SecProbe.io

February 7, 2019
Frederick Herbst
Chief Financial Officer
Ready Capital Corporation
1140 Avenue of the Americas, 7th Floor
New York, NY 10036
Re:Sutherland Asset Management Corporation
Form 10-K for the year ended December 31, 2017
Filed March 16, 2018
File No. 001-35808
Dear Mr. Herbst:
            We have reviewed your February 1, 2019 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
January 31, 2019 letter.
Form 10-K for the year ended December 31, 2017
Consolidated Statements of Income, page 115
1.We note your response to comment 3.  We continue to be unclear how you determined
that the current presentation of "gains on residential mortgage banking activities, net of
variable loan expenses" is compliant with Rule 9-04 of Regulation S-X.  Please
specifically address the following:
•Explain to us why realized and unrealized gains and losses on residential mortgage
loans and unrealized gains (loss) on IRLCs and other derivatives are characterized as
non-interest income while realized and unrealized gains on other financial instruments
are presented below total non-interest expense.  Additionally, tell us why a $4 million
unrealized loss and a $6.9 million unrealized gain on residential mortgage banking
financial instruments were recorded in 2017 and 2016, respectively, in "Net unrealized

 FirstName LastNameFrederick Herbst
 Comapany NameReady Capital Corporation
 February 7, 2019 Page 2
 FirstName LastName
Frederick Herbst
Ready Capital Corporation
February 7, 2019
Page 2
gain on financial instruments" rather than with the other residential mortgage banking
gains and losses recorded within non-interest income. Within your response, please
reference the authoritative literature management relied upon.
•Cite specific authoritative literature to support your position that loan origination fee
income on loans carried at fair value should not be classified as interest income in
accordance with Rule 9-04.1 of Regulation S-X.  We note that origination fees on
loans carried at fair value are not deferred and amortized like the origination fees on
loans held for investment.  However, please clarify for us how you determined that the
timing of revenue recognition would impact the characterization of recognized fees on
the statements of income.
•Cite specific authoritative literature to support your policy of presenting
"correspondent fees and other direct loan expenses, including the provision for loan
indemnification" as a reduction of the related income rather than as an expense.
            You may contact Kristi Marrone at (202) 551-3429 or Jennifer Monick at (202) 551-3295
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities