SecProbe.io

February 27, 2020
Daniel Miller
Chief Executive Officer
Steward Realty Trust, Inc.
9679 Myrtle Grove Lane
Easton, MD 21601
Re:Steward Realty Trust, Inc.
Post Qualification Amendment to Offering Statement on Form 1-A
Filed February 14, 2020
File No. 024-10925
Dear Mr. Miller:
            We have reviewed your amendment 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 offering statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Offering Statement on Form 1-A
General
1.It appears that the Form 1-K filed on June 12, 2019 is missing multiple material items of
that form and includes only the financial statements.  Please amend your Form 1-K to
include all items required by the Form.  Tell us how you determined you are eligible to
sell securities pursuant to Regulation A given the requirements of Rule 251(d)(3)(i)(F)
that you are current in your annual and semiannual filings pursuant to Rule 257(b), at the
time of such sale.  Please confirm it true that you have not issued any shares of Class A
common stock pursuant to Regulation A, or advise.
2.Please ensure the disclosure in your offering statement is current.  We note references on
the cover page to it being dated March 15, 2019 and for the period ended December 31,
2018.  Also, include complete Part III information including signatures.

 FirstName LastNameDaniel Miller
 Comapany NameSteward Realty Trust, Inc.
 February 27, 2020 Page 2
 FirstName LastName
Daniel Miller
Steward Realty Trust, Inc.
February 27, 2020
Page 2
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Ruairi Regan at 202-551-3269 or Pam Howell at 202-551-3357 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       David McElroy, Esq.