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Stone Ridge Residential Real Estate Income Fund I, Inc.

 ROPES & GRAY LLP

 PRUDENTIAL TOWER

800 BOYLSTON STREET

BOSTON, MA 02199-3600

WWW.ROPESGRAY.COM

 October 18, 2019

BY EDGAR

 Robert Schmidt

 T +1 617 951 7831

F +1 617 235 9425

 robert.schmidt@ropesgray.com

 United States Securities & Exchange Commission

Division of Investment Management

 100 F Street, NE

Washington, DC 20549

 Attention: Karen Rossotto

Re:
 Stone Ridge Residential Real Estate Income Fund I, Inc. (the “Fund”)

File Numbers: 333-232263; 811-23451

 Dear
Ms. Rossotto:

 On behalf of the Fund, we are transmitting for filing or will hereafter transmit for filing under the Securities Act
of 1933, as amended (the “1933 Act”), and the Investment Company Act of 1940, as amended (the “1940 Act”), Pre-Effective Amendment No. 2 (“Amendment No. 2”) under the 1933 Act to the Registration Statement on
Form N-2, initially filed with the Securities and Exchange Commission (the “SEC”) on June 21, 2019 (the “Registration Statement”) and previously amended by Pre-Effective Amendment No. 1 (“Amendment No. 1),
filed on August 8, 2019.

 Amendment No. 2 reflects changes made in response to comments of the SEC’s staff (the
“Staff”) on the Registration Statement that were provided on October 2, 2019. For the convenience of the Staff, these comments have been restated below in their entirety. The Fund’s response follows each comment. Reference is
also made to the Fund’s responses to the Staff’s comments on Amendment No. 1, made in a letter to the Staff dated August 8, 2019 (the “August 8 Letter”). References in the responses to the Fund’s prospectus or
statement of additional information are to those filed as part of Amendment No. 2. In addition to revisions made in response to Staff comments, certain other changes have been made in Amendment No. 2. Capitalized terms used but not defined
herein have the meanings assigned to them in Amendment No. 2.

 This letter omits confidential information for which we seek
confidential treatment under the Freedom of Information Act. The portion of this letter for which confidential treatment is sought is marked as [Redacted - Confidential Treatment Requested]. A separate unredacted version of this letter has been
delivered to the Staff.

 August 8 Letter Responses

1.
 Staff Comment: The Staff has a number of comments related to the Fund’s response to comment 3:

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Karen Rossotto, Esq.

October 18, 2019

 THIS CORRESPONDENCE HAS BEEN REDACTED AND IS

THE SUBJECT OF A CONFIDENTIAL TREATMENT REQUEST

a.
 The response includes the following: “A substantial portion of the Fund’s investments will
consist of interests in private investment vehicles that will invest in single family rental properties.” The Staff believes the prospectus reads as though the Fund will primarily hold direct interests in single family properties. How
will the Fund’s investments be allocated between investments in rental properties through private vehicles and direct investments in such properties?

Response: The Fund’s investments will consist primarily of interests in private investment vehicles that provide
exposure to single family rental properties, rather than direct investments in such properties. The Fund has extensively revised its strategy disclosure to clarify this point. Please see Appendix A, which includes a version of the Fund’s
summary strategy disclosure marked against the disclosure as included in Amendment No. 1.

 At least 40% of the
Fund’s portfolio will consist of assets that qualify as “investment securities” within the meaning of Section 3(a)(1)(C) under the 1940 Act. As discussed in detail in the Fund’s response to comment 3 in the August 8
Letter and in its response to comment 1.h below, the Fund considers its interests in private investment vehicles to be “investment securities” when it has a passive interest in such vehicles and such vehicles are not majority-owned
subsidiaries. [Redacted - Confidential Treatment Requested] The Fund does not consider directly held interests in properties to be “investment securities.” Accordingly, the Fund cannot invest more than 60% of its portfolio in direct
interests in properties or any other assets that would not constitute “investment securities” (considered in the aggregate). The Fund notes that its existing disclosure includes a statement to this effect. Please see Appendix A.

 While the Fund retains the flexibility to make direct investments in properties up to the maximum amount that would be
consistent with its “investment company” status, the Fund supplementally notes that it does not expect that its portfolio will initially contain any direct investments in properties.

b.
 The Fund states that it will invest in entities organized as “partnerships, limited liability companies
or as similar business entities.” Please clarify what these similar business entities are.

Response: The Fund intended the phrase “similar business entities” to be a catch-all to include any types of
business organizations not specifically enumerated. The Fund expects that the private investment vehicles in which it invests will typically be

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THE SUBJECT OF A CONFIDENTIAL TREATMENT REQUEST

partnerships or limited liability companies. The Fund has included a sentence to this effect in its strategy disclosure.

c.
 The Fund discusses the percentage ownership the Fund will have in private investment vehicles and the nature
of that ownership. For each private investment vehicle, what level of economic ownership and what level of control will there be?

Response: [Redacted - Confidential Treatment Requested] Subject to this constraint, the Fund has the flexibility to
invest in private investment vehicles with any level of voting control or economic ownership.

 With respect to each
private investment vehicle in which the Fund invests, the applicable real estate operator or its affiliate will act as the general partner or managing member and manage the day-to-day operations of such vehicle (e.g., locating and acquiring
properties, conducting renovations, managing the rental relationship, selling properties when appropriate and managing the books and records of the entity). The real estate operator will also hold equity in each vehicle. The Fund will generally have
the right, alongside other equity holders in the vehicle, if any, to approve extraordinary actions (e.g., mergers, liquidations, or extensions of terms) to be taken by the company and may have approval rights with respect to certain other
matters depending on the investment vehicle.

d.
 The Fund states that it expects to be a “passive investor with respect to a substantial portion
of” the interests that it holds. Will the Fund invest in any private investment vehicles where it is active in management? What proportion of the Fund’s assets will consist of such interests? Will these interests be
treated as investment securities for purposes of the Fund’s 3(a)(1)(C) analysis?

 Response:
As described above, with respect to each private investment vehicle in which the Fund invests, the applicable real estate operator or its affiliate will act as the general partner or managing member and manage the day-to-day operations of such
vehicle. The Fund will not be active in managing the day-to-day affairs of such vehicle.

e.
 The Fund states that “the Commission has indicated that interests in limited partnerships formed for
purposes of investing in real estate may not be securities within the meaning of Section 3(a)(1)(C) . . . [when the issuer] owns more than 50% of the limited partnership interests in all the limited partnerships in which it
invests.”

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Karen Rossotto, Esq.

October 18, 2019

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THE SUBJECT OF A CONFIDENTIAL TREATMENT REQUEST

How does the Fund interpret this? Is it on a company-by-company basis, or as a totality, across all the LP interests that the Fund owns?

Response: The Fund interprets this test to apply with respect to voting interests and on a company-by-company basis.

f.
 With respect to partnership interests, the Fund states that it “will not have the ability to replace
the general partners in all cases.” Does the Fund intend to invest in any LPs in which it would have the authority to dismiss the general partner?

Response: [Redacted - Confidential Treatment Requested]

g.
 The Fund states that its directly held investments in non-subsidiary partnerships and limited liability
companies “will not generally constitute investments in ‘majority-owned subsidiaries.’” Please explain what “generally” means in this context. If these investments will never be “majority-owned
subsidiaries” (or if this will primarily be the case), please revise to clarify that.

Response: As noted above, at least 40% of the Fund’s portfolio will consist of assets that qualify as
“investment securities” within the meaning of Section 3(a)(1)(C) under the 1940 Act. The Fund is aware that “majority-owned subsidiaries,” within the meaning of the 1940 Act, are not “investment securities” and the
Fund, although it may have such subsidiaries, will not count them towards the 40% threshold.

h.
 The Fund states that though it “may own more than 50% of the economic interests in an investment
vehicle, the Fund will, as noted above, waive its voting rights or other formal control privileges with respect to such vehicles to the extent necessary to preserve its investment company status.” What authority are you using to determine
that, if the Fund waives its rights and formal control privileges, the investment can count as an investment security for purposes of 3(a)(1)(C)? Please revise your analysis here to make it clearer for the Staff.

Response: [Redacted - Confidential Treatment Requested]

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Karen Rossotto, Esq.

October 18, 2019

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THE SUBJECT OF A CONFIDENTIAL TREATMENT REQUEST

Therefore, the conclusion referenced in the Staff’s comment is not essential to the Fund’s status as an investment company. However, the Fund does believe that, in instances where it
owns greater than 50% of the economic interests in a private investment vehicle but waives its voting rights permanently, the Fund’s interest in such private investment vehicle does constitute an “investment security” for purposes of
Section 3(a)(1)(C) under the 1940 Act. The key authorities supporting the point that such interest are “securities” within the meaning of the 1940 Act are those set forth in the Fund’s response to comment 3 in the August 8
Letter, namely: Williamson v. Tucker, 645 F.2d 404, 424 (5th Cir. 1981); Mayer v. Oil Field Systems Corp., 721 F.2d 59, 65 (2d. Cir. 1983) (finding that a limited partnership interest “generally is a security because such an interest involves
investment ‘in a common enterprise with profits to come solely from the efforts of others”); and SEC Investment Co. Act Release No. IC-8456 (Aug. 9, 1974). The below analysis supplements the Fund’s response to comment 3 in the
August 8 Letter. (As explained in the August 8 Letter, the Fund’s interests in private investment vehicles where it permanently waives voting rights would not constitute majority-owned subsidiaries for purposes of
Section 3(a)(1)(C). Therefore, such interest are “investment securities” if they are “securities.”)

Extensive case law supports the principle that partnership interests are securities when the interest holder lacks
meaningful, hands-on control of an underlying entity. In determining whether an interest constitutes a security, courts have long focused on substance over form, placing an emphasis on economic reality. SEC v. W. J. Howey Co., 328 U.S. 293, 299
(1946). Building on the third factor in the Howey test, courts have applied the Williamson factors to determine whether a general partnership interest constitutes a security. Williamson v. Tucker, 645 F.2d 404, 423 (5th Cir. 1981).
Under the Williamson test, a partnership interest (in this case, a general partnership interest) would qualify as an investment contract under any one of the following situations: “(1) an agreement among the parties leaves so little
power in the hands of the partner or venturer that the arrangement in fact distributes power as would a limited partnership; or (2) the partner or venturer is so inexperienced and unknowledgeable in business affairs that he is incapable of
intelligently exercising his partnership or venture powers; or (3) the partner or venturer is so dependent on some unique entrepreneurial or managerial ability of the promoter or manager that he cannot replace the manager of the enterprise or
otherwise exercise meaningful partnership or venture powers.” Williamson, 645 F.2d at 424. The Fund’s interests in private investment vehicles (even when the Fund owns greater than 50% economic interest) would satisfy either the first or
third prongs of the Williamson test, as the Fund will exercise no day-to-day management authority with respect to such vehicle and will be reliant on the unique expertise of the real estate operator to acquire and manage individual
properties. See also SEC v. Friendly Power

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Company, 49 F.Supp.2d 1363, 1369 (S.D.Fla. 1999) (finding a general partnership interest to be a security when general partners outsourced their management responsibilities); Cohen v. Goodfriend,
642 F. Supp. 95, 99 (E.D.N.Y. 1986) (finding a general partnership interest to be a security where the general partner believed that he had been sold a limited partnership interest); SEC v. Merchant Capital LLC, 483 F.3d 747, 757 (11th Cir. 2007)
(citing Albanese v. Fla. Nat’l Bank, 823 F.2d 408, 412 (11th Cir. 1987)) (finding a limited partnership interest to be a security “where removal of the general partner is only for cause, and investors have no other ability to impact
management, the interest is an investment contract as a matter of law.”); Merchant, 483 F.3d at 760-61 (finding that an investment security existed when the powers of partners in a registered limited liability partnership to remove or control
the manager were illusory due to a lack of information or ballot restrictions, even if they had formal voting privileges).

The Fund submits that its lack of voting and control rights would force it to rely on the general partner, supporting a
finding that an investment security exists under Section 3(a)(1)(C).

i.
 In the final paragraph of the response, the Fund argues that it would also be considered an investment
company on the basis of Section 3(a)(1)(A) of the 1940 Act on the ground that it “will hold itself out as being engaged primarily ‘in the business of investing, reinvesting, or trading in securities.’” The Staff
believes that this line of reasoning does not work based on the current prospectus disclosure. As drafted, the prospectus suggests that the Fund will invest primarily in single family properties, which are not securities.

Response: The Fund has extensively revised its strategy disclosure to clarify that its investments will consist
primarily of interests in vehicles that provide exposure to single family rental properties, rather than direct investments in such properties. As described in the foregoing responses, the Fund’s interests in private investment vehicles will
predominately constitute “investment securities” within the meaning of Section 3(a)(1)(C), which are necessarily “securities” for purposes of Section 3(a)(1)(A). Please see Appendix A.

2.
 Staff Comment: In the Fund’s response to comment 7, the Fund states that it “retains the
flexibility to adjust the strategies of Subsequent Funds based on market conditions or other considerations.” Please ensure that this concept is disclosed in the Regis