SecProbe.io

January 4, 2012
Via E-mail

Nicholas S. Schorsch 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.
Amendment No. 1 to Registrati on Statement on Form S-11
Filed October 27, 2011
  File No. 333-177563

Dear Mr. Schorsch:

We have reviewed amendment no. 1 to your registration statement and have the
following comments.  In some of our comments, we may ask you to provide 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 response to comment 4 of our le tter dated November 23, 2011.  Please note
that you are responsible for analyzing the a pplicability of Regulation M to your share
repurchase program.  We are not taking a posit ion on the conclusions described in your
response.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 2
 2. We note your response to comment 5.  Please re vise the last full pa ragraph on page 6 and
the second paragraph on page 203 to clarify th at the advisor will re view the valuation
estimate established by the independent valu er for consistency with your valuation
guidelines and the reasonableness of the conc lusions and may in its discretion consider
other factors in calculating the NAV.  Please include similar disclo sure regarding the
advisor’s authority to review and adjust the values determined by the independent valuer
in the new risk factor on page 34.
 3. We note your disclosure on pages 36, 102, and 143 regarding the proceeds raised by
American Realty Capital (“ARC”) Propertie s.  We note that on pages 102 and 143 you
provide different amounts of net proceeds ra ised and that on page 36 you disclose the
gross proceeds.  Please revise your disclo sure on pages 102 and 143 as appropriate to
address the discrepancy in the amounts and plea se ensure that your disclosure on page 36
is accurate.

Prospectus Cover Page

 4. We note your response to comment 7 of our  letter dated November 23, 2011.  Please
confirm that the cover page of the prospectus delivered to investors will have at least a 10
point modern type font as required by Rule  420 of Regulation C.  If necessary, please
consider removing disclosure  not required by Item 501 of Regulation S-K or Industry
Guide 5.

5. We note your response to comment 8 of our  letter dated November 23, 2011.  Please
disclose the number of other programs cu rrently managed by your sponsor.  Please make
similar revisions to your disclosure on page 8.

6. Please revise your cover page to provide disc losure regarding the shares to be offered
pursuant to your dividend reinve stment plan.  Please refer to  Item 501 of Regulation S-K.
 What is the purchase price for shar es of our common stock?, page 6

 7. We note your intention to file a monthly pric ing supplement.  Prior to effectiveness,
please provide us a draft of the monthly s upplement.  The monthly supplement should
prominently disclose the website address a nd phone number where the most recent price
may be obtained and should include disclo sure of the NAV per share for each of the
business days in the prior month.  In additi on, to the extent the NAV per share deviates
by more than 5% from the price disclosed in  the most recently filed prospectus, please
confirm that you will file an updated pricing supplement.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 3
 How will your advisor calculate NAV per share?, page 7

 8. Please disclose in this secti on that the fees that you pay your  advisor and other affiliates
that are based on NAV will be higher because  you are amortizing certain costs over the
five year period, resulting in a higher NAV.  Additionally, please  disclose that this will
result in investors paying a higher price than if these costs were not amortized.

9. We note your response to comment 13 of our letter dated November 23, 2011.  We
reissue our comment.  Please revise to clarif y whether the independent valuer will also
value the liabilities.  For example, the disc losure on page 34 indi cates the independent
valuer will value liabilities but the disclosu re on page 126 indicates that the advisor will
perform this calculation.
 What are your exit strategies?, page 11

 10. We note your response to comment 17 of our  letter dated November 23, 2011.  Please
revise to clarify whether the three to six y ear period is measured from the conclusion of
the offering covered by this registration statem ent, or the conclusion of the offering as
may be extended via a follow-on registration stat ement.  In addition, please disclose in
this section that your intended liquidity events  are subject to the boa rd determining it is
appropriate to commence a liquidity event and that a majority of your shareholders will
need to approve a liquidity event.  Pleas e clarify, if true, that you may continue
indefinitely if a majority of your sharehol ders do not approve a liquidity transaction.
Please also revise your disclosu re on page 118 as appropriate.

What are the fees that you will pay …?, page 14

11. We note your disclosure that you will pay your advisor a subordinated participation fee or
subordinated incentive fee equal to 15%.  Ho wever, on page F-12, you indicate that these
fees will equal 25%.  Please revise, as appropriate, to correct this discrepancy.
 Valuation Policies, page 125

 12. We note your response to comment 28 of our  letter dated November 23, 2011.  We will
continue to monitor for your response to this comment.
 Management’s Discussion and Analysis of Fina ncial Condition and Results of Operation, page
131
 Liquidity and Capital Resources, page 131

 13. Please expand your discussion to disclose the amount of organizational and offering costs
incurred/paid on your behalf to date.  Al so, expand your footnotes to include your
accounting policy for orga nizational costs.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 4
 Table I, page A-2

 14. We note your response to comment 33.  We s till do not understand how this ratio can be
negative.  Assuming this issue is addressed, we  do not object to the presentation given the
clarifying footnotes.  However, please note that we would also  not object to the inclusion
of the ratios in the footnotes directly in the table.  The to tal acquisition cost for purposes
of the percentage leverage row in Table I ma y include the portion of  the acquisition cost
financed through a mortgage.
Draft Opinions

15. We note your response to comment 37 of our letter dated November 23, 2011.  Please file
these opinions as part of your correspondence on EDGAR.
 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
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 5
 You may contact Wilson Lee at (202) 551- 3468 or Jessica Barber ich, Assistant Chief
Accountant, at (202) 551-3782 if you have que stions regarding comments on the financial
statements and related matters.  Please contact Stacie Gorman at (202) 551-3585 or me at (202)
551-3852 with any other questions.
Sincerely,
   /s/ Michael McTiernan   Michael McTiernan
Assistant Director
cc: Peter M. Fass, Esq. ( via e-mail )