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    Chicago

    New York

    Washington, DC

    London

    San Francisco

    Los Angeles

    Singapore

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    Miami

    vedderprice.com

    Nathaniel Segal

    Shareholder

    +1 312 609 7747

    nsegal@vedderprice.com

August 11, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Investment Management

100 F Street, NE

Washington, D.C. 20549

    Attn:
    Mr. Raymond A. Be, Attorney-Adviser

    Division of Investment Management

 Re: Origin Real Estate Credit Fund (formerly, Origin Real Estate Credit Interval Fund)

Registration Statement on Form N-2

File Nos. 333-287135, 811-24089

Dear Mr. Be,

On behalf of Origin Real Estate Credit Fund (formerly,
Origin Real Estate Credit Interval Fund) (“Registrant” or the “Fund”), this letter responds to the comments received
by email from the staff of the Division of Investment Management (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission” or “SEC”), in a letter dated June 13, 2025 and addressed to Michael McVickar, General Counsel,
Origin Investments, relating to the Staff’s review of the above-referenced registration statement originally filed with the Commission
on May 9, 2025, pursuant to the Securities Act of 1933, as amended (the “Securities Act”), and the Investment Company Act
of 1940, as amended (the “1940 Act”) (the “Registration Statement”), through the Commission’s electronic
data gathering, analysis and retrieval (“EDGAR”) system.

For convenience of reference, the comments of
the Staff have been reproduced herein and are accompanied by corresponding Registrant responses. Registrant notes that its responses are
also reflected, to the extent applicable, in Pre-Effective Amendment No. 1 to the Registration Statement, filed on or about August 11,
2025 (the “Amendment”). Unless otherwise noted, capitalized terms have the same meaning as contained in the Amendment.

General

1.            Comment: We note that portions of the filing, including the Fund’s financial statements, are incomplete. A full financial
review (e.g., seed financial statements, auditor’s report, consent) must be performed prior to declaring the registration statement
effective. We may have additional comments on such portions when you complete them in a pre-effective amendment, or disclosures made
in response to this letter, on information supplied supplementally, or on exhibits added in any amendments.

Response: Registrant acknowledges
the Staff’s comment and confirms that incomplete portions of the Registration Statement will be completed and updated in a subsequent
pre-effective amendment. Specifically, with respect to the financial statements, Registrant expects to include them in Pre-Effective Amendment No. 2 to the Registration
Statement, which Registrant intends on filing within the next week.

222 North LaSalle
Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005

Vedder
Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California,
Vedder Price Pte. Ltd., which operates in Singapore and Vedder Price (FL), LLP, which operates in Florida.

Mr. Raymond A. Be

Division of Investment Management

Securities and Exchange Commission

August 11, 2025

Page 2

2.            Comment:
Please supplementally explain the status of any exemptive relief or no-action request submitted, or expected to be submitted, in connection
with the registration statement, including the applications for multi-class relief and co-investment relief referenced in the filing.

Response:
Registrant notes that concurrent with the filing of the Registration Statement on May 9, 2025, it filed an application seeking an order
from the Commission to permit the Fund to issue multiple classes of shares of beneficial interest with asset-based service and/or distribution
fees and to impose early withdrawal charges (“Multi-Class Relief”). On May 23, 2025, we provided the Staff—specifically,
Erin Loomis Moore and Matthew Cook of the Chief Counsel’s Office—with a requested blackline of the application against relevant
precedent. Because Origin Credit Advisers, LLC (“OCA” or the “Adviser”), the Fund’s investment adviser,
was unable to obtain EDGAR codes to enable it to be identified as a co-applicant with the Fund’s May 9, 2025 Multi-Class Relief
application, an amended application for Multi-Class Relief was filed on June 4, 2025, solely for the purpose of adding the Adviser as
a co-applicant. On August 4, 2025, Registrant received comments from Ms. Moore and Mr. Cook on its amended application for Multi-Class
Relief. Registrant intends on filing a further amended application for Multi-Class Relief concurrent with its pre-effective amendment
filing or shortly thereafter.

Separately, Registrant
continues to evaluate the desirability and feasibility of filing an application seeking an order from the Commission with respect to co-investment
relief.

Registrant does not
believe that any other exemptive relief or any no-action request is necessary to launch and operate the Fund, and offer its shares, in
compliance with the Federal securities laws.

3.            Comment:
Section 8(c) of the Securities Act relates to post-effective amendments. Please remove the check from the box next to “when declared
effective pursuant to Section 8(c).”

Response: Registrant notes
that the box was checked inadvertently and the check has been removed.

 Prospectus

Cover page

4.            Comment:
The Fund’s 80% policy suggests that it will primarily invest in loans on multifamily residential properties, recognizing that
the policy includes “other real estate-related investments.” However, much of the focus of the discussion that follows
relates to the “other real estate-related investments,” including commercial real estate as well as other commercial
loans (e.g., mezzanine debt, etc.). If the Fund intends to primarily invest in multifamily real estate loans, revise the disclosure
to describe multifamily loans more prominently and completely (including risks) or clarify how they fit within the current
disclosure. If multifamily real estate investments are not expected to be more significant than “other real estate-related
investments,” consider revising the 80% policy to place less prominence on multifamily real estate loans.

Response: Registrant has
reworked the description of its principal investment strategies and revised the 80% policy for clarity in light of the Staff’s comments,
both the above-noted comment 4 as well as comment 5 below (regarding “will originate, invest and manage…”). Please refer
to the revised prospectus, including the cover page and page 2, included with the Amendment.

Mr. Raymond A. Be

Division of Investment Management

Securities and Exchange Commission

August 11, 2025

Page 3

5.            Comment:
In your 80% policy you state the Fund will “originate, invest and manage … in a portfolio of multifamily real estate loans
and other real estate-related investments.” In the Summary, please clarify what you mean by “originate, invest and manage”
and discuss the Adviser’s capabilities and experience originating and managing real estate loans and investments, including its
experience and intentions with respect to under- or non-performing loans and investments.

In addition, please ensure your
Summary disclosure addresses other relevant investment considerations such as:

 · What you mean by “multifamily”,

 · Anticipated loan sizes,

 · Whether loans will be collateralized (first-lien, second, etc.),

 · Whether you will lend to new projects or existing/occupied properties
only,

 · The types of data, metrics, analyses, and investment factors you consider when making investment decisions
and monitoring and valuing existing investments.

Response: Please
refer to Registrant’s response to comment 4 above, as reflected in the Amendment, which includes the revised 80% policy,
removing reference to “originate, invest and manage,” as well as revised disclosure clarifying what is meant by
“multifamily.” Registrant’s revised description of its investment program clarifies that loans eligible for
investment include both senior mortgage loans, subordinated mortgage loans and various other types of debt investments, whether
secured or unsecured. In this respect, Registrant directs the Staff’s attention to the revised disclosure regarding
sub-categories of investments within the Fund’s primary asset classes, including, in particular, the disclosure under
“Direct Lending Opportunities,” which addresses anticipated loan sizes and ability to lend to new or existing
properties. Additionally, the revised disclosure specifically addresses the range of loans in which the Fund may invest, including
second and lower lien loans as well as unsecured loans.

With respect to the Staff’s comment regarding the types of data relied
upon by the Adviser, Registrant directs the Staff’s attention to inclusion of disclosure under the sub-header
“Investment Process,” under the header “INVESTMENT OBJECTIVES, POLICIES AND STRATEGIES,” in
the body of the prospectus (pages 49-50). As to the Staff’s comment concerning the Adviser’s capabilities and experience
originating and managing real estate loans and investment, Registrant notes the inclusion of additional disclosure under the
sub-header “Adviser Capabilities” in the Prospectus Summary, and under the revised sub-header “Market
Opportunity and Adviser Capabilities” in the body of the prospectus (page 39).

Mr. Raymond A. Be

Division of Investment Management

Securities and Exchange Commission

August 11, 2025

Page 4

6.            Comment:
The disclosure under the caption “Leverage” states that the Fund may use leverage to enhance returns. Supplementally advise
in further detail the anticipated amount and timing of such leverage. To the extent the Fund intends to obtain such leverage in the first
year, ensure the estimated cost is reflected in the fee table.

Response: Registrant notes
that, as disclosed under the caption “Leverage,” the Fund primarily intends to enter into financing transactions using
reverse repurchase agreements; relatedly, for clarity, Registrant has changed references from “may use” to “will use.” For the Staff’s information, Registrant expects the Fund to use such financing transactions to the
maximum amount permissible (i.e., up to 33⅓% of the Fund’s total assets, including the assets subject to, and obtained with
the proceeds of, such indebtedness, immediately after entering into any type of financing transaction) and expects to do so in conjunction
with the Fund’s inception. The Fund does not intend to issue preferred shares or convertible securities in the first 12 months following
effectiveness of the registration statement. Registrant confirms that the estimated cost of leverage is reflected in the fee table, as
revised.

7.            Comment:
We note that the Fund will be seeded via predecessor funds/accounts. Please supplementally advise as to any prior staff guidance, including
no-action letters, that the Fund intends to rely on in order to (1) effect the formation transactions contemplated to create the Fund
and (2) present prior performance of any of the predecessor funds, if the Fund intends to do so. Please discuss the basis for the Fund’s
belief that such guidance is applicable.

Response:

(1) Formation Transactions and SEC
Staff Guidance

As disclosed in the prospectus,
prior to the commencement of the Fund’s operations, each of Origin Multifamily Credit Fund, LLC (“MCF”) and Origin
Strategic Credit Fund, LLC (“SCF,” and together with MCF, the “Predecessor Funds”), each a private fund
relying on an exemption from registration under Section 3(c)(7) of the Investment Company Act, will reorganize with and transfer all
of their portfolio securities into the Fund and the Predecessor Funds will cease operations (the “Reorganization”). The
Fund and the Predecessor Funds intend on effecting the Reorganization in accordance with the conditions set forth in GuideStone
Financial, et al., SEC No-Action Letter (pub. avail. December 27, 2006) (“GuideStone”). In GuideStone,
the Staff provided no-action relief from Section 17(a)(1) of the Investment Company Act with respect to the transfer by each of
several unregistered funds exempt from registration as investment companies pursuant to Section 3(c) of the Investment Company Act
(each, an “Unregistered Fund”) of all of its assets to a corresponding, newly created series of an affiliated investment
company registered under the Investment Company Act (a “Corresponding Fund”) in exchange for shares of the Corresponding
Fund. Each Unregistered Fund and its Corresponding Fund may have been deemed to be affiliates because they may have been deemed to
be under the common control of GuideStone Financial Resources of the Southern Baptist Convention.

Mr. Raymond A. Be

Division of Investment Management

Securities and Exchange Commission

August 11, 2025

Page 5

With respect to Registrant, each of
SCF and MCF is managed by its respective managing member which, in turn, delegated investment management responsibilities and decisions
to OCA, a Delaware limited liability company and SEC-registered investment adviser, as implemented by Thomas Briney, President and Chief
Investment Officer of OCA. OCA will serve as investment adviser to the Fund and Mr. Briney will serve as the Fund’s portfolio manager.
Similar to the circumstances in GuideStone, each of the Fund, MCF and SCF may be deemed to be affiliates because they may be deemed
to be under the common control of OCA. As noted above, the Reorganization will be effected in accordance with the conditions of and circumstances
described in GuideStone.

Specifically, the Fund will be acquiring
all of the assets of the Predecessor Funds pursuant to an Agreement and Plan of Merger (the “Plan”). The Plan provides that
the Reorganization will comply with the terms of paragraphs (b), (c), (d), (e), (f) and (g) of Rule 17a7 under the Investment Company
Act and the provision of Rule 17a-8 under the Investment Company Act (as these provisions apply to a merger between unregistered funds
that are eligible to rely on that rule and a registered investment company), in accordance with the Staff’s position in GuideStone.
Consistent with the requirements set forth in GuideStone:

a.            The
Fund will be a shell portfolio at the time of the Reorganization;

b.             The
assets of each of the Predecessor Funds will consist of securities that are appropriate, in type and amount for investment by the Fund
in light of its investment objectives and policies;

c.             The
Predecessor Funds will transfer all of their portfolio securities at the time of the Reorganization to the Fund;

d.             The
Fund has the same procedures for determining net asset value as the Predecessor Funds and will follow those procedures in determining
the amount of shares to be issued in the Reorganization.

Mr. Raymond A. Be

Division of Investment Management

Securities and Exchange Commission

August 11, 2025

Page 6

e.            The
Reorganization will proceed in a sequential matter and, in the final stage of its implementation, the assets of each Predecessor
Fund shall vest in and be acquired by the Fund and the securities issued by the Predecessor Funds will be converted into a number of
newly issued shares of the Fund, which shall be received by the investors of the Predecessor Funds simultaneously;

f.            The
Fund will comply with the recordkeeping requirements described in GuideStone;

g.            OCA,
consistent with its fiduciary duties, has disclosed to the Independent Trustees of the Fund the existence of, and all the material facts
relating to, any conflicts of interest between the Adviser and the Fund with regard to the Reorganization to facilitate the ability of
the Independent T