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CORRESP
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              601 Lexington Avenue

              New York, NY 10022

              United States

              +1 212 446 4800

              www.kirkland.com

               Facsimile:

                +1 212 446 4900

    November 15, 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

              Amendment No. 1 to Registration Statement on Form 10-12G

              Filed October 18, 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 November
      4, 2024, with respect to the above referenced Registration Statement on Form 10-12G initially filed on September 6, 2024, as amended by a pre-effective amendment thereto filed on October 18, 2024 (as amended, 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 a post-effective amendment to the Registration Statement (the “Post-Effective

        Amendment”) with this letter.

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     U.S. Securities and Exchange Commission

        Division of Corporation Finance

        Office of Real Estate & Construction

        November 15, 2024

        Page 2

    Amendment No. 1 to Registration Statement on Form 10-12G filed October 18, 2024

    Item 7. Certain Relationships and Related Transactions, and Trustee Independence

    Dealing with Potential Conflicts of Interest, page 118

          1.

            We note your response to prior comment 12. Please revise to specify when, under your conflict of interest policy, transactions would be required to be presented to your board of trustees for approval. We note, for example, disclosure in
              your risk factor on page 82, "Our conflict of interest policy may not be successful . . . ."

    Response: In response to the Staff’s comment, the Company has revised pages 119 to 120 of the Post-Effective Amendment.

    General

          2.

            We note your responses to prior comments 19 and 20. Please discuss supplementally the nature of the Company’s subsidiaries that currently (or may expect to in the future) rely on Sections 3(c)(1) or 3(c)(7) of the 1940 Act for an exclusion
              from the definition of “investment company” (e.g., nature of investors, advisory relationships, etc.).

    Response: Generally, the Company’s subsidiaries that currently (or may expect to in the future) rely on Sections 3(c)(1) or 3(c)(7) of the
      1940 Act will do so when the Company determines that (i) existing positions set forth by the Staff may not support relying on another exception or exclusion under the 1940 Act (e.g., to the extent the entity’s assets are not addressed in no-action
      letters issued by the Staff for purposes of the Section 3(c)(5)(C) analysis) or (ii) the entity does not yet have sufficient qualifying real estate assets to rely on Section 3(c)(5)(C) (e.g., to the extent the entity is newly formed and has not yet
      acquired or originated sufficient qualifying real estate assets but nonetheless expects to rely on Section 3(c)(5)(C) in the future).

    While a third-party joint venture partner may in the future hold an interest in a subsidiary of the Company that relies on Sections 3(c)(1) or 3(c)(7), investors generally acquire interests in the
      Company (and not its subsidiaries). Furthermore, the Company’s subsidiaries that currently (or may expect to in the future) rely on Sections 3(c)(1) or 3(c)(7) are not managed as separate advisory clients. Rather, the Company is an advisory client of
      FCR Advisors LLC (the “Adviser”). The Adviser manages the Company’s assets, which are generally held in various subsidiaries of the Company—including any subsidiaries that currently (or may
      expect to in the future) rely on Sections 3(c)(1) or 3(c)(7).

       U.S. Securities and Exchange Commission

          Division of Corporation Finance

          Office of Real Estate & Construction

          November 15, 2024

          Page 3

    Currently, the Company has two wholly owned subsidiaries that it has determined to conservatively treat as relying on Section 3(c)(7) of the 1940 Act because the assets of such subsidiaries generally
      consist of mortgage servicing rights (“MSRs”) acquired from unaffiliated third parties, and positions set forth by the Staff indicate such MSRs would therefore not be sufficient, on their
      own, for such subsidiaries to rely on Section 3(c)(5)(C).1 Specifically, based on positions set forth by the Staff, certain MSRs are treated as qualifying real estate
      assets for purposes of Section 3(c)(5)(C), while other MSRs—generally including MSRs that are acquired from an unaffiliated third party under certain conditions—are treated as real estate-related assets.2 As a result, the Company has determined that a subsidiary whose assets generally consist of MSRs acquired from unaffiliated third parties should conservatively rely on Section 3(c)(7) because such
      subsidiary may not meet the applicable tests for Section 3(c)(5)(C).

    The Company does not currently have any other interest in any entity that relies on Section 3(c)(1) or Section 3(c)(7).

    As discussed in the Post-Effective Amendment, we intend to conduct our operations so that the Company complies with the 40% test set forth in Section 3(a)(1)(C) of the 1940 Act. Therefore, securities
      issued by any entity that is excepted from the definition of “investment company” based on Section 3(c)(1) or Section 3(c)(7) of the 1940 Act, together with any other investment securities the Company owns, may not have a value in excess of 40% of
      the value of the Company’s total assets (exclusive of U.S. government securities and cash items) on an unconsolidated basis. We will monitor our holdings to ensure continuing and ongoing compliance with this test. We confirm that the Company’s
      interests in the two Section 3(c)(7) subsidiaries discussed above are treated as “investment securities” for purposes of the 40% test and are reflected as such in the ratio provided in the Company’s response to prior comment 19.

            1

              As discussed in our previous response, to qualify for the exclusion pursuant to Section 3(c)(5)(C) of the 1940 Act, based on positions set forth by the Staff of the SEC, each subsidiary of the Company that seeks to rely on Section
                3(c)(5)(C) generally is required to hold (i) at least 55% of its assets in qualifying real estate assets and (ii) at least 80% of its assets in qualifying real estate assets and real estate-related assets.

            2

              See Redwood Trust Inc., SEC Staff No-Action Letter (Aug. 15, 2019).

          3.

            We note your response to prior comment 22. Wherever you include disclosure in the registration statement related to subsidiaries relying on Rule 3a-7 for an exemption from the 1940 Act, please revise to clarify that no such subsidiaries
              are currently operating.

    Response: In response to the Staff’s comment, the Company has revised page 16 of the Post-Effective Amendment.

    We hope that the foregoing has been responsive to the Staff’s comments. If you have any questions related to this letter, please contact Ross M. Leff at (212) 446-4947 of Kirkland & Ellis LLP.

            Sincerely,

              /s/ Ross M. Leff

            Ross M. Leff

    Via Email:

              cc:

                Avraham Dreyfuss

                Fortress Credit Realty Income Trust

                David Brooks

                Fortress Investment Group LLC

                Nicole M. Runyan

                David L. Perechocky

                Tamar Donikyan

                Kirkland & Ellis LLP