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 Document 590 Madison Avenue, 33rd Floor New York, NY 10022 212-287-2119 July 31, 2025 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, NE Washington, D.C. 20549 Attention: Ameen Hamady and Isaac Esquivel Re: BrightSpire Capital, Inc. Form 10-K for the year ended December 31, 2024 File No. 001-38377 Dear Mr. Hamady and Mr. Esquivel:     This letter sets forth the response of BrightSpire Capital, Inc. (the “Company”) to the comment from the staff (the “Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”) in a letter dated July 18, 2025 (the “Comment Letter”) regarding the above referenced filings. For ease of review, the Company has set forth below in bold type the numbered comment of the Staff in the Comment Letter, with the Company’s response thereto immediately following the comment. Form 10-K for year ended December 31, 2024 Non-GAAP Supplemental Financial Measures Undepreciated Book Value Per Share, page 60 1. We note your presentation of undepreciated book value and undepreciated book value per share as non-GAAP financial measures. In regard to your presentation please address the following • Revise your disclosure regarding the definition of undepreciated book value as it does not appear to address all the items that are being adjusted from the most directly comparable GAAP measure, which appears to be stockholders’ equity excluding noncontrolling interests in investment entities. Specifically, July 31, 2025 Page 2 your definition does not appear to discuss non-GAAP impairment of real estate as an adjustment; and • Expand your disclosure to indicate that the non-GAAP impairment adjustment is itself a non-GAAP financial measure, provide a reconciliation to its most directly comparable GAAP measure and expand your disclosure to discuss the usefulness of such measure. Refer to Item 10(e) of Regulation S-K . Response to Comment No. 1 :     In the Company’s future filings, the Company will enhance its disclosures regarding undepreciated book value and undepreciated book value per share (with additions underlined and deletions indicated by strikethroughs in the paragraph below) and to include a reconciliation of non-GAAP impairment of real estate as follows:      Undepreciated Book Value Per Share We believe that presenting undepreciated book value per share is a more useful and consistent measure of the value of our current portfolio and operations for our investors as it . It additionally enhances the comparability to our peers who do not hold similar real estate investments. Undepreciated book value per share excludes our share of accumulated depreciation and amortization on real estate investments (including related intangible assets and liabilities) and as of the quarter ended June 30, 2024, includes non-GAAP impairment of real estate and any related foreign currency translation. Non-GAAP impairment of real estate and foreign currency translation excludes is a non-GAAP measure that reflects our share of a property’s the carrying value (including any related foreign currency translation) on certain net leased and other real estate office properties whose non-recourse mortgages have matured mature within 12 months or who have been placed in a cash flow sweep by their lender. Our ability to refinance at their maturity dates is burdened by the current interest rate environment, lenders’ aversion to finance or refinance office properties and/or associated improvements or paydowns potentially demanded at such properties. Loan maturity defaults can and have led lead to foreclosures. Cash flow sweeps restrict our ability to utilize earnings generated by a property. Given this potential likelihood As such , we believe it is prudent to recognize impairments and exclude our share of the carrying value related to these properties. The following table calculates our GAAP book value per share and undepreciated book value per share ($ in thousands, except per share data): June 30, 2025 December 31, 2024 Stockholders’ equity excluding noncontrolling interests in investment entities XX XX Accumulated depreciation and amortization XX XX Non-GAAP impairment of real estate XX XX Foreign currency translation XX XX Undepreciated book value XX XX July 31, 2025 Page 3 June 30, 2025 December 31, 2024 GAAP book value per share XX XX Accumulated depreciation and amortization per share XX XX Non-GAAP impairment of real estate XX XX Foreign currency translation XX XX Undepreciated book value per share XX XX Total outstanding shares - Class A common stock XX XX June 30, 2025 December 31, 2024 Impairment attributable to BrightSpire Capital, Inc. XX XX Adjustments: Current year non-GAAP impairment of operating real estate XX XX Non-GAAP impairment as of prior fiscal year-end XX XX Impairment attributable to BrightSpire Capital, Inc. (XX) (XX)     Non-GAAP impairment of real estate XX XX * * * * *          The Company acknowledges that it is responsible for the accuracy and adequacy of the disclosure in its filings, notwithstanding any review, comments, action or absence of action by the Staff.         Should the Staff have any questions or comments, or would like additional information, please do not hesitate to contact me at (212) 287-2119.      Very truly yours, BrightSpire Capital, Inc. By: /s/ Frank V. Saracino Name: Frank V. Saracino Title: Chief Financial Officer July 31, 2025 Page 4 cc: David Palamé BrightSpire Capital, Inc. David W. Bonser Tifarah R. Allen Hogan Lovells US LLP Eric Rubin Rivi Harari Deloitte & Touche LLP Tom Beversluis Andrew Harvazinski Ernst & Young LLP