  Please refer to Item  601(b)(3) of Regulation S-K.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 8
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