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April 22, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attn: Raymond Be, Attorney-Adviser

 Re: Cantor Fitzgerald Sustainable Infrastructure Fund

Registration Statement on Form N-2

File Nos. 333-262031, 811-23773

Ladies and Gentlemen:

On behalf of Cantor Fitzgerald Sustainable Infrastructure
Fund (the “Registrant” or the “Fund”), we hereby file with the staff (the “Staff”) of the Division
of Investment Management of the Securities and Exchange Commission (the “Commission”) Amendment No. 1 (“Amendment
No. 1”) to the above-referenced registration statement on Form N-2 (the “Registration Statement”). Amendment
No. 1 includes revisions to the Registration Statement in response to the Staff’s comments in its letter dated February 7,
2022 relating to the Registration Statement (the “Comment Letter”) and to otherwise update disclosure.

In addition, we are providing the following responses
to the Comment Letter. To assist your review, we have retyped the text of the Staff’s comment in italics below. Page references
in the responses correspond to the pages of Amendment No. 1. All capitalized terms used but not defined in this letter have the meanings
given to them in Amendment No. 1. The responses and information described below are based upon information provided to us by the
Fund.

General

 1. We note that portions of the filing, including the Fund’s financial statements, are incomplete.
We may have additional comments on such portions when you complete them in a pre-effective amendment, on disclosures made in response
to this letter, on information supplied supplementally, or on exhibits added in any amendments.

Any incomplete portions of the Registration
Statement will be completed in a subsequent pre-effective amendment to the Registration Statement.

Greenberg
Traurig, LLP n Attorneys
at Law n WWW.GTLAW.COM

2200 Ross Avenue, Suite 5200 n
Dallas, TX n
Tel 214.665.3685

 2. Please supplementally explain if you have received exemptive relief or submitted, or expect to submit,
any exemptive application or no-action request in connection with the registration statement, including with respect to transactions with
certain affiliates.

The Registrant anticipates filing an exemptive
application in order to seek an order from the Commission (i) pursuant to Section 6(c) of the Investment Company Act of 1940, as amended
(the “1940 Act”) for an exemption from Sections 18(a)(2), 18(c) and 18(i) of the 1940 Act; (ii) pursuant to Sections 6(c)
and 23(c) of the 1940 Act for an exemption from Rule 23c-3 under the 1940 Act and (iii) pursuant to Section 17(d) of the 1940 Act and
Rule 17d-1 under the 1940 Act to permit the Registrant to issue multiple classes of shares and to impose early withdrawal charges and
asset-based distribution and/or service fees with respect to certain classes

 3. Please confirm in your response letter that FINRA
has reviewed the proposed distribution arrangements for the offering described in the registration statement and that FINRA has issued
a statement expressing no objections to the distribution arrangements.

The Registrant intends to operate as an “interval
fund” pursuant to Rule 23c-3 under the 1940 Act. As such, the Registrant will rely on FINRA Rule 5110(h)(2) which exempts

securities of any "closed-end" investment
company as defined in Section 5(a)(2) of the . . . [1940 Act] that makes periodic repurchase offers pursuant to Rule 23c-3(b) under the
. . . [1940 Act] and offers its shares on a continuous basis pursuant to Rule 415(a)(1)(xi) of SEC Regulation C . . .

from the requirements of FINRA Rules 2310, 5110
and 5121. Thus, the Registrant does not intend to have FINRA review the proposed distribution arrangements that are described in the registration
statement.

 4. The Fund’s name includes the word “Sustainable”.
We believe this word suggests a type of investment and, therefore, the Fund should include an 80% names rule policy that covers sustainable
infrastructure investments. Please revise the strategy section accordingly.

The Registrant has revised the 80% policy to cover
sustainable infrastructure investments and clarified the strategy section of the prospectus to reflect the integration of sustainability
considerations into the investment selection process. Please refer to comments 12 and 13, below for a discussion of how the Sub-Adviser
determines “sustainability” with respect to individual investments.

 5. On page 5, you highlight that many of the investments
you seek to make “are intended for large, institutional investors and have a large minimum investment size and other investor criteria
that might otherwise limit their availability to individual, non-institutional investors.” You are conducting a best-efforts offering
to retail investors and the total proceeds available to the Fund for investment are uncertain. Please clarify, and where appropriate qualify,
how you intend to obtain access to these private investment funds given your size and the nature of your investor base.

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The disclosure is intended to highlight that many
of the Private Investment Funds targeted by the Registrant typically are available only to “qualified purchasers” as such
term is defined in Section 2(a)(51) of the 1940 Act. As such, access to such funds is limited to the majority of retail investors. However,
once the Registrant reaches $25 million in assets, the Registrant will satisfy the definition of a qualified purchaser for purposes of
the 1940 Act. As the disclosure in the prospectus highlights, during the early stages of the lifecycle of the Registrant, the investment
portfolio largely will consist of publicly traded securities. Over time, as the Registrant gathers sufficient assets, the investment portfolio
of the Registrant will shift such that, under normal market conditions, 70% of the assets of the Registrant will be allocated to various
Private Investment Funds.

Prospectus

Cover Page

 6. Please revise the “Interval Fund/Repurchase
Offers” section to provide information consistent with Guide 10 to Form N-2. In particular, Guide 10 states that in response to
Item 1.1.b, the prospectus cover page should specify the intervals between deadlines for repurchase requests, pricing, and repayment and,
if applicable, the anticipated timing of the registrant’s initial repurchase offer (which, under Rule 23c-3, must occur no later
than two periodic intervals after the effective date of the registration statement). The Guide further states that this disclosure should
include a cross-reference to the sections of the prospectus that discuss the risks relating the Fund’s repurchase policies.

The disclosure has been updated to reflect the
guidance of Guide 10 to Form N-2.

Investment Objective and Policies (page 1)

 7. The disclosure states that the Fund will invest
between 50% and 95% of its assets in Private Investment Funds. With an eye to clarifying this disclosure, supplementally explain what
types of funds these are, including any securities law exemptions upon which they are relying to remain unregistered under the Investment
Company Act. Please note that registered closed-end funds that invest more than 15% of their net assets in certain types of private funds
should impose a minimum initial investment requirement of at least $25,000 and restrict sales to investors that, at a minimum, satisfy
the accredited investor standard. Please explain to us why it is/would be appropriate for the Fund to offer shares without imposing these
limitations. We may have additional comments after reviewing your response.

Given the nature of the Private Investment Funds
in which the Registrant will seek to invest, the Registrant does not believe it is appropriate or in the best interests of investors for
the Staff to impose the limitations described above. While the Private Investment Funds in which the Registrant will invest likely will
encompass a mixture of funds that are excluded from the definition of an “investment company” for purposes of the 1940 Act
under either Section 3(c)(5)(C) of the 1940 Act or Section 3(c)(7) under the 1940 Act, the

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nature of the investment portfolio, risk
and expense profile of each Private Investment Fund largely will be consistent with that of a private Real Estate Investment Trust (each,
a “REIT”)[1] and in any event will not
include funds that: engage in hedging related strategies, have significant exposure to commodities or derivatives, impose performance
fees on unrealized gains, or employ a significant amount of leverage. Like most private REITs, the assets held by the various Private
Investment Funds largely will be interests in real property or interests in improvements on real property, including, but not limited
to, toll-roads, airports and seaports. Indeed, the investment portfolio of the Registrant will be substantially similar to other closed-end
registered investment companies that are offered to retail investors without regard to whether or not such investors satisfy the definition
of an “accredited investor” under Regulation D. Indeed, the Registrant would note that several such closed-end registered investment companies have allocated the bulk of their investment
portfolios to private REITs, including one fund that has allocated more than 90% of its assets to private REITs without being limited
to accredited investors. Imposing such a limitation on the Registrant would significantly disadvantage
the Registrant relative to competing funds without a substantive difference between the investment portfolio of the Registrant and its
competitors.

Like investments held by private REITs, the investments
held by the Private Investment Funds in which the Registrant will invest are long-duration investments. Indeed, the risk-return profile
for infrastructure investments looks more like the spectrum of risks and returns applied to most institutional real estate portfolios.
Many of the Private Investment Funds in which the Registrant will invest have a return profile akin to a long-term bond, with an immediate
and sustainable current coupon and a term of 15 to 30 years or more, with much of the overall return driven by current income which is
indistinguishable from the return profile of a core real estate investment.

In addition, the fee structure of the open-end
Private Investment Funds in which the Registrant will invest is in line with the fee structure of similar open-end private REITs. According
to a study conducted by Probitas Partners, the overwhelming majority of open-end private infrastructure funds (94% of the funds included
in the study) have management fees of less than 1.25% of net asset value and the majority of such funds (58% of the included funds) have
a management fee of less than 1.00% of net asset value.[2] By comparison, the majority
of private REITs charge management fees between 0.5% and 1.5%. In addition, 80% of the open-end infrastructure funds included in the Probitas
Survey impose a carried interest calculation of less than 15% which largely is consistent with the fee charged by private REITs.[3]

The Registrant notes that the Private Investment
Funds in which it will invest will be managed by leading, institutional infrastructure managers. By investing in the Private Investment
Funds offered by multiple managers, the Registrant will benefit from building an investment portfolio that is diversified with respect
to individual infrastructure projects, as well as with respect to geography.

[1]
A private REIT refers to a privately offered investment fund that seeks to invest in real estate assets and which is excluded from the
definition of an investment company pursuant to either section 3(c)(5)(C) or 3(c)(7) of the 1940 Act, but which is treated as a REIT for
purposes of Subchapter M of the Internal Revenue code, and which are targeted to institutional investors, including endowments and corporate
pension funds.

[2]
Probitas Partners’ Infrastructure Institutional Investor Trends: 2019, pg. 16 (2019) (“Probitas Survey”).

[3]
Probitas Survey at 17.

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The
operation of the Private Investment Funds is consistent with that of other institutional oriented funds. In particular, the Private Investment
Funds all will provide the Registrant, the Adviser and the Sub-Adviser with annual audited financials, quarterly unaudited financials,
quarterly investment account statements, detailed information about each asset held (including valuations) and the leverage and liabilities
of the Investment Fund. Furthermore, the quarterly net asset value calculated by each Private Investment Fund will be calculated in accordance
with the guidelines of FASB ASC 946, Financial Services —
Investment Companies (“Topic 946”) which sets forth the same valuation
processes employed by registered investment companies.

 8. With respect to the Fund’s investments in
such Private Investment Funds, supplementally

advise if the Fund anticipates acquiring a
control position over any such private funds and any regulatory implications that may result from such acquisition.

The Registrant does not anticipate ever acquiring
a control position with respect to any Private Investment Fund. Indeed, the Registrant will seek to structure each investment in a Private
Investment Fund specifically to avoid being deemed to “control” any such Private Investment Fund as contemplated by the 1940
Act.

 9. The disclosure beginning with the second paragraph
starting with “The Fund pursues its

investment objective by strategically investing”
appears to be a discussion of the Fund’s strategy. On page 2, there is a separate section captioned “Investment Strategy.”
Consider consolidating the disclosure of the Fund’s investment strategy.

The Registrant has streamlined and consolidated
the disclosure as requested on page 1 of Amendment No. 1.

 10. We note your definition of an infrastructure company
includes companies who provide services to companies engaged in such activities. Please explain to us what sorts of companies are contemplated
by this disclosure and why you believe it is appropriate to categorize them as infrastructure companies.

The Registrant defines “infrastructure”
as the essential facilities and services upon which the economic productivity of society depends. Infrastructure companies are typically
involved in water, energy, social services and the movement of goods and can include:  regulated assets, including electricity transmission
lines, gas and oil pipelines; water distribution systems, and wastewater collection and processing systems;  transportation assets,
including toll roads, bridges, tunnels, railroads, rapid transit links, seaports, and airports; communications assets, including radio
and television broadcast towers, wireless communications towers, cable systems, and satellite networks; and social infrastructure assets,
including schools, hospitals, prisons, and courthouses. Thus, the Registrant views an operating company that derives at least 50% of their
revenues, operating income, or assets from infrastructure business activities to be infrastructure related and within the universe of
investments contemplated by the investment strategy of the Registrant.

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Examples of infrastructure related companies include,
but are not limited to:

 · Data Center Companies: Companies that
own, operate, and/or develop data centers, which own and manage facilities that customers use to safely and efficiently store computer
servers and data;

 · Cellular Tower Companies: Companies that
own, operate and/or develop cellular towers that lease antennae and equipment space on cellular towers to wireless carriers; and

 · Digital Infrastructure Hardware Companies:
Companies that manufacture, design, and/or assemble the servers and/or other hardware often used in data centers and cellular towers,
including data center servers, proce