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CORRESP
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CORRESP

 Simpson Thacher & Bartlett LLP

900 G STREET NW

WASHINGTON, DC 20001

 TELEPHONE: +1-202-636-5500

 FACSIMILE: +1-202-636-5502

 Direct Dial Number

202-636-5592

 E-mail Address

Steven.Grigoriou@stblaw.com

 June 13, 2024

 VIA
EDGAR

 Securities and Exchange Commission

 Division
of Investment Management

 100 F Street, N.E.

 Washington,
D.C. 20549

 Attn: David P. Mathews

Re:
 Franklin BSP Real Estate Debt BDC

Registration Statement on Form 10 (File No. 000-56653)

Dear Mr. Mathews:

 On behalf of Franklin
BSP Real Estate Debt BDC, formerly known as Franklin BSP Real Estate Credit BDC, we hereby transmit for filing to the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) responses to comments
received from the Staff on May 30, 2024 relating to the above-referenced registration statement on Form 10, filed with the SEC on April 22, 2024 (the “Registration Statement”).

For convenience of reference, the comments of the Staff have been reproduced herein. We have discussed the Staff’s comments with
representatives of the Company. The Company’s responses to the Staff’s comments are set out immediately under the reproduced comment. All capitalized terms used but not defined in this letter have the meanings given to them in the
Registration Statement.

 GENERAL COMMENTS

1.
 Comment: The Registration Statement states that the Company intends to file an election to be regulated
as a BDC under the 1940 Act as soon as reasonably practical following its filing of this Form 10. In correspondence, please advise as to when the Company expects to file such election.

Response: The Company filed its election to be regulated as a BDC on Form N-54A on June 6,
2024 and has revised the Registration Statement accordingly.

Securities and Exchange Commission

June 13, 2024

2.
 Comment: Please advise in correspondence if the Company or Advisor expects to submit or rely upon any
exemptive applications or no-action relief requests in connection with the Registration Statement or operations of the Company, other than the co-investment Order, and
pending application for a new co-investment exemptive order which would supersede the Order if granted, as described in the Registration Statement.

Response: The Company confirms that the Company and the Advisor do not expect to submit or rely upon any exemptive applications or no-action relief requests in connection with the Registration Statement or operations of the Company, other than the co-investment Order and the pending application for a new co-investment exemptive order, which would supersede the Order if granted.

3.
 Comment: Please confirm that the Company does not intend to issue debt securities or preferred stock
within a year from the effective date of the Registration Statement. If the Company plans to issue preferred shares within a year from the effectiveness of the Registration Statement, please include additional disclosure of risks to holders of
Common Shares in the event of a preferred shares offering.

 Response: The Company confirms that it does not intend
to issue preferred shares within one year of the effectiveness of the Registration Statement. The Company may issue debt securities within one year of the effectiveness of the Registration Statement and refers the Staff to “Item 1A. Risk
Factors—Risks Related to Debt Financing” in the Registration Statement for a discussion of risks to common shareholders in the event the Company issues debt securities.

REGISTRATION STATEMENT

 Explanatory Note

4.
 Comment: In the second paragraph, please clarify the definitions for Benefit Street Partners L.L.C. in
its roles as both Advisor and Administrator. For example, in reference to the definition of “Other BSP Accounts”, the disclosure describes such accounts as being advised and/or managed by “BSP”. Earlier in the paragraph,
the term “BSP” is described as being used to refer to Benefit Street Partners L.L.C. in its role as an administrator.

Response: In response to the Staff’s comment, the Company has revised the Registration Statement accordingly.

5.
 Comment: In addition to the disclosure on page 63 of the Registration Statement, and elsewhere,
regarding uncertainty as to sources, amounts and timing of distributions, please also add to the bullet points in this section a description of the uncertainty as to amounts and frequencies of distributions.

Response: In response to the Staff’s comment, the Company has revised the Registration Statement accordingly.

Securities and Exchange Commission

June 13, 2024

 Summary Risk Factors

6.
 Comment: The introduction to the Summary Risk Factors section states that the complete discussion of
risk factors faced by the Company are set forth in Item 1A of the Registration Statement. The Introduction to the Risk Factors section in Item 1.A. however states that it is not a complete list of risk factors. Please conform the statements to be
consistent in this regard, and confirm in correspondence that the disclosure of risks in the Registration Statement fairly addresses all material actual and potential risks associated with an investment in the Company’s Common Shares.

 Response: In response to the Staff’s comment, the Company has revised the Registration Statement accordingly
and confirms that the disclosure of risks in the Registration Statement fairly addresses all known material actual and potential risks associated with an investment in the Company’s Common Shares.

Item 1. Business

7.
 Comment: In the description of the Company’s business (page 5), please include definitions
and/or examples of what is meant by the terms “middle market” investments and “multi-family” lending, as those types of investments are stated to be the intended focus of the Company’s portfolio investments.
Please also include in the disclosure estimates or ranges of anticipated exposure of the portfolio to investments tied to the middle market and multifamily segments of the CRE industry, as compared to other market categories or segments of the CRE
industry represented in the portfolio (e.g., office space, industrial use or retail).

 Response: In
response to the Staff’s comment, the Company has revised the Registration Statement accordingly.

8.
 Comment: Please also elaborate further in the description of the Company’s business regarding what
is meant by “conservative loan-to-value ratios against high-quality real assets” and how it reduces downside risk.

Response: In response to the Staff’s comment, the Company has revised the Registration Statement accordingly.

Investment Strategy (page 6)

9.
 Comment: Inclusion of the term “Real Estate Credit” in the Company’s name will, upon its
election to be regulated as a BDC, require an 80% test policy and compliance with Rule 35d-1. Please add to the description of the Company’s investment strategy a statement of 80% policy consistent with
the requirements of Rule 35d-1, and include disclosure of whether the policy will be fundamental or non-fundamental, and if the latter, also disclose that investors will
be given 60 days’ advance notice of any change in such policy.

 Response: In response to the Staff’s
comment, the Company advises that Staff that it has changed its name from “Franklin BSP Real Estate Credit BDC” to “Franklin BSP Real Estate Debt BDC” and has revised the Registration Statement accordingly. Additionally, in
response to the Staff’s comment, the Company’s Board of Trustees has adopted a non-fundamental 80% policy to invest in debt instruments issued by companies primarily engaged in the business of owning
and/or operating real estate and revised the disclosure accordingly.

Securities and Exchange Commission

June 13, 2024

 Market Opportunity (page 9)

10.
 Comment: Please explain in the disclosure what price-to-book multiples are and how they are relevant to the assertions made regarding the real estate lending market’s equilibrium shift.

Response: In response to the Staff’s comment, the Company has revised the Registration Statement accordingly.

Investment Process (page 10)

11.
 Comment: The description of the Investment Process and graphics focuses primarily on the investment
process and diligence associated with loans. Given that the investment strategy description also includes, to a lesser extent, investments in other real estate related debt and equity investments, please add disclosure, where applicable, of how the
investment or diligence processes might be similar or differentiated from the loan origination and related processes when the Advisor is making other types of investments on behalf of the Company.

Response: In response to the Staff’s comment, the Company advises that it uses the same investment process for all investments,
including non-loan investments, and has updated the graphics accordingly.

 Management Fee and
Incentive Fee (page 14)

12.
 Comment: In this section, or an otherwise appropriate location, we suggest that, because it would be
helpful to investors, you consider adding a fee table that conforms to requirements of Item 3 of Form N-2.

Response: The Company notes that disclosure under the heading “Item 2. Financial Information—Discussion of
Management’s Expected Operating Plans—Expenses” provides a description of the expenses that the Company will be obligated to pay, including the management fees and incentive fees payable to the Advisor. In addition, the Company also
has an expense cap on organization expenses, offering expenses and operating expenses, and investors therefore are aware of the maximum amount of organization, offering and operating costs that could be payable by the Company. The Company is aware
that Form N-2 (used for registered public offerings by Business Development Companies and investment companies) requires a summary of fund fees and expenses that includes estimates of expenses as a percentage
of net assets. As the Company is not making a registered public offering, it is not required to file a Form N-2. The Company respectfully submits that it is not aware of a requirement in Form 10 to include a
fee table that conforms to the requirements of Item 3.1 of Form N-2. The Company’s actual expense and fee-related information will be publicly available in the
financial statements included in its periodic reports.

13.
 Comment: Please also consider including incentive fee examples and a graphical representation
demonstrating the operation of the incentive fee in the Registration Statement; and adding an easy-to-understand statement or example describing the incentive fee (e.g., results in the Company paying an
incentive fee equal to X% on income that exceeds our y% hurdle).

 Response: The Company respectfully declines to
include a graphical representation referenced above. Additionally, the Company’s shares are being offered to accredited investors and the Company does not believe that the above suggested disclosure is necessary for such investors.

Securities and Exchange Commission

June 13, 2024

14.
 Comment: The disclosure states that “[F]or the purpose of computing the Company’s Pre-Incentive Fee Net Investment Income, the calculation methodology will look through total return swaps as if the Company owned the referenced assets directly.” Based on the disclosure in the Registration
Statement, it is unclear the extent to which the Company will enter into total return swaps in pursuit of its investment strategy. If the Company intends to engage in total return swaps as a component of its investment portfolio:

a.
 Please add disclosure clarifying the Company’s intended use of total return swapsto achieve its investment
objective, and describing material risks associated with such instruments; and

b.
 Also advise the staff in correspondence how the Company will treat the loans and obligors underlying total
return swaps for purposes of determining whether such investments qualify as an Eligible Portfolio Company under Section 55(a) of the 1940 Act.

Response: In response to the Staff’s comment (a), the Company advises that it does not intend to invest in total return swaps in a
material manner and confirms that, if it does invest in total return swaps in a material manner, the Company will update its disclosure accordingly.

In response to the Staff’s comment (b), for purposes of Section 55(a) of the 1940 Act, the Company will treat each loan underlying
the swap as a qualifying asset only if the obligor on the loan is an eligible portfolio company and as a non-qualifying asset if the obligor is not an eligible portfolio company.

Administration Agreement (page 16)

15.
 Comment: In addition to a description of the Administration Agreement, please also identify and describe
in the disclosure the institution that will serve as the Company’s custodian and a description of custodial arrangements and expenses. Also include as a material contract the custodial agreement as an exhibit to the Registration Statement.

 Response: In response to the Staff’s comment, the Company has revised the Registration Statement accordingly
and filed the custodial agreement as Exhibit 10.6 to the Registration Statement.

 Private Placement (page 17)

16.
 Comment: Please disclose in the Registration Statement the minimum initial commitment of capital that
will be required of investors, any minimums applicable to follow-on capital commitments, and the bases upon which the Advisor in its discretion may accept lower amounts or decline to accept particular
commitments.

 Response: Due to a change of the Company’s term as more fully described in the Company’s
response to the Staff’s Comment 18, the Company has revised Subscription Agreement filed as Exhibit 4.1 to the Registration Statement. The Company advises that there is no minimum capital commitment, whether initial or follow-on, and that all references to minimum capital commitments have been removed in the Subscription Agreement.

Securities and Exchange Commission

June 13, 2024

17.
 Comment: Please provide in the disclosure more details, or examples, of the types of legal, tax,
regulatory or other considerations that could prompt the Company to make non-pro rata capital drawdowns, and in correspondence, please explain the policies and procedures the Company will follow to ensure
investors are treated fairly and equitably in such circumstances.

 Response: In response to the Staff’s
comment, the Company has revised the Registration Statement accordingly. The Company advises the Staff, on a supplemental basis, that the Company will generally call drawdown capital on a pro rata basis but may call drawdown capital on a non-pro rata basis (i) to seek to equalize the percentage of a particular investor’s total Capital Commitment that has been contributed to the Company relative to the capital contributions of other
investors, (ii) to avoid any violation of the Securities Act, the 1940 Act or any state (or other jurisdiction) securities or “blue sky” laws applicable to the Fund, and (iii) to comply with the aggregated ownership limit as
provided in the Company’s Declaration of Trust for the Company to qualify as a REIT. Additionally, the Company advises the Staff that it has removed all references pertaining to benefit plan investors within the meaning of ERISA in the
Registration Statement, and in the Subscription Agreement filed as Exhibit 4.1 to the Registration Statement, as the Company no longer intends to admit any benefit plan investors.

Term (Pages 18-19)

18.
 Comment: Please consider adding a separate sub-heading to
separate the disclosure regarding the share repurchase program from the discussion immediately above it regarding the Company’s term and perpetual duration.

Response: The Company advises that its Board of Trustees has approved, and its organizational documents have been amended, to change the
Company’s term from a perpetual life BDC to a fixed term BDC. Further, the Company will not have a share