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June 25, 2024
Jilliene Helman
Chief Executive Officer
RealtyMogul Apartment Growth REIT, Inc.
10573 W. Pico Blvd, PMB #603
Los Angeles, CA 90064
Re:RealtyMogul Apartment Growth REIT, Inc.
Amendment No. 1 to Offering Statement on Form 1-A
Response dated June 7, 2024
File No. 024-12375
Dear Jilliene Helman:
            We have reviewed your response and have the following comments.
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 offering statement and the information you
provide in response to this letter, we may have additional comments.
Correspondence submitted June 7, 2024
General
1.We note your distribution reinvestment plan. Please update your cover page to provide an
allocation of the securities being offered pursuant to the distribution reinvestment plan. In
addition, please revise to clarify how your activities will be done in compliance with
Regulation A; for example, please ensure that your analysis and disclosure reflects: (i)
confirmation that the distribution reinvestment plan securities are being offering pursuant
to Rule 251(d)(3)(i)(B); (ii) confirmation that you will provide investors with a hyperlink
to the current offering circular in connection with and at the time of any distribution
reinvestment (refer to Rule 251(d)(1)(iii)); (iii) how you will comply with the investment
limitations and qualifications for purchaser status set forth in Rule 251(d)(2)(i)(C) with
respect to any securities purchased through your distribution reinvestment plan; and (iv)
how you will ensure you are eligible to offer and sell securities pursuant to Regulation A
at the time of such sales.

 FirstName LastNameJilliene  Helman
 Comapany NameRealtyMogul Apartment Growth REIT, Inc.
 June 25, 2024 Page 2
 FirstName LastName
Jilliene  Helman
RealtyMogul Apartment Growth REIT, Inc.
June 25, 2024
Page 2

2.You propose to offer your existing investors the opportunity to purchase additional shares
in your offering at regular intervals by participating in your “automatic investment
program.”  Please revise to clarify how your activities will be done in compliance with
Regulation A; for example, please ensure that your analysis and disclosure reflects: (i) that
you will obtain the affirmative consent from each holder prior to any and each share
purchase made through your “automatic investment program”; (ii) confirmation that you
will provide investors with a hyperlink to the current offering circular in connection with
and at the time of any such additional monthly investment (refer to Rule 251(d)(1)(iii));
(iii) how you will comply with the investment limitations and qualifications for purchaser
status set forth in Rule 251(d)(2)(i)(C) with respect to any share purchases made through
your “automatic investment program”; and (iv) how you will ensure you are eligible to
offer and sell securities pursuant to Regulation A at the time of such sales.
            Please contact Ameen Hamady at 202-551-3891 or Isaac Esquivel at 202-551-3395 if you
have questions regarding comments on the financial statements and related matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Lauren Prevost