SecProbe.io

April 22, 2015

Via E -mail
Timothy G. Wallace
President
Community Healthcare Trust Incorporated
Suite 106
354 Cool Springs Blvd.
Franklin, Tennessee 37067

Re: Community Healthcare Trust Incorporated
Registration Statement on Form S -11
Filed April 2, 2015
  File No. 333 -203210

Dear Mr. Wallace :

We have reviewed 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 bel ieve an amendment is appropriate, please  tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our March 18, 2015 letter .

Distribution Policy, page 57

1. We note your response to comments 5 and 6. Consistent with your response, please revise
to clarify why you have not incl uded the adjustments referenced in those comments and
the reason for the omission.

2. We note your response to comments 5 and 6.   We note that 19 leases are scheduled to
expire in 2016, which represents 26.2% of your revenue.  Please tell us what percentage
of your total annualized lease revenue will expire in each of the quarters in 2016.

3. We note your response to comments 5 and 6 and that based on management’s historical
experience and initial conversations with tenants, you anticipate that most of this space
will be renewed with minimal tenant improvements or leasing commissions.  To the

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 2

 extent that the leases expiring in the next 12 months would have a material impact on
your Estimated Cash Available for Distributions , please  tell us how your assumption  that
most of the leases expiring in the next 12 months will be renewed is consistent with the
3-year historical retention rate  for these properties .  Additionally, to the extent material,
please quantify for us your historical experience with respect to i ncurring tenant
improvements or leasing commission for renewing leases at these properties.  We may
have further comment.

4. We note your response to our comment 5 that existing owners expended only a minimal
amount of capital expenditures during 2014 and th at you expect that the Company will be
responsible for minimal recurring capital expenditures, if any.  Please tell us the amount
of capital expenditures that were incurred during 2014.  Further, please provide us with
the three year historical average of recurring capital expenditures for these properties.
We may have further comment.

5. It appears from the disclosure in the first paragraph on page 58 that the calculation of
estimated CAD includes recurring capital expenditures. Please revise to clarify how  your
calculation reflects those expenditures.

6. Please tell us why you refer to FFO in footnote (1) to the table on page 58 given that it is
not presented in your calculation of estimated CAD.

7. We note your response to comment 7.  Please further revise the line item ‘Estimated cash
available for distribution for the year ended December 31, 201 4’ to refer to it ‘as
adjusted. ’

8. We note your disclosure in footnote (1) on page 58 that states cash available for
distribution is intended to measure a REIT’s cash flow generated by operations and
available to pay dividends.   Please tell us if you intend to present CAD in future
filings.   If so, please note if you view CAD as a liquidity measure, it  should be reconciled
to a co mparable GAAP liquidity measure .  If you do not intend  to present CAD in future
filings, please tell us the purpose of including the discussion of CAD in this footnote.   We
note that estimated CAD for purposes of the Dividend P olicy section indicates that
estimated CAD is not a liquidity measure, but it appears that you view CAD as a liquidity
measure.   Please tell us how you were able to determine that estimated CAD is not a
liquidity measure but CAD is a liquidity measure.

Financial Statem ents

Unaudited Pro Forma Consolidated Financial Statements, page F -3

9. We note your revisions to your Rule 3 -14 financial statements indicate that certain
amounts in rental revenue include operating expense recoveries.  Please revise your P ro

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 3

 Forma Consolidated Statement of Income and your Rule 3 -14 financial statements to
disaggregate rental income and operating expense recoveries.

10. We note your response to comment 19.  As previously requested, please revise to include
a column reflect ing the historical result of operations of the Initial Properties separate
from pro forma adjustments resulting from business combination accounting and other
assumptions.  For example, as indicated in your response to comment 5, renewals and
replacements of leases that expired during the past 12 months have been reflected in the
pro forma calculation; thus, your adjustment (5) for rental income should be
disaggregated based on historical rental income and adjustments to historical rental
income.  Your revi sion to your filing should include your basis for any adjustments to
historical amounts.

11. We note your response to comment 22.  Please tell us how you considered the tenant
improvements, if any, in your allocation of the purchase price.

12. We note your r esponse to comment 23.  Please revise to clarify that you are not giving
effect to the credit facility because you have not received commitments from any lenders
consistent with your response to comment 11 and disclosure on page 68.

13. We note your response to comment 25.  Please expand footnote (7) to disclose the range
of amortization periods  and average amortization period for intangible assets.

14. We note your response to comment 26 and your revision to footnote (8).  We note that
this adjustment gives effect to the expected incremental costs of being a public company,
certain components of the adjustment for general and administrative expenses are based
on estimates and management’s prior experience managing a public REIT, and
anticipated property visit s.  The above items do not appear to be factually supportable.
Accordingly, please revise to exclude the expenses  that are not factually supportable .
However, you may disclose your estimate of the items that are not factually supportable
in a footnote.

Community Healthcare Trust Incorporated Consolidated Financial Statements

Notes to Consolidated Financial Statements

Purchase of Investment Properties, page F -16

15. We note your response to comment 27 and your revision to Note 3 on page F -17. Please
revise to clarify how you determine if the intangible should include any fixed rate
renewal options.

16. We note your response to comment 29. We await the inclusion of audited Regulation S -X
Rule 3 -14 financial statements for Provena  Medical Center for the three months ended

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 4

 March 31, 2015 in your next amendment to the registration statement. We refer you to
the letter of the Division of Corporation Finance, Chief Accountant’s Office, dated March
31, 2015 in response to your Rule 3 -14 waiver request.

Exhibits

17. We note that you have entered into purchase agreements to acquire the Initial Portfolio.
Please include these agreements as exhibits to the registration statement or tell us why
you believe they are not required.

We urge a ll persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its manag ement are in
possession of all facts relating to a company’s disclosure, 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 regist ration statement , please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any act ion 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 and 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 requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respe ctive responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any  amendment prior to the requested effective date of the
registration statement.

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 5

 You may contact Jorge Bonilla, Staff Accountant,  at (202) 551 -3414 or Jennifer Monick,
Senior Staff Accountant,  at (202) 551 -3295 if you have questions regarding comments on  the
financial statements and related matters.  Please contact Rahul Patel, Staff Attorney,  at (202)
551-3799 or me at (202) 551 -3655 with any other questions.

Sincerely,

 /s/ Sonia Gupta Barros

 Sonia Gupta Barros
Assistant Director

cc: Tonya Mitchem Grindon, Esq.