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CORRESP
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                601 Lexington Avenue

                New York, NY 10022

                United States

                +1 212 446 4800

                 Facsimile:

               +1 212 446 4900

                www.kirkland.com

    October 17, 2024

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Real Estate & Construction

    100 F Street, NE

    Washington, D.C. 20549

              Attn:

              Howard Efron

                Kristina Marrone

                Benjamin Holt

                Pam Long

              Re:

              Fortress Credit Realty Income Trust

                Registration Statement on Form 10-12G

                Filed September 6, 2024

                File No. 000-56685

    Ladies and Gentlemen:

    This letter sets forth the responses of Fortress Credit Realty Income Trust (the “Company”) to the written comments
      received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
      in your letter dated October 3, 2024, with respect to the above referenced Registration Statement on Form 10-12G filed on September 6, 2024 (the “Registration Statement”).

    The text of the Staff’s comments has been included in this letter for your convenience, and we have numbered the paragraphs below to correspond to the numbers in the Staff’s
      letter. For your convenience, we have also set forth the Company’s response immediately below the numbered comments.

    In addition, the Company has revised the Registration Statement and the Company is concurrently filing an amendment to the Registration Statement (the “Amended Registration Statement”) with this letter.

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    U.S. Securities and Exchange Commission

      Division of Corporation Finance

      Office of Real Estate & Construction

      October 17, 2024

      Page 2

    Registration Statement on Form 10-12G Filed September 6, 2024

    Item 1. Business

    Leverage, page 11

              1.

              Please disclose your target leverage ratio, as this term is used on page 13 and in several risk factors. We note that you have disclosed Fortress’s historical average leverage of 50-65% for commercial and
                residential real estate debt investments. Please also revise to disclose whether there is an upper limit to the amount of leverage you may utilize, and if so, please specify such limit. In this regard, we note your statement that you could
                add more leverage in certain instances where a transaction can support it. Also revise to briefly discuss how you would determine a transaction can support additional leverage and strategies you may use to manage the risks of using
                leverage, such as “match-funded” structures and/or hedging, as you explain on pages 84 and 87, respectively.

    Response: We respectfully
        advise the Staff that the Amended Registration Statement has been revised (pages 11 and 12) to address the Staff’s comment. In addition, we respectfully direct the Staff to pages 13 and 14 relating to limitations on the incurrence of indebtedness.

    Fortress Credit Realty Income Trust Structure, page 15

              2.

              Please revise the ownership structure chart on page 16 to reflect the following, as applicable:

              •

              The ownership of FIG LLC by Fortress;

              •

              The ownership of the company by each of FIG LLC and BTG, as of the most recent practicable date, as a result of their purchases of shares pursuant to the FIG Subscription Agreement and the BTG
                Subscription Agreement, respectively;

              •

              The Administration Agreement between the company and FCR Advisors LLC; and

              •

              The ownership by the company of various subsidiaries/investments.

    Response: In response to the
        Staff’s comment, the Company has revised its ownership structure chart on page 17 of the Amended Registration Statement to disclose (a) the ownership of FIG LLC by Fortress Investment Group LLC, (b) the ownership of the Company by each of FIG LLC
        and BTG after giving effect to purchases of shares pursuant to the subscription agreements, (c) the Administration Agreement between the Company and FCR Advisors LLC and (d) the ownership by the Company of various subsidiaries and/or investments.

          U.S. Securities and Exchange Commission

            Division of Corporation Finance

            Office of Real Estate & Construction

            October 17, 2024

            Page 3

    Management Fee, page 18

              3.

              Please revise here and under the heading “Our Independent Valuation Advisor” on page 131 to identify your independent valuation advisor.

    Response: In response to the
        Staff’s comment, the Company has revised pages 19 and 133 of the Amended Registration Statement.

    Term and Termination Rights, page 18

              4.

              Please revise here and your associated risk factor on page 75 to clarify whether there would be a penalty if the company were to terminate the Management Agreement (i) without cause or (ii) upon
                less than 60 days’ written notice. Also revise to clarify what constitutes “cause” under the Management Agreement, as it does not appear to be defined in Exhibit 10.1

    Response: In response to the
        Staff’s comment, the Company respectfully advises the Staff that the Management Agreement does not use the term “cause” and there is no penalty payable upon termination of the Management Agreement. The Amended Registration Statement has been
        revised (pages 19 and 76) to clarify and address the Staff’s comment.

    Organization and Offering Expense Reimbursement, page 19

              5.

              Please revise to disclose, as of the most recent practicable date, all organization and offering expenses advanced by the Adviser on behalf of the company. In this regard, we note your financial
                statement disclosure that as of July 16, 2024, the Adviser has incurred $2.9 million of organization and offering expenses on behalf of the company.

    Response: We respectfully
        advise the Staff that the Amended Registration Statement has been revised (page 21) to address the Staff’s comment.

            U.S. Securities and Exchange Commission

              Division of Corporation Finance

              Office of Real Estate & Construction

              October 17, 2024

              Page 4

    Performance Fee, page 19

              6.

              Please revise to further explain how Core Earnings is calculated. More specifically, define “certain non-cash adjustments” and “certain material non-cash income or expense items.” Also clarify or
                explain your statement, “in each case after discussions between the Adviser and our independent trustees and approved by a majority of our independent trustees,” which suggests that despite Core Earnings for a given quarter being the result
                of a defined calculation or formula, the Adviser and your independent trustees nevertheless retain the discretion to modify Core Earnings. Also revise to disclose who calculates Core Earnings and who is ultimately and solely responsible for
                determining Core Earnings.

    Response: The Company
        respectfully advises the Staff that Core Earnings is the result of a defined formula as specified in the Management Agreement. The definition of “Core Earnings” allows the exclusion from net income (loss) of certain non-cash adjustments and certain
        material non-cash income or expense items. However, such exclusions must be discussed between the Adviser and the Company’s independent trustees and any exclusions from net income (loss) covered by clause (vi) of the definition of “Core Earnings”
        must be approved by a majority of the independent trustees. This definition of “Core Earnings”, which is similar to a number of peer mortgage REITs, is designed to give the Adviser and the independent trustees some level of flexibility and
        discretion to provide a more accurate and consistent calculation of Core Earnings across multiple quarters by excluding certain non-cash adjustments and non-cash income or expense items that may arise in a specific quarter.  The Company has revised
        the disclosure on page 20 of the Amended Registration Statement to disclose who calculates Core Earnings and who is ultimately and solely responsible for determining Core Earnings.

              7.

              Please revise to disclose, if true, that the Adviser is entitled to receive compensation under the performance fee for a given year even if shareholders experienced a decline in NAV per share. In
                this regard, we note your disclosure on page 124 that it is possible that certain service providers or Sourcing Partners may receive incentive compensation from the company, even though the company, as a whole, does not have net capital
                appreciation.

    Response: In response to the
        Staff’s comment, the Company has revised the disclosure on page 20 of the Amended Registration Statement.

    Share Repurchase Plan, page 23

              8.

              Please be advised that you are responsible for analyzing the applicability of the tender offer rules, including Rule 13e-4 and Regulation 14E, to your share repurchase plan. We urge you to consider
                all the elements of your share repurchase plan in determining whether the plan is consistent with relief granted by the Division of Corporation Finance in prior no action letters. To the extent you are relying on Blackstone Real Estate
                Income Trust, Inc. (Letter dated September 12, 2016), Rich Uncles NNN REIT, Inc. (Letter dated December 21, 2016), Hines Global REIT II, Inc. (Letter dated April 26, 2017), or Black Creek Diversified Property Fund Inc. (Letter dated
                September 1, 2017), please provide us with an analysis as to how your program is consistent with such relief. To the extent you have questions as to whether the plan is entirely consistent with the relief previously granted by the Division
                of Corporation Finance, you may contact the Division’s Office of Mergers and Acquisitions at 202-551-3440.

            U.S. Securities and Exchange Commission

              Division of Corporation Finance

              Office of Real Estate & Construction

              October 17, 2024

              Page 5

    Response: The Company
        acknowledges the Staff’s comment and respectfully advises the Staff that it has analyzed the applicability of the tender offer rules, including Rule 13e-4 and Regulation 14E, and has also considered the Staff’s no-action letters referenced above,
        in each case, with respect to its share repurchase plan (the “Share Repurchase Plan”). The Company respectfully advises the Staff that the
        Company believes its Share Repurchase Plan is consistent with the relief granted by the Staff in prior no-action letters, in particular, the relief granted to Blackstone Real Estate Income Trust, Inc. in the Staff’s letter dated September 12, 2016
        (“Blackstone”) and Griffin Capital Essential Asset REIT II, Inc. (SEC No-Action Letter dated September 20, 2017 (“Griffin”). By way of illustration, set forth below is a table comparing the key features underlying the relief granted in Blackstone and Griffin compared to the Share
        Repurchase Plan. As shown below, the Share Repurchase Plan contains each of the key features specified by the Staff in Blackstone and Griffin.

            Key Features of Share Repurchase Plan

            Blackstone

            Griffin

            The Company

            All material information relating to the repurchase plan will be fully and timely disclosed to all shareholders. The terms of the repurchase plan will be fully disclosed in the Company’s
              offering documents, and the most recently determined NAV per share for each class of the Company’s shares will always be available on the Company’s website and toll-free information line. 1

            Yes

            Yes

            Yes

            The Company will not solicit repurchases under the repurchase plan other than through the Company’s offering materials and supplements thereto disclosing the transaction price and NAV per
              share of each class of the Company’s shares. Shareholders desiring to request repurchase of all or a portion of their shares will do so of their own volition and not at the behest, invitation or encouragement of the Company. The role of the
              Company in effectuating repurchases under the repurchase plan will be ministerial.

            Yes

            Yes

            Yes

                1

                We note that each of Blackstone and Griffin relate to continuous public offerings of common stock registered
                    under the Securities Act of 1933, as amended (the “Securities Act”) and, accordingly, disclosed the terms of their respective programs in a prospectus, while the Company is
                    conducting a continuous private offering of its common shares exempt from registration under the Securities Act. Substantially the same information will be provided in the offering memorandum relating to the private offering. We do not
                    believe the nature of the offering is determinative as the condition relates to disclosure of the program terms to investors in the relevant disclosure document provided at the time the investor makes an investment decision. See also
                    Broadstone Net Lease Inc. (relying on existing no-action letter relief in connection with its repurchase program while conducting a continuous private offering).

            U.S. Securities and Exchange Commission

              Division of Corporation Finance

              Office of Real Estate & Construction

              October 17, 2024

              Page 6

            Shares will be repurchased quarterly under the repurchase plan at a price which will generally be equal to the NAV per share for the applicable class of shares for the prior month, and
              the Company will provide shareholders information by supplement, disclosing the historical NAV per share of each class of shares and also provide each month the transaction price and the NAV per share for each class of shares on the Company’s
              website and toll-free information line. Subject to the terms of the repurchase plan, the Company will repurchase shares at the transaction price per share for the applicable class of the Company’s shares.2

            Yes

            Yes

            Yes

            Repurchases will be made on a quarterly basis. The repurchase price normally will be paid in cash within three business days following the last calendar day of the applicable quarter and
              will be the same for all shares of the same class repurchased in a given quarter.3

            Yes

            Yes

            Yes

                2

                While Blackstone refers to a monthly repurchase program, the Company’s repurchase plan is consistent with Griffin, which
                    provides for quarterly repurchases. While Blackstone and Griffin undertook to file prospectus supplements disclosing the historical NAV per share, the Company intends to file a Current Report on Form 8-K under the Exchange Act of 1934,
                    as amende