SecProbe.io

January 14, 2020
Brian Mitts
President
NexPoint Real Estate Finance, Inc.
300 Crescent Court
Suite 700
Dallas, Texas 75201
Re:NexPoint Real Estate Finance, Inc.
Registration Statement on Form S-11
Filed December 24, 2019
File No. 333-235698
Dear Mr. Mitts:
            We have reviewed your registration statement and have the following comment.  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 registration statement and providing the
requested information.  If you do not believe our 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 registration statement and the information you
provide in response to this comment, we may have additional comments.
Registration Statement Filed on Form S-11
Unaudited Pro Forma Consolidated Financial Statement Information
4. Pro Forma Adjustments, page F-18
1.We note from your disclosure in notes (b) through (f) that balances reflected in the
columns of your unaudited pro forma consolidated balance sheet as of September 30,
2019 for SFR Loans, CMBS B-Pieces, Mezzanine Loan, Preferred Equity and Alternative
Structured Financing Investment ("ASFI") represent "the contribution and subsequent
results" of the respective assets and liabilities upon the completion of the Formation
Transaction. Additionally, we note from note (b) that cash attributable to the SFR Loans

 FirstName LastNameBrian Mitts
 Comapany NameNexPoint Real Estate Finance, Inc.
 January 14, 2020 Page 2
 FirstName LastName
Brian Mitts
NexPoint Real Estate Finance, Inc.
January 14, 2020
Page 2

consists of monthly payments of interest and principal less interest expense and servicing
fees. Please clarify for us what is meant by "subsequent results" and whether or not results
of operations subsequent to the Formation Transaction are reflected in any balance sheet
line item of your pro forma balance sheet.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Isaac Esquivel at 202-551-3395 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Ronald (Ron) Alper at 202-551-3329 or Jennifer Gowetski at 202-551-3401 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Charles T. Haag