SecProbe.io

April 10, 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. 2 to Registrati on Statement on Form S-11
Filed March 29, 2012
  File No. 333-177563

Dear Mr. Schorsch:

We have reviewed amendment no. 2 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. Based on the disclosure throughout the prospe ctus, it appears that the value to be
assigned to the property portfo lio in any future disclosure  of NAV per share will be
attributed to the valuation expert.  Conseque ntly, please confirm that the valuation expert
will file a consent with respect to this disclosure.  If the property portfolio value is not
intended to be attributed to the valuation e xpert, please revise the disclosure to clarify
that the advisor is responsible for the value as signed to the property portfolio, explain in
detail how the advisor will exercise its disc retion in calculating the property value, and
remove the reference to the valuation expert in the “Experts” secti on of the prospectus.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. April 10, 2012 Page 2
 Management’s Discussion and Analysis …, page 139

 Liquidity and Capital Resources, page 139

 2. We have considered your revisions in response to comment 13.   Please expand your
discussion to also disclose the amount of or ganizational and offering costs incurred/paid
on your behalf subsequent to December 31, 2011, if material.

Statement of Cash Flows, page F-6

3. The amount presented for deferred offering costs paid directly by affiliates is inconsistent
with the amount disclosed within Note 3 on pa ge F-12.   Please clarify and revise, as
necessary.
Note 2 – Summary of Significant Accounting Policies, page F-8

4. Please expand to include your accounting policy fo r organizational costs.   Reference is
made to paragraph 720-15-25-1 of FASB Accounting Standards Codification which
indicates organizational costs s hould be expensed as incurred.
 Table III – Operating Results of Pu blic Program Properties, page A-8

 5. We note your disclosure in footnote (5) indicatin g that the Federal tax results for the year
ended December 31, 2011 is not available as of the date of the filing.  Please update this
information after April 15, 2012; to the exte nt necessary, include estimated information
along with a footnote noting the source of the data and whether the data is subject to
adjustment.

 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;

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. April 10, 2012 Page 3
  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.
 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 )