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Goldman Sachs Real Estate Finance Trust Inc

200 West Street, New York, New York 10282

Via EDGAR

October 10, 2024

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Mail Stop 3010CF/AD8

Washington, DC 20549

Attn: Pam Long

 Ruairi Regan

 Peter McPhun

 Shannon Menjivar

Re: Goldman Sachs Real Estate Finance Trust Inc

 Amended Registration Statement on Form 10

 Filed September 6, 2024

 File No. 000-56667

Ladies and Gentlemen:

This letter sets forth the response of Goldman Sachs Real Estate Finance Trust Inc, a Maryland corporation (the “Company”), to the comment of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) contained in the letter dated October 1, 2024, pertaining to the Amended Registration Statement on Form 10 (the “Registration Statement”) that was submitted to the SEC on September 6, 2024. We have included the Staff’s comment below, followed by the Company’s response thereto.

Amended Registration Statement on Form 10

NAV, page 150

1.Please revise your NAV template to identify the primary valuation method and the key assumptions used in the primary valuation method, including the weighted average for each key assumption and a quantitative example of the sensitivity of the estimate to changes in assumptions.

Response:  The Company undertakes to revise its NAV template to add the following as requested:

Set forth below is the weighted average of the discount rate, the key assumption used in the discounted cash flow methodology, the primary methodology used in the [Month], 2024 valuation of our investments in commercial loans.

Investment  Discount Rate

Commercial Loans  [__]

Division of Corporation Finance

U.S. Securities and Exchange Commission

October 10, 2024

Page 2

The investment value sensitivity analysis table presented below shows the estimated impact of a change in market discount rates, up and down 100 basis points, on the fair value of our investments in commercial loans as of [Month], 2024, assuming a static portfolio and constant financing. When evaluating the impact of changes in discount rates, the most likely cash flows are also considered in the analysis, including assumed prepayment dates. The analysis presented assumes that all other factors remain unchanged, the changes listed below would result in the following effects on our investment values.

  [Month], 2024

Change in Discount Rates  Projected Increase (Decrease) in Investment Value  Percentage Change in Projected Investment Value

1.00% increase  $[__]  [__]%

1.00% decrease  $[__]  [__]%

We would be happy to provide any additional information that might assist you in connection with this matter. Please feel free to contact Robert Bergdolt at DLA Piper LLP (US) by email at robert.bergdolt@us.dlapiper.com or by phone at (919) 786-2002 with any questions or additional comments.

Very truly yours,

Goldman Sachs Real Estate Finance Trust Inc

By: /s/ Mallika Sinha

 Name: Mallika Sinha

 Title: Chief Financial Officer

cc: Robert Bergdolt, Esq., DLA Piper LLP (US)

 Laura Sirianni, Esq., DLA Piper LLP (US)