SecProbe.io

United States securities and exchange commission logo
October 14, 2020
Mostafa Nagaty
Chief Financial Officer
KKR Real Estate Finance Trust Inc.
9 West 57th Street, Suite 4200
New York, NY 10019
Re:KKR Real Estate Finance Trust Inc.
Form 10-K for the year ended December 31, 2019
Form 10-Q for the quarterly period ended March 31, 2020
Form 10-Q for the quarterly period ended June 30, 2020
File No. 001-38082
Dear Mr. Nagaty:
            We have reviewed your September 23, 2020 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
September 10, 2020 letter.
Form 10-Q for the quarterly period ended March 31, 2020
Item 2. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Core Earnings , page 46
1.We have considered your response to comment 1 in our letter dated July 20, 2020. We
continue to believe that your presentation of Core Earnings, which excludes the unrealized
portion of the provision for credit losses, appears to substitute individually tailored
recognition and measurement methods for those of GAAP and could violate Rule 100(b)
of Regulation G, as discussed in Question 100.04 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations. Please refrain from disclosing this
performance measure, or any other performance measures that exclude the provision for

 FirstName LastNameMostafa Nagaty
 Comapany NameKKR Real Estate Finance Trust Inc.
 October 14, 2020 Page 2
 FirstName LastName
Mostafa Nagaty
KKR Real Estate Finance Trust Inc.
October 14, 2020
Page 2
credit losses, or portions of the provision for credit losses, in future filings.
            You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or Shannon
Menjivar, Accounting Branch Chief, at (202) 551-3856 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction