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VIA EDGAR and FedEx Overnight

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3561

Attn:	     Ms. Kellie
Kim

Mr. Isaac Esquivel

Office of Real Estate &
Construction

    Re:
    Bluerock Homes Trust, Inc.

    Form 10-K for the fiscal year ended December 31, 2024

    Commission File No. 001-41322

Ladies and Gentlemen:

This letter is submitted on
behalf of Bluerock Homes Trust, Inc. (the “Company”), in response to a comment received from the staff of the
Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”),
Office of Real Estate & Construction, by letter dated July 8, 2025 with respect to the Company’s Form 10-K for
the fiscal year ended December 31, 2024 filed with the Commission on March 20, 2025 (“Form 10-K”).

For your convenience, the
Company’s response is prefaced by the exact text of the Staff’s comment in bold, italicized text. References to rules herein
are with respect to the current rules promulgated by the Commission under Regulation S-X of the Securities Act of 1933, as amended.

Form 10-K for the fiscal year ended December 31,
2024

Notes to Consolidated Financial Statements

Note 3 - Acquisition of Real Estate, page F-15

 1. We note your acquisition of Avenue at Timberlin Park on July 31, 2024 with an acquisition price
of $33.8 million. Please tell us how you determined it was unnecessary to provide audited financial statements and pro forma financial
information for this acquisition.

Response:

The Company respectfully advises
the Staff that the acquisition of Avenue at Timberlin Park did not constitute a “significant” acquisition of a real estate
operation under Rule 1-02(w)(1)(i) as modified by Rule 3-14(b)(2), based on the following calculation, which equals a significance
level of 17%.

 · Numerator (cash paid by the issuer) = $11,055,105

 · Denominator (aggregate worldwide market value) = $65,277,270

Rule 3-14 of Regulation
S-X requires issuers to present the audited financial statements and pro formas of acquisitions of real estate operations that exceed
a “significance” threshold of 20%. In order to determine significance, Rule 1-02(w)(1)(i), as modified by Rule 3-14(b)(2),
requires an issuer to compare (a) the investments by the issuer and its subsidiaries in the acquired property and any advances they
made to the acquired property (the “Total Investment”) to (b) the average aggregate worldwide market value of
the issuer’s voting and non-voting common equity (“WWMV,” and such test as referred to herein, the “Amended
Investment Test”). WWMV is calculated using the shares outstanding and daily average price of the issuer’s common stock
for the last five trading days of the calendar month ended before the earlier of (i) the issuer’s announcement of the transaction
or (ii) the date of the acquisition agreement.

Total Investment

The Total Investment for the
property used as the numerator in the calculation above included the cash paid, inclusive of closing costs, in the amount of $11,055,105.
As a precedent step to the acquisition closing, a wholly-owned subsidiary of the Company’s operating partnership formed specifically
to acquire and hold the property entered into a new mortgage loan in the amount of $23,660,000 (the “Avenue Mortgage”),
which was secured solely by the property. In the Total Investment numerator above, the Company did not include the amount of the Avenue
Mortgage, which we believe is appropriate to treat as “assumed debt.”

The Company’s exclusion
of the Avenue Mortgage from the Total Investment was based on the language of Rule 3-14, related SEC commentary in SEC Release No. 33-10786
regarding treatment of “assumed debt” for purposes of Rule 3-14, and the Staff’s most recent Financial Reporting
Manual guidance on the same.

Rule 3-14(b)(2)(ii) specifies
that, when WWMV is not available, the issuer’s total assets should be used in its place as the denominator of the Amended Investment
Test, and the Total Investment used as the numerator should include any assumed debt secured by the acquired property in this instance.
The Staff’s recently-released Financial Reporting Manual clarifies how this is calculated:

2920.5 Investment Test – Numerator
- Real Estate Operations – When this test is based on the total assets of the registrant (because the registrant does not have an
aggregate worldwide market value), include any assumed debt secured by the real properties in the “investments in” determination
for the tested real estate operation. For example, if the registrant paid $100 million in cash and assumed $40 million of debt secured
by the acquired properties, the “investments in” the acquired real estate operation for the numerator would be $140 million.

Under Rule 3-14(b)(2),
this specification is applicable only to instances when total assets is used in place of WWMV; it is not applicable to instances when
WWMV is available. This appears to reflect an intentional distinction by the Commission, indicating that when WWMV is available, the opposite
approach should be taken, and the Total Investment should exclude any assumed debt secured by the acquired property.

This conclusion is further
supported by SEC Release No. 33-10786, in which the Commission addressed the Amended Investment Test (the “Adopting Release”):

When based on total assets, the final
amendments specify, as proposed, that the test should be adapted to compare the registrant’s and its other subsidiaries’ “investments
in” the real estate operation, including any debt secured by the real properties that is assumed by the registrant, to the registrant’s
total assets as of the end of the most recently completed fiscal year. We believe a modified Investment Test is necessary to appropriately
determine significance for acquisitions of real estate operations because it takes into consideration the unique structure of these types
of acquisitions, which typically involve assumed debt that is secured by the real properties that offsets the value of the real estate
operation being acquired [emphasis added].1

The Commission thus acknowledges
in the Adopting Release that assumed debt secured by the acquired property offsets the value of the property, and for this reason, should
not be included as part of the Total Investment when that amount is compared to WWMV for purposes of determining the significance of the
acquisition under Rule 3-14.2

1 See Adopting Release at p.95.

2 The same conclusion was reached
by Deloitte. See Chapter 3 - Real Estate Operations Acquired or to Be Acquired, 3.3 Measuring the Significance of Real Estate Operations”
in Deloitte’s Roadmap publication:

While the Commission did not
explicitly define “assumed debt,” both existing debt and new mortgage debt on the acquired property serve to offset the value
of the specific property acquired in the same manner. There is no substantive distinction between the effect of debt already in place
and the effect of new mortgage debt on the value of an acquiring issuer’s investment in the property. A seller could encumber a
property with mortgage debt a day before the sale of that property, which would be existing debt, or a new mortgage can be entered into
concurrent with the closing – the impact of both is the same. Therefore, all debt secured by an acquired real estate operation at
closing – whether existing, or in the form of new mortgage debt – should be excluded from the Total Investment as “assumed
debt” for purposes of the Amended Investment Test.

WWMV

As of April 2, 2024 (the
date of entry into the purchase and sale agreement for the acquisition of the property), the Company’s WWMV was $65,277,270, based
on (i) 3,871,265 shares of the Company’s Class A common stock outstanding, and (ii) a daily average price of the
Company’s Class A common stock of $16.86 for the last five trading days of March 2024 (i.e., the calendar month ended
before the date of the purchase and sale agreement) on the NYSE American. The Company did not otherwise publicly announce the potential
acquisition of the property prior to entering into the purchase and sale agreement.

Conclusion

The Total Investment in the
property of $11,055,105, when compared to the Company’s WWMV of $65,277,270, resulted in a significance level of 17% under the Amended
Investment Test. Because the property did not exceed a significance level of 20%, the Company determined that it was not required to file
(1) a current report on Form 8-K under Item 2.01 to report the acquisition, nor (2) Rule 3-14 financial statements
or pro forma financial statements under Item 9.01 of Form 8-K.

***

If you have any questions
or comments regarding the foregoing, please contact the undersigned at 646-278-4225 or Sonia Barros with Sidley Austin LLP at 202-736-8387.

    Sincerely,

    /s/ Jason Emala

    Jason Emala

    Chief Legal Officer

    Bluerock Homes Trust, Inc.

cc: Sonia G. Barros, Sidley Austin LLP

To determine the significance of real
estate operations, a registrant only needs to perform the investment test described in Rule 1-02(w)(1)(i) as modified by Rule 3-14(b)(2)(ii).
. . . The registrant applies the modified investment test as follows on the basis of whether it has an AWMV:

 · Registrant has AWMV — The registrant’s
investment in the real estate operation is compared with the registrant’s AWMV:

 o Investment in the real estate operation — This amount is determined on the basis of the “consideration
transferred,” which is measured in accordance with the applicable accounting standards. The investment should exclude any
debt secured by the real properties that is assumed by the registrant [emphasis added]. . . .