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 CLIFFORD CHANCE US LLP

 TWO MANHATTAN WEST

 375 9TH AVENUE

 NEW YORK, NY 10001-1696

 TEL +1 212 878 8000

 FAX +1 212 878 8375

 www.cliffordchance.com

 July 16, 2025

 VIA EDGAR

 Mr. David Link

 Ms. Mary Beth Breslin

 United States Securities
and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, D.C. 20549-0404

 Re:

 CNL Strategic Residential Credit,
Inc.

 Registration Statement on Form 10-12G

 Filed on June 2, 2025

 File No. 000-56755

 Responses to Staff comments made
by letter dated June 27, 2025

 Dear Mr. Link and Ms. Breslin:

 On behalf of our client,
CNL Strategic Residential Credit, Inc. (the " Company "), set forth below are the responses of the Company to the comments
made by the staff (the " Staff ") of the Securities and Exchange Commission (the " SEC ") by letter
dated June 27, 2025 (the " Comment Letter ") in connection with the Company's Registration Statement on Form 10-12G
(the " Registration Statement "), which was filed on June 2, 2025. Concurrently with the filing of this response letter,
the Company is filing the Amendment No. 1 to the Registration Statement (the " Amended Registration Statement "). The
Amended Registration Statement has been updated in response to the Staff's comments made in the Comment Letter.

 The Company's responses
to the Staff's comments contained in the Comment Letter are set out in the order in which the comments were set out in the Comment
Letter and are numbered accordingly. Unless otherwise indicated, all page references in the responses below are to the pages of a marked
copy of the Amended Registration Statement, which was submitted today by the Company via EDGAR, reflecting all changes made to the Amended
Registration Statement, unless otherwise specified. Defined terms used herein but not otherwise defined have the meanings ascribed to
them in the Registration Statement.

 Form 10-12G filed on June 2, 2025

 Share Repurchase Plan, page 27

 1. We note your disclosure on pages 27-28 and 125 that you will use periodic NAV pricing for both your
offerings and share repurchase plan. Please clarify both discussions how you will communicate the prior period's NAV for the various
classes of shares. Further, in the event of adjustments to the offering price prior to acceptance of subscriptions, please clarify how
investors can check for an adjusted offering price prior to the closing date of their subscription.

 CLIFFORD CHANCE US LLP Mr. David Link Ms. Mary Beth Breslin United States Securities and Exchange Commission July 16, 2025 Page 2

 In response to the Staff's comment,
the Company has revised the disclosure on pages 27-28 and 125 of the Amended Registration Statement to clarify that (1) the Company will
file a current report on Form 8-K with the SEC disclosing the prior month's NAV per share and the current offering price for each
class of the Company's shares, which report will be incorporated by reference into the Company's confidential offering memorandum
(the " Offering Memorandum ") for its continuous private offering (the " private offering ") of shares
of its common stock, and (2) in the event of adjustments to the offering price prior to acceptance of subscriptions, investors can check
the Company's filings with the SEC, which will be available on the website of the SEC, or call the Company by telephone for an
adjusted offering price prior to the closing date of their subscription.

 See also Ares Real Estate Income Trust
Inc. (File No. 000-52596) and Ares Industrial Real Estate Income Trust Inc. (File No. 000-56032) for registrants that also file current
reports on Form 8-K with the SEC to disclose the prior month's NAV per share and the current transaction price for each share class
in connection with their private offerings.

 2.

 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 program 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 program 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.

 The Company acknowledges that it is responsible
for analyzing the applicability of the tender offer rules, including Rule 13e-4 and Regulation 14E under the Securities Exchange Act of
1934, as amended (the " Exchange Act "), to its share repurchase plan. The Company believes that its share repurchase
plan is consistent with the relief granted by the Division of Corporation Finance in prior no-action letters and the share repurchase
plan of CNL Strategic Capital, LLC (IPO Registration No. 333-222986) (" CNL SCAP "), which was reviewed by the Staff
in connection with CNL SCAP's initial public offering.

 CNL SCAP, which is managed by an affiliate
of the Company's external advisor, filed a registration statement on Form S-1 for its initial public offering, which was declared
effective on March 7, 2018. During the SEC comment process for CNL SCAP's initial public offering, the Staff requested
CNL SCAP to explain how CNL

 CLIFFORD CHANCE US LLP Mr. David Link Ms. Mary Beth Breslin United States Securities and Exchange Commission July 16, 2025 Page 3

 SCAP's share repurchase program
fits within the existing no action relief granted to other issuers by the Division of Corporation Finance in connection with Rule 13e-4
and Regulation 14E. The Company illustrated how CNL SCAP's share repurchase program was consistent with the existing relief using
a table summarizing the key features highlighted in such existing relief and comparing such features of CNL SCAP's share repurchase
program and the peer programs that CNL SCAP's share repurchase program benchmarked, including Blackstone Real Estate
Income Trust, Inc. (" BREIT "). CNL SCAP confirmed that the Staff did not object to CNL SCAP's share repurchase
program prior to the effectiveness of CNL SCAP's registration statement on Form S-1 for its initial public offering.

 Similarly, set forth below is a table
comparing the key features underlying the existing relief granted by the Division of Corporate Finance, in particular the relief granted
to BREIT in the Staff's no-action letter dated September 12, 2016, and CNL SCAP's share purchase program compared to the Company's
share repurchase plan. As shown below, the Company's share purchase plan contains substantially each of the key features specified
in the relief granted to BREIT or included in CNL SCAP's share repurchase program.

 Key Features of Share Repurchase Plan
 BREIT
 CNL SCAP
 The Company

 All
 material information relating to the share repurchase plan will be fully and timely disclosed to all stockholders. The terms of the
 share repurchase plan will be fully disclosed in the Offering Memorandum, 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 share repurchase plan other than through the Offering Memorandum and the documents incorporated by reference therein disclosing the transaction price and NAV per share of each class of the Company's shares. Stockholders 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 share repurchase plan will be ministerial.
 Yes
 Yes
 Yes

 1 We note that each of BREIT and CNL SCAP relates to a continuous public offering of shares of common stock and limited liability company interests, respectively, registered under the Securities Act of 1933, as amended (the "Securities Act") and, accordingly, disclosed the terms of their respective program in a prospectus, while the Company intends to conduct a private offering. The Company will provide substantially the same disclosure in the Offering Memorandum relating to the private offering. The Company does 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).

 CLIFFORD CHANCE US LLP Mr. David Link Ms. Mary Beth Breslin United States Securities and Exchange Commission July 16, 2025 Page 4

 Key Features of Share Repurchase Plan
 BREIT
 CNL SCAP
 The Company

 Shares
 will be repurchased quarterly under the share repurchase plan at a price which will generally be equal to the NAV per share for the
 applicable class of shares as of the last date of the month immediately prior to the repurchase date, and the Company will provide
 stockholders information by current reports on Form 8-K, which will be incorporated by reference into the Offering Memorandum, 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 share 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 five business days following the last
 business day of the month of a calendar quarter end (the " repurchase date ") and will be the same for all shares
 of the same class repurchased in a given quarter. 3
 Yes
 Yes
 Yes

 Repurchases
 under the share repurchase plan will be limited to up to 2.5% of the Company's aggregate NAV per calendar quarter (based on
 the aggregate NAV as of the last date of the month immediately prior to the repurchase date) and up to 10.0% of the Company's
 aggregate NAV per year (based on the average aggregate NAV as of the end of each of the Company's trailing four quarters). 4
 Yes
 Yes
 Yes

 2 While BREIT refers to a monthly repurchase program, the Company's share repurchase plan is consistent with CNL SCAP, which provides for quarterly repurchases. While BREIT 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 or otherwise disclose to all stockholders, including by means of the Company's website, the applicable repurchase price to ensure each stockholder receives on a quarterly basis substantially the same information that would otherwise be included in the Company's prospectus supplement if it was undertaking a registered offering under the Securities Act. Similar to CNL SCAP, in the unlikely event the repurchase price for the applicable quarter is not made available by the tenth business day prior to the last business day of such quarter, then the Company may, in its sole discretion, extend the repurchase date into the immediately subsequent month to ensure such notice period is satisfied.

 3 See note 2. Additionally, while BREIT discloses that the repurchase price normally will be paid in cash
within three business days following the last calendar day of the applicable month, the Company will generally pay the repurchase price
within five business days after the repurchase date, which is consistent with CNL SCAP.

 4 The BREIT program provided for a 2% limitation in any calendar month and a 5% limitation for any calendar
quarter, while Company's share repurchase program is consistent with CNL SCAP's share repurchase program, which limits repurchases to
up to a 2.5% of the aggregate NAV per calendar quarter (based on the aggregate NAV as of the last date of the month immediately prior
to the repurchase date) and up to 10.0% of the aggregate NAV per year (based on the average aggregate NAV as of the end of each of our
trailing four quarters).

 CLIFFORD CHANCE US LLP Mr. David Link Ms. Mary Beth Breslin United States Securities and Exchange Commission July 16, 2025 Page 5

 Key Features of Share Repurchase Plan
 BREIT
 CNL SCAP
 The Company

 If
 the quarterly or annual volume limitation is reached in any given quarter or the Company determines to repurchase fewer shares than
 have been requested to be repurchased in any particular quarter, repurchases under the share repurchase plan for such quarter will
 generally be made on a pro rata basis. 5
 Yes
 Yes
 Yes

 Stockholders may withdraw any repurchase request by notifying the Company on the Company's toll-free information line before 4:00 p.m. Eastern time on the last business day of the applicable quarter.
 Yes
 Yes
 Yes

 Material
 modifications, including any reduction to the quarterly or annual limitations on repurchases, and suspensions of the share repurchase
 plan will be made by the Company's board of directors upon 30 days' prior notice to stockholders. 6
 Yes
 Yes
 Yes

 There will be no established regular trading market for the Company's shares. The share repurchase plan will be terminated if the Company's shares are listed on a national securities exchange or included for quotation in a national securities market, or in the event a secondary market for the Company's shares develops.
 Yes
 Yes
 Yes

 The share repurchase plan is intended to remain open indefinitely for the life of the Company unless modified or suspended by the Company's board of directors. The Company is structured as a perpetual-life entity and has no intention to list its shares for trading on an exchange or other trading market.
 Yes
 Yes
 Yes

 The share repurchase plan is open to all stockholders.
 Yes
 Yes
 Yes

 3. Please be advised that you are responsible for analyzing the applicability of Regulation M to your
share repurchase plan. We urge you to consider all the elements of your share repurchase plan in determining whether the program is consistent
with the class relief granted by the Division of Market Regulation in the class exemptive letter granted Alston & Bird LLP dated October
22, 2007. To the extent you have questions as to whether the plan is entirely consistent with that class exemption, you may contact the
Division of Trading and Markets at 202-551-5777.

 5 See note 2. Additionally, the Company has the right to waive the pro rata repurchase requirement in the
event of the death, permanent disability or bankruptcy of a stockholder or other exigent circumstances. See also Goldman Sachs Real Estate
Finance Trust Inc. (repurchasing on a pro rata basis after it has repurchased all shares for which repurchase has been requested due to
death or disability).

 6 While BREIT provides that it will promptly notify stockholders in case of material
modifications and suspensions of its share repurchase program, the Company will provide 30 days' prior notice to stockholders, which
is consistent with CNL SCAP's share repurchase program.

 CLIFFORD CHANCE US LLP Mr. David Link Ms. Mary Beth Breslin United States Securities and Exchange Commission July 16, 2025 Page 6

 The