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CORRESP
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 CORRESP

 Simpson Thacher & Bartlett LLP

 425 L EXINGTON A VENUE
 N EW Y ORK , NY 10017

 TELEPHONE :
 +1-212-455-2000 FACSIMILE : +1-212-455-2502

 Direct Dial Number (212) 455-3974

 E-mail Address
 jonathan.gaines@stblaw.com
 July 11, 2025 Via
EDGAR Emily Rowland Lauren Hamilton
 Securities and Exchange Commission Division of Investment
Management 100 F Street, N.E. Washington, D.C. 20549

 Re:
 Blackstone Private Real Estate Credit and Income Fund
 Registration Statement on Form 10
 File Nos. 000-56726 and 814-01853
 Dear Ms. Rowland and Ms. Hamilton: On
behalf of Blackstone Private Real Estate Credit and Income Fund (the “Fund”), we hereby file this letter with the Securities and Exchange Commission (the “Commission”) in response to oral comments received from (i) the
disclosure staff of the Division of Investment Management (the “Staff”) of the Commission on May 9, 2025, May 13, 2025, May 16, 2025 and May 28, 2025 with respect to the pre-effective
amendment to the registration statement on Form 10 (the “Registration Statement”) filed with the Commission on April 14, 2025 (the “Pre-Effective Amendment”), the comment letter filed
with the Commission on April 8, 2025 (the “Previous Comment Letter”) and the post-effective amendment to the Registration Statement filed with the Commission on May 2, 2025 (the “Post-Effective Amendment”), and (ii) the
accounting Staff on July 8, 2025 with respect to the Post-Effective Amendment. For convenience of reference, the Staff’s comments
have been reproduced herein. Unless otherwise defined below, capitalized terms shall have the meanings given to them in the Pre-Effective Amendment or the Previous Comment Letter. The responses and information
described below are based upon information provided to us by the Fund. The Fund will file a post-effective amendment to the Registration Statement reflecting the changes described herein concurrently with this letter (the “Future
Amendment”). Disclosure Staff Comments
 Pre-Effective Amendment

 1.
 With respect to the Fund’s response to Comment 7 in the Previous Comment Letter, the Staff notes that
the Fund added risk disclosure regarding net leased commercial properties. If net leased commercial properties are part of the Fund’s principal investment strategies, please add corresponding strategy disclosure.

 Securities and Exchange Commission

 July 11, 2025
 Response : The Fund will revise “Global Lending” under “Item 1.
Business—Investment Strategy” in the Future Amendment as follows: Global Lending : BREC intends to originate and acquire
loans across the spectrum of commercial and residential real estate, including senior loans, B-Notes, mezzanine loans and other investments (such as preferred equity) that are subordinated or otherwise junior
in the capital structure that involve privately negotiated structures. The underlying assets for these investments will include commercial and residential properties in various stages of their business plan, including properties in transition. BREC also may make investments in commercial properties subject to net leases.

 2.
 With respect to the Fund’s revised 80% policy:

 a.
 Please consider revising the 80% policy as follows:
 “Under normal circumstances, we will invest directly or indirectly at least 80% of our assets ( net assets plus borrowings for investment purposes ) in private real estate investment (loans, debt securities, preferred stock) and other investments that are expected to (i) make regular distributions, dividends,
interest, rent or other similar types of payments and (ii) generate returns primarily from income (including investments in leased assets that meet these criteria), in each case, that are offered privately or are investments in private
companies.” Response : The Fund respectfully acknowledges the Staff’s comment. However, the Fund believes the current
formulation of the Fund’s 80% policy is appropriate.

 b.
 Please confirm whether and disclose to what extent the “other investments” will be in publicly
offered investments or public companies. Response : The Fund hereby confirms that the reference to “other
investments” in the Fund’s 80% policy is qualified by “in each case, that are offered privately or are investments in private companies” at the end of the 80% policy. Accordingly, other investments that are included in the 80%
policy will be either privately placed investments in public companies or in private companies.

 c.
 Please revise the disclosure relating to the Fund’s 80% policy in the Registration Statement to reflect
the following information, which was provided by the Fund in the response to Comment 8 in the Previous Comment Letter:
 In addition, the Fund hereby confirms that unfunded commitments will not count towards the Fund’s 80% policy. The Fund may consider
equity investments to count towards the Fund’s 80% policy to the extent they meet the criteria for income-focused investments set forth above. Additionally, the Fund will consider residual tranche (which may be characterized as
“equity”) investments in
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 July 11, 2025

structured finance vehicles collateralized by real estate private credit instruments, including CMBS, as counting towards its 80% policy. In this respect, the Fund views an investment in the
residual tranche to be consistent with exposure to the underlying private real estate credit instruments and, accordingly, counted towards the Fund’s 80% policy.
 Response : The Fund will add the following disclosure in the Future Amendment following the disclosure regarding the Fund’s 80%
policy under “Item 1. Business”: The Fund may consider equity investments to count towards the Fund’s aforementioned 80%
policy to the extent they meet the criteria for income-focused investments in its 80% policy. Additionally, the Fund views residual tranche (which may be characterized as “equity”) investments in structured finance vehicles collateralized
by real estate private credit instruments, including commercial MBS (“CMBS”), as consistent with exposure to the underlying private real estate credit instruments; accordingly, the Fund will consider such residual tranche investments as
counting towards its 80% policy.

 3.
 With respect to the response to Comment 19 in the Prior Comment Letter, please remove the following sentence
at the end of the first paragraph of the risk factor beginning with “An investment in our common shares will have limited liquidity . . .”: “Additionally, shareholders who participate in repurchase offer must do so without knowledge
of what the repurchase price of our common shares will be on the repurchase date.” Response : The Fund
respectfully submits that the referenced disclosure is meant to inform investors of the potential risks associated with the Fund’s share repurchase program as it relates to the Fund’s limited liquidity and risks associated with the tender
offer process and is not intended to be an announcement of future tender offers. Nevertheless, the Fund has removed the referenced disclosure in response to the Staff’s comment.

 4.
 With respect to any Subsidiary:

 a.
 Please revise the following sentence in the last paragraph of “Item 1A. Risk Factors—Risks Related
to the Fund’s Investments—We are subject to risks associated with investing through Subsidiaries” to state that the Fund will treat a Subsidiary’s debt as its own: “We will comply with Section 61 of the
1940 Act, governing investment policies, capital structure and leverage, on an aggregate basis with any Subsidiary.”
 Response : The Fund will revise the disclosure in the Future Amendment as follows:
 We will comply with Section 61 of the 1940 Act, governing investment policies, capital structure and leverage, on an aggregate basis with
any Subsidiary and, accordingly, will treat any Subsidiary’s debt as our own for purposes of Section 61 of the 1940 Act .

 b.
 Please identify and disclose the custodian of the Subsidiary.
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 Securities and Exchange Commission

 July 11, 2025
 Response : The Fund will revise the disclosure in the Future Amendment to note that the
custodians of the Subsidiaries currently are U.S. Bank National Association and The Bank of New York Mellon.

 c.
 Please supplementally explain why the Fund has not added the disclosure requested in Comment 23.d in the
Previous Comment Letter. Response : The Fund respectfully notes that, although its response to Comment 23.d in
the Previous Comment Letter indicates that it did not believe additional disclosure was required, the Fund did nonetheless add the following disclosure, which the Fund believes addresses the comment:
 We do not expect that any Subsidiary will be required to register as an investment company under the 1940 Act. We expect that any investment
advice provided by an investment adviser to our Subsidiary would be provided by our Adviser, and our Board of Trustees will consider any investment advisory services provided to a Subsidiary in connection with the Board of Trustees’ annual
consideration of our investment advisory agreement. Any investment advisory agreement for a Subsidiary will comply with Section 15 of the 1940 Act, including that (i) such investment advisory agreement will be approved by the Board of
Trustees and (ii) such investment advisory agreement between the Subsidiary and its investment adviser will be filed as an exhibit to our public filings.

 5.
 The Staff notes that the Fund included additional disclosure regarding horizontal risk retention tranches
(“HRRs”) under “Item 1A. Risks Related to the Company’s Investments – Certain risks associated with CMBS may adversely affect our results of operations and financial condition.” If HRRs are part of the Fund’s
principal investment strategies, please add corresponding strategy disclosure. Response : The Fund will
revise “Real Estate Securities” under “Item 1. Business—Investment Strategy” in the Future Amendment as follows:
 Real Estate Securities : BREC will seek to invest in liquid real estate-related debt, primarily CMBS (including horizontal risk retention tranches (“HRRs”)) but also RMBS and commercial real estate CLOs. BREC’s
investments in securities will add access to a wider array of asset and credit profiles (from investment grade to below investment grade), while also allowing BREC to capitalize during periods when public market securities prices diverge from
underlying collateral value.

 6.
 Under “Item 11. Description of Registrant’s Securities to be Registered—Delaware Law and
Certain Declaration of Trust Provisions—Derivative Actions”:

 a.
 In the last sentence of the first paragraph, rather than referring to Declaration of Trust for the
“certain percentage” of holders required to join a derivative action brought by a shareholder against the Fund, please state the required percentage in the disclosure itself.
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 Securities and Exchange Commission

 July 11, 2025
 Response : The Fund will revise the disclosure in the Future Amendment as follows:
 No shareholder may maintain a derivative action on behalf of the Company unless holders of a certain at least ten
percent age
 (10%) of the then outstanding common shares, as disclosed in our described in the Declaration of Trust, join in the bringing of such action.

 b.
 In the following disclosure in the second paragraph regarding an undertaking by shareholders bringing a
request for a derivative action to reimburse the Fund, please change the word “may” to “shall” to align with the Fund’s Declaration of Trust: “ . . . and the Board of Trustees shall be entitled to retain counsel and
other advisers in considering the merits of the request and may require an undertaking by the shareholders making such request to reimburse the Company for the expense of any such counsel and Advisers in the event that the Board
of Trustees determines not to bring such action.” (emphasis added). Response : The Fund will make the
requested change in the Future Amendment.

 7.
 The Staff notes that Note 6 in the Notes to the Financial Statements states that the Fund will not be
obligated to reimburse the investment adviser for the Fund’s expenses until it has completed its first sale of shares in its private offering, and that the total organization, offering and other costs incurred through
April 1, 2025 were $2,227,331. Please provide an analysis as to why no accrual for such expenses is required under ASC 450. Further, the Fund should consider including a footnote to the Statement of Assets and Liabilities
describing the nature and amount of the commitment and contingent liability in accordance with ASC 450.
 Response : The Fund applies the accounting guidance of ASC 450, Contingencies. Disclosure of Certain Loss Contingencies, when evaluating
whether the contingent obligation to repay the Adviser for expenses incurred on behalf of the Fund, should be recognized in the Fund’s financial statements. Pursuant to ASC 450-20-25-2, a contingent liability should be recognized when both (1) it is probable that a loss has been incurred and (2) the amount of the loss is reasonably estimable. ASC 450-20-20 defines “probable” as “the future event or events are likely to occur,” which is generally considered a 75% threshold.
 The Fund executed an Expense Support and Conditional Reimbursement Agreement (the “Expense Support Agreement”), pursuant to which the
Adviser agrees to bear all expenses of the Fund until the Fund completes its first sale of shares in its private offering. As of April 1, 2025, the Fund determined that it was reasonably possible, but not sufficiently probable that the Fund
would complete its first sale of shares in its private offering. As such, pursuant to the guidance of ASC 450, the expenses incurred through April 1, 2025 have not been recognized in the Statement of Assets and Liabilities and are disclosed in
the Notes to the Financial Statements. The Fund respectfully acknowledges the Staff’s comment with regard to the inclusion of a
footnote to the Statement of Assets and Liabilities describing the nature and amount of the commitment and contingent liability in accordance with ASC 450, however the Fund believes the reference to Note 6 in the Statement of Assets and Liabilities
to be clear to the users of the financial statements, and is consistent with market practice for such disclosures. Post-Effective Amendment

 8.
 Please supplementally explain the rationale for the Adviser not charging the Fund any advisory
fees. Please also explain to the Staff how this Fund will be used in the Blackstone family of funds .
 Response: As discussed with the Staff on May 28, 2025, the Fund is designed primarily to provide exposure to a real estate debt strategy to
investment vehicles, accounts and programs (collectively, “investors”) where fees are otherwise paid to Blackstone. Given that Blackstone anticipates receiving separate fees with respect to such investors, the Adviser believes, and the
Board of the Fund determined, it is fair and reasonable to not charge any management fee or incentive fee to the Fund. Within the Blackstone family of funds, certain Blackstone-advised funds may invest in the Fund to gain exposure to real estate
debt within their overall investment program; for example, Blackstone Private Multi-Asset Credit and Income Fund, a multi-asset credit interval fund managed by Blackstone Credit & Insurance (“BXCI”), and Blackstone Private Credit Fund,
a non-traded business development company also managed by BXCI, have invested in the Fund in reliance on Rule 12d1-4. As noted to the
Staff, the Fund is aware of numerous examples of registered funds that do not charge advisory fees because fees are charged to investors outside of the fund. For example, certain funds, including those listed below, that are held through wrap fee
programs do not charge a management fee where the participants in these programs pay a wrap fee to the sponsor of the progra