SecProbe.io

CORRESP
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CORRESP

 March 27, 2026

VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of Real
Estate & Construction

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Cantor Fitzgerald Income Trust, Inc. (the “Company”)

Registration Statement on Form S-11 (File
No. 333-294576) (the “Registration Statement”)

 Acceleration Request

 Requested Date: Monday, March 30, 2026

Requested Time: 3:30 p.m. Eastern Time

Dear Ladies and Gentlemen:

 On behalf of the several
underwriters of the Company’s proposed public offering, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), we hereby join in the Company’s request that the effective date of the
above-referenced Registration Statement be accelerated so that the above-referenced Registration Statement will be declared effective at 3:30 p.m., Eastern Time, on March 30, 2026, or as soon as practicable thereafter, or at such later time as
the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”).

Pursuant to Rule 460 of the General Rules and Regulations of the Commission under the Act, please be advised that there will be distributed to each
underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure the adequate distribution of the preliminary
prospectus.

 The undersigned advises that it has complied and will continue to comply, and that it has been informed by the participating underwriters and
dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,

CANTOR FITZGERALD & CO.

As representative of the several underwriters

 /s/ Beau Bohm

Name: Beau Bohm

Title: Managing Director, Global Co-Head of Equity Capital Markets

CORRESP
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CORRESP

 March 27, 2026

VIA EDGAR

 U.S. Securities and
Exchange Commission

 Division of Corporation Finance

100 F Street, NE

 Washington, DC 20549

Re:
 Cantor Fitzgerald Income Trust, Inc.

Request for Acceleration of Effectiveness

File No. 333-294576

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Cantor Fitzgerald Income Trust, Inc. (the “Company”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) accelerate the effective date of
its Registration Statement on Form S-11 (File No. 333-294576) (the “Registration Statement”) and declare the Registration Statement effective as of 3:30
p.m. Eastern Time on March 30, 2026, or as soon thereafter as practicable, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Commission (the
“Staff”).

 If you have any questions regarding this request, please contact Michael J. Kessler of Alston & Bird LLP,
counsel to the Company, at (212) 210-9566. The Company respectfully requests that such effectiveness be orally confirmed by calling Mr. Kessler at (212) 210-9566
and that such effectiveness also be confirmed in writing.

 [Signature Page Follows]

Sincerely,

CANTOR FITZGERALD INCOME TRUST, INC.

By:

 /s/ Chris Milner

Name:

Chris Milner

Title:

President

cc:

 Michael J. Kessler, Alston & Bird LLP

Lindsey Magaro, Alston & Bird LLP

 [Signature Page to
Acceleration Request]

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CORRESP

 March 24, 2026

VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 Office of Real
Estate & Construction

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Cantor Fitzgerald Income Trust, Inc. (the “Company”)

Registration
 Statement on Form S-11 (File
No. 333-294576) (the “Registration Statement”)

Acceleration
 Request

Requested
 Date: Thursday, March 26, 2026

Requested
 Time: 3:30 p.m. Eastern Time

Dear Ladies and Gentlemen:

 On behalf of the several
underwriters of the Company’s proposed public offering, and pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), we hereby join in the Company’s request that the effective date of the
above-referenced Registration Statement be accelerated so that the above-referenced Registration Statement will be declared effective at 3:30 p.m., Eastern Time, on March 26, 2026, or as soon as practicable thereafter, or at such later time as
the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”).

Pursuant to Rule 460 of the General Rules and Regulations of the Commission under the Act, please be advised that there will be distributed to each
underwriter or dealer, who is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure the adequate distribution of the preliminary
prospectus.

 The undersigned advises that it has complied and will continue to comply, and that it has been informed by the participating underwriters and
dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,

CANTOR FITZGERALD & CO.

As representative of the several underwriters

 /s/ Beau Bohm

Name: Beau Bohm

Title: Managing Director

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CORRESP

 March 24, 2026

VIA EDGAR

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

Re:
 Cantor Fitzgerald Income Trust, Inc.

Request for Acceleration of Effectiveness

File No. 333-294576

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Cantor Fitzgerald Income Trust, Inc. (the “Company”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) accelerate the effective date of its
Registration Statement on Form S-11 (File No. 333-294576) (the “Registration Statement”) and declare the Registration Statement effective as of 3:30
p.m. Eastern Time on March 26, 2026, or as soon thereafter as practicable, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Commission (the
“Staff”).

 If you have any questions regarding this request, please contact Michael J. Kessler of Alston & Bird LLP,
counsel to the Company, at (212) 210-9566. The Company respectfully requests that such effectiveness be orally confirmed by calling Mr. Kessler at (212) 210-9566
and that such effectiveness also be confirmed in writing.

 [Signature Page Follows]

Sincerely,

CANTOR FITZGERALD INCOME TRUST, INC.

By:

 /s/ Chris Milner

Name:

Chris Milner

Title:

President

cc:
 Michael J. Kessler, Alston & Bird LLP

Lindsey Magaro, Alston & Bird LLP

 [Signature Page to
Acceleration Request]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 24, 2026

William Ferri
Chief Executive Officer
Cantor Fitzgerald Income Trust, Inc.
110 E. 59th Street
New York, NY 10022

 Re: Cantor Fitzgerald Income Trust, Inc.
 Draft Registration Statement on Form S-11
 Submitted February 17, 2026
 CIK No. 0001666244
Dear William Ferri:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement and
non-public draft
submission on EDGAR at least two business days prior to the requested effective
date and time.
Please refer to Rules 460 and 461 regarding requests for acceleration. We
remind you that the
company and its management are responsible for the accuracy and adequacy of
their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Please contact Catherine De Lorenzo at 202-551-3772 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
cc: Michael Kessler, Esq.
</TEXT>
</DOCUMENT>

July 5, 2024
Mr. Paul Pion
Chief Financial Officer
Cantor Fitzgerald Income Trust, Inc.
110 E. 59th Street
New York, NY 10022
Re:Cantor Fitzgerald Income Trust, Inc.
Form 10-K For the Fiscal Year Ending December 31, 2023
File No. 000-56043
Dear Mr. Paul Pion:
            We have completed our review of your filing. We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Yuta Delarck

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CORRESP

 July 3, 2024

Securities and Exchange Commission

 Office of Real
Estate & Construction

 Division of Corporation Finance

100 F Street NE

 Washington, D.C. 20549-3561

Re:
 Cantor Fitzgerald Income Trust, Inc.

Form 10-K For the Fiscal Year Ending December 31, 2023

File No. 000-56043

Dear Ms. Kim:

 On behalf of our client,
Cantor Fitzgerald Income Trust, Inc. (the “Company”), we submit to the staff (the “Staff”) of the U.S. Securities and Exchange Commission this letter setting forth the Company’s response to the comments
contained in the Staff’s letter dated May 30, 2024 regarding the Company’s Form 10-K for the fiscal year ended December 31, 2023.

For ease of reference, the Staff’s comment is reproduced below in bold and is followed by the Company’s response.

Form 10-K For the Fiscal Year Ending 12/31/2023

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations. Net Asset Value, page 67

1.
 We note the average NAV per share was $22.08 as of December 31, 2023, compared to $26.82 as of
December 31, 2022. Please tell us what factors lead to the decrease in the estimated NAV. Additionally, enhance your disclosure in future filings by including the factors that contributed to any significant increase or decrease in estimated NAV
over comparative periods.

 Response: In response to the Staff’s comment, the Company advises the Staff that, as
disclosed in the Company’s prospectus supplement No. 6 dated December 19, 2023, in 2023, the Company engaged an independent valuation firm (Robert A. Stanger & Co., Inc) to provide its appraised market value of the
Company’s consolidated real estate assets. The decrease in NAV from $26.82 as of December 31, 2022 to $22.08 as of December 31, 2023 is primarily due to the re-appraisal of the Company’s
consolidated real estate assets, which reflected the negative impact of higher interest rates on U.S. commercial real estate value. The other contributing factors included the Company’s distributions in excess of modified funds from operations
and expense reimbursements to the Company’s advisor during the corresponding period.

 The Company will enhance its disclosure in future filings by
including the factors that contributed to any significant increase or decrease in the estimated NAV over comparative periods.

 If you have any questions or comments concerning this submission or require any additional
information, please do not hesitate to contact the undersigned at (212) 801-6928.

Very truly yours,

GREENBERG TRAURIG, LLP.

By:

/s/ Yuta N. Delarck

Yuta N. Delarck, Esq.

cc:

Paul Pion, Chief Financial Officer, Cantor Fitzgerald Income Trust, Inc.

United States securities and exchange commission logo
May 30, 2024
Mr. Paul Pion
Chief Financial Officer
Cantor Fitzgerald Income Trust, Inc.
110 E. 59th Street
New York, NY 10022
Re:Cantor Fitzgerald Income Trust, Inc.
Form 10-K For the Fiscal Year Ending December 31, 2023
File No. 000-56043
Dear Mr. Paul Pion:
            We have reviewed your filing and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K For the Fiscal Year Ending 12/31/2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations.
Net Asset Value, page 67
1.We note the average NAV per share was $22.08 as of December 31, 2023, compared to
$26.82 as of December 31, 2022.  Please tell us what factors lead to the decrease in the
estimated NAV. Additionally, enhance your disclosure in future filings by including the
factors that contributed to any significant increase or decrease in estimated NAV over
comparative periods.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Kellie Kim at 202-551-3129 or Shannon Menjivar at 202-551-3856 if you
have questions regarding comments on the financial statements and related matters.

 FirstName LastNameMr. Paul Pion
 Comapany NameCantor Fitzgerald Income Trust, Inc.
 May 30, 2024 Page 2
 FirstName LastName
Mr. Paul Pion
Cantor Fitzgerald Income Trust, Inc.
May 30, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

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CORRESP

 Cantor Fitzgerald Income Trust, Inc.

110 E. 59th Street

 New
York, NY 10022

 February 5, 2024

VIA EDGAR AND EMAIL

 Division of Corporation Finance

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

 Re: Cantor Fitzgerald Income Trust, Inc.

 Registration Statement on Form S-11, as amended (File No. 333-273828)

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the
Securities Act of 1933, as amended, Cantor Fitzgerald Income Trust, Inc., (the “Company”) hereby requests the Securities and Exchange Commission (the “Commission”) to accelerate the effectiveness of its Registration Statement on
Form S-11 (File No. 333-273828) and declare the Registration Statement, as then amended, effective as of 4:00 p.m., Washington, D.C. time, on February 7, 2024
or as soon thereafter as practicable.

 In connection with this request for acceleration of effectiveness, the Company acknowledges that (i) should
the Commission or its staff, acting pursuant to delegated authority, declare the filing effective, such declaration does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or its
staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert the
declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact Yuta N. Delarck of Greenberg Traurig, LLP (counsel to the Company) at (212) 801-6928 with any questions
about this acceleration request. The Company hereby authorizes Ms. Delarck to orally modify or withdraw this request for acceleration. Please notify us when the delegated authority copy of the orders of the Commission declaring the Registration
Statement effective has been executed.

Sincerely,

 /s/ Paul Pion

Paul M. Pion

Chief Financial Officer

 cc: Joseph A. Herz, Esq.

Yuta N. Delarck, Esq.

United States securities and exchange commission logo
August 16, 2023
Howard Lutnick
Chairman and Chief Executive Officer
Cantor Fitzgerald Income Trust, Inc.
110 E. 59th St.
New York, NY 10022
Re:Cantor Fitzgerald Income Trust, Inc.
Registration Statement on Form S-11
Filed August 9, 2023
File No. 333-273828
Dear Howard Lutnick:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Kibum Park at 202-551-6836 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Yuta N. Delarck, Esq.

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CORRESP

 Cantor Fitzgerald Income Trust, Inc.

110 E. 59th Street

New York, NY 10022

August 7, 2020

 VIA EDGAR AND EMAIL

 Division of Corporation Finance

 Securities and
Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

Re:
 Cantor Fitzgerald Income Trust, Inc.

Registration Statement on Form S-11 (File
No. 333-237327)

 Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Cantor Fitzgerald Income Trust, Inc., formerly known as Rodin Global Property Trust,
Inc., (the “Company”) hereby requests the Securities and Exchange Commission (the “Commission”) to accelerate the effectiveness of its Registration Statement on Form S-11 (File No. 333-237327) and declare the Registration Statement, as then amended, effective as of 4:00 p.m., Washington, D.C. time, on August 10, 2020 or as soon thereafter as practicable.

In connection with this request for acceleration of effectiveness, the Company acknowledges that (i) should the Commission or its staff, acting pursuant
to delegated authority, declare the filing effective, such declaration does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or its staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert the declaration of effectiveness as a defense in
any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Please contact Yuta N. Delarck of
Greenberg Traurig, LLP (counsel to the Company) at (212) 801-6928 with any questions about this acceleration request. The Company hereby authorizes Ms. Delarck to orally modify or withdraw this request
for acceleration. Please notify us when the delegated authority copy of the orders of the Commission declaring the Registration Statement effective has been executed.

Sincerely,

/s/ Paul Pion

Paul M. Pion

Chief Financial Officer

 cc:    Joseph A. Herz, Esq.

Yuta N. Delarck, Esq.

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CORRESP

 Joseph A. Herz

212-801-6926

herzj@gtlaw.com

June 15, 2020

 VIA
EDGAR

 U.S. Securities and Exchange Commission

 Division
of Corporation Finance

 100 F Street, NE

 Washington, DC
20549

Attention:

 DavidLink

Office of Real Estate and Commodities

Re:

 Rodin Global Property Trust, Inc.

Registration Statement on Form S-11

 Filed
March 20, 2020

 File No. 333-237327

 Dear Mr. Link:

On behalf of Rodin Global Property Trust, Inc., a Maryland corporation (the “Company”), and pursuant to the applicable
provisions of the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder and our most recent telephone conversation on May 29, 2020, set forth below are the Company’s responses to the comment letter from
the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Mr. Howard Lutnick of the Company, dated April 3, 2020 (the “Comment Letter”), relating to the
Registration Statement on Form S-11 filed with the Commission on March 20, 2020 (the “Registration Statement”). For ease of reference, each of the Staff’s comments is reproduced
below in italics and is followed by the Company’s responses.

 General

1.
 We note that you incorporate by reference your Form 10-K for the
fiscal year ended December 31, 2019; however, the Form 10-K incorporates by reference information from your definitive proxy statement that has not yet been filed. Please note that we will not be in a
position to accelerate the effective date of your registration statement until you have amended the Form 10-K to include Part III information or filed the definitive proxy statement. Please refer to Compliance
and Disclosure Interpretations, Securities Act Forms Question 123.01 for guidance.

 United States Securities and Exchange Commission

Division of Corporation Finance

 June 15, 2020

Page 2 of 3

Response:

 The Company advises the Staff that the
Company has filed with the Commission a definitive Proxy Statement on Schedule 14A on April 17, 2020, which contains the information required to be included in Part III of the Annual Report on Form 10-K.

2.
 We note you indicate that you have adopted a share repurchase program. We also note your affiliation with
Cantor Fitzgerald. Please provide us with a detailed analysis of what exemption, if any is required, would be available for Cantor Fitzgerald’s activities under your repurchase program. We may have further comment.

Response:

 The Company advises the Staff that none
of Cantor Fitzgerald & Co., the dealer manager for the offering (the “Dealer Manager”), the Company’s sponsor, Cantor Fitzgerald Investors, LLC (the “Sponsor”), or Rodin Global Property Advisors, LLC,
the Company’s advisor (the “Advisor”) engage in any non-administrative activities relating to the Company’s share repurchase program. The share repurchase program is established and
administered by the Company. As disclosed on page 29 of the Registration Statement, stockholders who would like to request repurchase of their shares are advised to contact the Company to receive the required repurchase forms and instructions
concerning required signatures. In all cases, the payment of funds in connection with qualified repurchases are from the Company’s accounts. Certain broker dealers require that their clients make repurchase requests through such broker dealers,
so investors are further advised to contact their broker dealer first if they want to request repurchase of the shares. Although employees of the Dealer Manager, the Sponsor or the Advisor may serve as the points of contact by the registered
broker-dealers requesting share repurchases on behalf of the investors, their role is purely administrative and is limited to connecting the investors to the Company for purposes of processing qualified share repurchases.

***

 United States Securities and Exchange Commission

Division of Corporation Finance

 June 15, 2020

Page 3 of 3

If you should have any questions about this letter or require any further information, please call me at (212)
801-6926.

 Sincerely,

 /s/ Joseph A. Herz

 Joseph A. Herz

cc:
 Pam Howell, Esq. Sherwin Salar, Esq.

Yuta N. Delarck, Esq., Greenberg Traurig, LLP

April 3, 2020
Howard Lutnick
Chief Executive Officer
RODIN GLOBAL PROPERTY TRUST, INC.
110 E. 59th Street
New York, NY 10022
Re:RODIN GLOBAL PROPERTY TRUST, INC.
Registration Statement on Form S-11
Filed March 20, 2020
File No. 333-237327
Dear Mr. Lutnick:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-11 filed on March 20, 2020
General
1.We note that you incorporate by reference your Form 10-K for the fiscal year ended
December 31, 2019; however, the Form 10-K incorporates by reference information from
your definitive proxy statement that has not yet been filed.  Please note that we will not be
in a position to accelerate the effective date of your registration statement until you have
amended the Form 10-K to include Part III information or filed the definitive proxy
statement.  Please refer to Compliance and Disclosure Interpretations, Securities Act
Forms Question 123.01 for guidance.
2.We note you indicate that you have adopted a share repurchase program.  We also note
your affiliation with Cantor Fitzgerald.  Please provide us with a detailed analysis of what
exemption, if any is required, would be available for Cantor Fitzgerald's activities under

 FirstName LastNameHoward Lutnick
 Comapany NameRODIN GLOBAL PROPERTY TRUST, INC.
 April 3, 2020 Page 2
 FirstName LastName
Howard Lutnick
RODIN GLOBAL PROPERTY TRUST, INC.
April 3, 2020
Page 2
your repurchase program.  We may have further comment.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact David Link at (202) 551-3356 or Pam Howell at (202) 551-3357 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

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Acceleration Request

 Rodin Global Property Trust, Inc.

110 E. 59th Street

New York, NY 10022

March 21, 2017

 VIA EDGAR AND EMAIL

 Division of Corporation Finance

 Securities and
Exchange Commission

 100 F Street, N.E.

 Washington, D.C.
20549

Re:
Rodin Global Property Trust, Inc.

Registration Statement on Form S-11 (File No. 333-214130)

 Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Rodin Global Property Trust, Inc. (the “Company”) hereby requests the
Securities and Exchange Commission (the “Commission”) to accelerate the effectiveness of its Registration Statement on Form S-11 (File No. 333-214130) and declare the Registration Statement, as then amended, effective as of
4:30 p.m., Washington, D.C. time, on March 23, 2017 or as soon thereafter as practicable.

 In connection with this request for acceleration of
effectiveness, the Company acknowledges that (i) should the Commission or its staff, acting pursuant to delegated authority, declare the filing effective, such declaration does not foreclose the Commission from taking any action with respect to
the filing; (ii) the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in
the filing; and (iii) the Company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact Joseph A. Herz of Greenberg Traurig, LLP (counsel to the Company) at (212) 801-6926 with any questions about this acceleration request.
Please notify us when the delegated authority copy of the orders of the Commission declaring the Registration Statement effective has been executed.

Sincerely,

Rodin Global Property Trust, Inc.

By:

 /s/ Kenneth Carpenter

Name:

Kenneth Carpenter

Title:

President

cc:
Judith D. Fryer, Esq.

Joseph A. Herz, Esq.

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Response Letter

 Joseph A. Herz

 212-801-6926

 herzj@gtlaw.com

March 21, 2017

 VIA
EDGAR AND UPS

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, NE

Washington, DC 20549

Attention:
Kim McManus, Senior Attorney

Office of Real Estate and Commodities

Re:
Rodin Global Property Trust, Inc.

Registration Statement on Form S-11

Filed February 1, 2017

File No. 333-214130

 Dear Ms. McManus:

On behalf of Rodin Global Property Trust, Inc., a Maryland corporation (the “Company”), and pursuant to the applicable provisions of
the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder (the “Securities Act”), please find attached for filing with the Securities and Exchange Commission (the “Commission”) via EDGAR a
complete copy of Pre-Effective Amendment No. 2 (“Amendment No. 2”) to the above-referenced Registration Statement on Form S-11 (the
“Registration Statement”).

 Amendment No. 2 includes revisions in response to the comment letter from the Staff of the
Commission (the “Staff”) to Mr. Michael Lehrman of the Company, dated February 8, 2017 (the “Comment Letter”), relating to Pre-Effective Amendment No. 1 to the Registration
Statement filed with the Commission on February 1, 2017 (“Amendment No. 1”). This letter provides responses to the Comment Letter, with responses keyed to the numbered comments in the Comment Letter.

For the Staff’s convenience, the Company is providing the Staff with four copies of Amendment No. 2, which have been marked to
indicate the location of changes from Amendment No. 1, together with four copies of this response letter as submitted to the Commission.

 Kim McManus, Esq.

March 21, 2017

 Page 2 of 4

 Conflicts of Interest

Charter Provisions Relating to Conflicts of Interest

Allocation of Investment Opportunities, page 95

1.
We note your disclosure on page 91 that neither CCRE, BGC nor any other Cantor Company is restricted from competing with your business. We also note that your disclosure relating to the allocation of investment
opportunities on page 95 appears to relate to future public and private entities with investment strategies that overlap with yours. Please revise your disclosure to also discuss how investment opportunities will be allocated between you and
existing Cantor Companies that compete with your business or have overlapping investment strategies.

 Response:

The Company advises the Staff that, as disclosed on page 91 of Amendment No. 2, the persons comprising BGC’s and CCRE’s day to day management
are generally different than the investment professionals of the Company’s sponsor. Investment opportunities sourced by the personnel of other Cantor Companies, to the extent not pursued by such companies, will be allocated by such companies in
their sole discretion. As disclosed on page 91 of Amendment No. 2, as well as on page 34 of Amendment No. 2 under the heading “Risk Factors – Risks Related to an Investment in Us – We may compete with other Cantor Companies
for investment opportunities for our company, which could negatively impact our ability to locate suitable investments,” other Cantor Companies are not required to refer any such opportunities to the Company’s sponsor. The Company further
advises the Staff that all investment opportunities sourced by the investment professionals of the Company’s sponsor will be allocated as set forth on pages 95 and 96 of Amendment No. 2 under the
sub-heading “Allocation of Investment Opportunities.”

 The Company has revised the disclosure on page 91
of Amendment No. 2 to reflect the allocation of investment opportunities sourced by other Cantor Companies described above. In addition, the Company has added disclosure on page 91 of Amendment No. 2 to note that the investment
professionals responsible for sourcing investments for the sponsor are generally different than the investment professionals responsible for sourcing investments for other Cantor Companies and to the extent there is overlap, such investment
professionals will first present suitable opportunities to the sponsor.

 Index to Consolidated Balance Sheet

2.
Please revise the heading on page F-2 and F-3 to change name of the Company from Rodin Global Access Property Trust, Inc. to Rodin
Global Property Trust, Inc.

 Kim McManus, Esq.

March 21, 2017

 Page 3 of 4

 Response:

In response to the Staff’s comment, the Company has revised the headings on pages F-3 and F-4 of Amendment No. 2 to reflect the change of the name of the Company from Rodin Global Access Property Trust, Inc. to Rodin Global Property Trust, Inc.

Exhibit 5.1

3.
We note that counsel has assumed sufficient authorized shares, an assumption we consider inappropriate as stated in Staff Legal Bulletin No. 19, Legality and Tax Opinions in Registered Offerings. Please have
counsel provide a revised legal opinion.

 Response:

The Company advises the Staff that Maryland counsel has revised its Exhibit 5.1 opinion in paragraph number six to note in the acknowledgement a specific
number of shares for each of the Class A and Class T Shares, based on a price per share of $26.32 and $25.51, respectively, and the authorized number of Class I Shares that may be issued in connection with the offering. The revised
opinion of Maryland counsel has been filed as Exhibit 5.1 to Amendment No. 2.

 ***

 Kim McManus, Esq.

March 21, 2017

 Page 4 of 4

 If you should have any questions about this letter or require any further information, please call me at
(212) 801-6926.

Sincerely,

/s/ Joseph A. Herz

Joseph A. Herz

cc:
Bryan Hough, Esq.

Mr. Jorge L. Bonilla

Ms. Shannon Sobotka

Jason Emala, Esq.

Judith D. Fryer, Esq., Greenberg Traurig, LLP

Mail Stop 3233
February 8, 2017

Via E -Mail
Michael Lehrman
Chairman and Chief Executive Officer
Rodin Global Property Trust, Inc.
110 E. 59th Street
New York, NY 10022

Re: Rodin Global Property Trust, Inc.
Amendment No. 1 to Registration Statement on Form S-11
Filed February 1, 2017
  File No. 333-214130

Dear Mr. Lehrman :

We have reviewed your amended registration statement  and have the following
comments .  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply t o your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our November 8, 2016  letter .

Conflicts of Interest

Charter Provisions Relating to Conflicts of Interest

Allocation of Investment Opportunities, page 95

1. We note your disclosure on page 91 that neither CCRE, BGC nor any other Cantor
Company is restricted from competing with your business.  We also note that your
disclosure relating to the allocation of investment opportunities on page 95 appears to
relate to future public and private entities with investment strategies that overlap with
yours.  Please revise your disclosure to also discuss how investment opportunities will be
allocated between you and existing Cantor Companies that compete with your business o r
have overlapping investment strategies.

Michael Lehrman
Rodin Global Property Trust, Inc.
February 8, 2017
Page 2

 Index to Consolidated Balance Sheet

2. Please revise the heading on page F -2 and F -3 to change name of the Company from
Rodin Global Access Property Trust, Inc. to Rodin Global Property Trust, Inc.

Exhibit 5.1

3. We note that counsel has assumed sufficient authorized shares, an assumption we
consider inappropriate as stated in Staff Legal Bulletin No. 19, Legality and Tax
Opinions in Registered Offerings. Please have counsel provide a revised legal opinion.

You may contact Jorge L. Bonilla, Staff Accountant, at (202) 551 -3414 or Shannon
Sobotka, Staff Accountant, at (202) 551 -3856 if you have questions regarding comments on the
financial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202)
551-8625 or me at (202) 551 -3215 with any other questions.

Sincerely,

 /s/ Kim McManus

Kim McManus
Senior Attorney
Office of Real Estate and
Commodities
cc:  Judith D. Fryer, Esq.
Joseph A. Herz, Esq.
Greenberg Traurig, LLP

CORRESP
1
filename1.htm

Response Letter

 Joseph A. Herz

 212-801-6926

 herzj@gtlaw.com

                January 31, 2017

VIA EDGAR AND UPS

 U.S. Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

Attention:
Kim McManus, Senior Attorney

 Office of Real Estate and Commodities

Re:
Rodin Global Property Trust, Inc.

 Registration Statement on Form S-11

Filed October 17, 2016

File No. 333-214130

Dear Ms. McManus:

 On behalf of Rodin
Global Property Trust, Inc., a Maryland corporation (the “Company”), and pursuant to the applicable provisions of the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder (the “Securities
Act”), please find attached for filing with the Securities and Exchange Commission (the “Commission”) via EDGAR a complete copy of Amendment No. 1 (“Amendment No. 1”) to the above-referenced Registration Statement
on Form S-11 (the “Registration Statement”).

 Amendment No. 1 includes revisions in
response to the comment letter from the Staff of the Commission (the “Staff”) to Mr. Michael Lehrman of the Company, dated November 8, 2016 (the “Comment Letter”), relating to the Registration Statement filed with the
Commission on October 17, 2016. This letter provides responses to the Comment Letter, with responses keyed to the numbered comments in the Comment Letter.

For the Staff’s convenience, the Company is providing the Staff with four copies of Amendment No. 1, which have been marked to
indicate the location of changes from the Registration Statement, together with four copies of this response letter as submitted to the Commission.

General

1.
We note your disclosure throughout that you may offer shares at a price that you believe reflects NAV per share of such stock more appropriately than the prior quarter’s NAV per share. Please expand your
disclosure to clarify how you will calculate the updated NAV per share. To the extent your template for NAV disclosures filed in these circumstances will differ, please provide us with a draft.

 Kim McManus, Esq.

January 31, 2017

  Page
 2
 of 5

 Response:

In response to the Staff’s comment, the Company has deleted the disclosure throughout Amendment No. 1 which provided that the Company may offer
shares at a price it believes reflects the NAV per share of such stock more appropriately than the prior quarter’s NAV per share in cases where the Company believes there has been a material change to the Company’s NAV per share since the
end of the prior quarter.

2.
We note your response to comment 12 that promptly following any adjustment to the offering prices per share, you will file a prospectus supplement or post-effective amendment to the registration statement disclosing
the offering prices and the effective date of such adjusted offering prices, and you will also post the updated information on your website. We also note your disclosure that you will ordinarily publish any adjustment to the NAV and the
corresponding adjustments to the offering prices of your shares on or around the 45th day following each completed fiscal quarter. Given that investors do not know the specific day that adjustments to the per share prices will be released, whether
pursuant to a quarterly adjustment or an adjustment in cases where you believe there has been a material change to your NAV, and they will not be contacted directly if there is a subsequent change in the per share prices, please describe the process
by which investors will receive the pricing information.

 Response:

In response to the Staff’s comment, the Company has revised the disclosure on pages ii, 2,13,123, 169 and 175 of Amendment No. 1 to disclose that the
Company expects to publish any adjustment to the NAV and the corresponding adjustments to the offering prices of the Company’s shares on the 45th day following each completed fiscal quarter,
unless such day is a Saturday, Sunday or banking holiday, in which case publication will be on the next business day.

 The Company believes that providing
additional clarity as to the date of publication of any adjustment to NAV and the corresponding adjustment to the offering prices of the Company’s shares, if any, and removing the ability of the Company to make adjustments as a result of
material changes to the Company’s NAV per share since the end of the prior quarter, combined with filing a prospectus supplement or post-effective amendment and posting on the Company’s website any new offering prices, will allow the
Company’s investors to be fully apprised in a timely and consistent manner as to any changes to the offering prices of its shares.

 Kim McManus, Esq.

January 31, 2017

  Page
 3
 of 5

 Questions and Answers About this Offering

What Kind of Offering is this?, page 2

3.
We note your disclosure that you will ordinarily publish any adjustment to the NAV and the corresponding adjustments to the offering prices of your shares on or around the 45th day following each completed fiscal
quarter, and your disclosure on page 169 that adjustments to the offering prices will be made publicly available by filing a prospectus supplement or post-effective amendment with the SEC and by posting on your website. Please revise your disclosure
here and in the prospectus summary to more prominently describe when and where the transaction price will be available.

Response:

 In response to the Staff’s
comment, the Company has provided additional disclosure on pages ii, 2, 123, 169 and 175 of Amendment No. 1 describing when and where the offering prices will be available.

Estimated Use of Proceeds, page 64

4.
Please revise to remove the adjusted net proceeds available for investment figures in footnote 1 to the use of proceeds tables.

Response:

 In response to the Staff’s
comment, the Company has removed the adjusted net proceeds available for investment figures in footnote 1 to the use of proceeds tables on pages 65, 66 and 68 of Amendment No. 1.

Net Asset Value Calculation and Valuation Procedures

NAV and NAV Per Share Calculation, page 121

5.
We note your disclosure on page 122 that for purposes of calculating your NAV, the organization and offering costs paid by your advisor through the first anniversary of the date on which you satisfy the minimum
offering will not be recognized in your financial statements until the reimbursement obligation is established or reflected in your NAV until you reimburse the advisor for these costs. Please tell us when such reimbursement obligation will be
established for purpose of your financial statements and the guidance upon which you relied.

 Response:

The Company advises the Staff that the reimbursement obligation will be established and recorded as a liability for purposes of its financial statements at the
end of each month following the satisfaction of the minimum offering requirement in an amount equal to the lesser of (i) the organization and offering costs incurred by the advisor that previously have not been recorded as a reimbursement
liability and (ii) one percent (1%) of the gross offering proceeds raised during such month. The Company’s policy with respect to recording the reimbursement liability in the Company’s financial statements will correspond to when the
Company believes it is legally obligated to reimburse the advisor pursuant to the terms of the Advisory Agreement.

 Kim McManus, Esq.

January 31, 2017

  Page
 4
 of 5

 Plan of Distribution, page 169

6.
We note your disclosure that the transaction price may be revised after an investor makes a subscription request such that the price the investor will pay may be significantly different from the NAV per share as of
the date on which the investor made the subscription request. Please explain to us how you intend to proceed (e.g., would you seek affirmative reconfirmation) if you materially amend the price after receiving subscriptions from potential investors
based on the previously disclosed price.

 Response:

The Company advises the Staff that in addition to notifying investors of any changes to the offering prices of its shares by making such information available
in prospectus supplements or post-effective amendments filed with the Commission and on the Company’s website, the Company has added an acknowledgement in its subscription form whereby investors indicate that they understand that the price at
which their investment is executed will be made available to them through a prospectus supplement or post-effective amendment and the Company’s website

The Company further advises the Commission that it will not accept any subscription agreements during the five business day period immediately prior to the
effectiveness of the new purchase price and investors may withdraw their purchase request during such period.

 Subscription Procedures, page 175

7.
We note your disclosure that a subscription request must be made by a completed and signed subscription agreement for a specific number of shares, and the full purchase price must be paid at the time of subscription.
You also state on page 2 that investors who have not received notification of acceptance of their subscription agreements prior to your publication of new offering prices may withdraw their purchase request during the five business day period after
publication of a new NAV. Please expand your discussion to describe your subscription process in more detail. Explain when you will accept subscriptions and what the price will be at the time of acceptance. In this regard, it appears that
subscriptions may be submitted prior to the time that the transaction price will be available. Please tell us how investors will comply with these subscription procedures. Please also clarify the information regarding price that will be available to
an investor at the time the investor is contractually committed to purchase.

 Response:

In response to the Staff’s comment, the Company has expanded the disclosure on pages ii, 2, 123, 169, 175 of Amendment No. 1to (i) further describe
the subscription process in more detail, including when the Company will accept subscriptions and what the price will be at the time of acceptance, and (ii) clarify the information regarding price that will be available to an investor at the
time the investor is contractually committed to purchase shares.

 ***

 Kim McManus, Esq.

January 31, 2017

  Page
 5
 of 5

 If you should have any questions about this letter or require any further information, please call me at
(212) 801-6926.

 Sincerely,

 /s/ Joseph A. Herz

 Joseph A. Herz

cc:
Bryan Hough, Esq.

 Mr. Jorge L. Bonilla

Ms. Shannon Sobotka

Mr. Michael Lehrman, Rodin Global Property Trust, Inc.

Judith D. Fryer, Esq., Greenberg Traurig, LLP

Mail Stop 3233
November 8, 2016

Via E -Mail
Michael Lehrman
Chairman and Chief Executive Officer
Rodin Global Property Trust, Inc.
110 E. 59th Street
New York, NY 10022

Re: Rodin Global Property Trust, Inc.
Registration Statement on Form S-11
Filed October 17, 2016
  File No. 333-214130

Dear Mr. Lehrman :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstanc es or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have additional comments.

Genera l

1. We note your disclosure throughout that you may offer shares at a price that you believe
reflects NAV per share of such stock more appropriately than the prior quarter’s  NAV
per share. Please expand your disclosure to clarify how you will calculate the updated
NAV per share. To the extent your template for NAV disclosures  filed in these
circumstances will differ, please provide us with a draft.

2. We note your response to comment 12 that promptly following any adjustment to the
offering prices per share, you will file a prospectus supplement or post -effective
amendment to the registration statement disclosing the offering prices and the effective
date of such adjusted offering prices, and you will also post the updated information on
your website. We also note your disclosure that you will ordinarily publish any
adjustment to the NAV and the corresponding adjustments to the offering prices of your

Michael Lehrman
Rodin Global Property Trust, Inc.
November 8, 2016
Page 2

 shares on or around the 45th day following each completed fiscal quarter.   Given that
investors do not know the specific day that adjustments to the per share prices will be
released , whether pursuant to a quarterly adjustment or an adjustment in cases where you
believe there has been a material ch ange to your NAV,  and they will not be contacted
directly if there is a subsequent change in the per share prices , please describe the process
by which investors will receive the pricing information.

Questions and Answers About This Offering

What kind of  offering is this?, page 2

3. We note your disclosure that you will ordinarily publish a ny adjustment to the NAV and
the corresponding adjustments to the offering prices of your shares on or around the 45th
day following each completed fiscal quarter , and yo ur disclosure on page 169 that
adjustments to the offering prices will be made publicly available by filing a prospectus
supplement or post -effective amendment with the SEC and by posting on your website .
Please revise your disclosure here and in the prospectus summary to more prominently
describe when and where the transaction price will be available.

Estimated Use of Proceeds, page 64

4. Please revise to remove the adjusted net proceeds available for investment figures in
footnote 1 to the use of proceeds tables.

Net Asset Value Calculation and Valuation Procedures

NAV and NAV Per Share Calculation, page 121

5. We note your disclosure on page 122 that for purposes of calculating your NAV, the
organization and offering costs paid by your advisor thr ough the first anniversary of the
date on which you satisfy the minimum offering will not be recognized in your financial
statements until the reimbursement obligation is established or reflected in your NAV
until you reimburse the advisor for these costs.  Please tell us when such reimbursement
obligation will be established for purpose of your financial statements and the guidance
upon which you relied.

Plan of Distribution, page 169

6. We note your disclosure that the transaction price may be revised after an investor makes
a subscription request such that the price the investor will pay may be significantly
different from the NAV per share as of the date on which the investor made the
subscription request.  Please explain to us how you intend to proceed (e.g., would you
seek affirmative reconfirmation) if you materially amend the price after receiving
subscriptions from potential investors based on the previously disclosed price.

Michael Lehrman
Rodin Global Property Trust, Inc.
November 8, 2016
Page 3

Subscription Procedures, page 175

7. We note your disclosure that a subscription request must be made by a completed and
signed subscription agreement for a specific number of shares, and the full purchase price
must be paid at the time of subscription.  You als o state on page 2 that investors who
have not received notification of acceptance of their subscription agreements prior to
your publication of new offering prices may withdraw their purchase request during the
five business day period after publication of  a new NAV.  Please expand your discussion
to describe your subscription process in more detail.  Explain when you will accept
subscriptions and what the price will be at the time of acceptance.  In this regard, it
appears that subscriptions may be submitt ed prior to the time that the transaction price
will be available.  Please tell us how investors will comply with these subscription
procedures.  Please also clarify the information regarding price that will be available to
an investor at the time the inve stor is contractually committed to purchase.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Refer to Rules 460 and 461 regarding requests for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

You may contact Jorge L. Bonilla, Staff Accountant, at (202) 551-3414 or Shannon
Sobotka, Staff Accountant, at (202) 551 -3856 if you have questions regarding comments on the
financial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202)
551-8625 or me at (202) 551 -3215 with any other questions.

Sincerely,

 /s/ Kim McManus

Kim McManus
Senior Attorney
Office of Real Estate and
Commodities

cc: Judith D. Fryer, Esq.
 Joseph A. Herz, Esq.
Greenberg Traurig, LLP

CORRESP
1
filename1.htm

CORRESP

 Joseph A. Herz

 212-801-6926

 herzj@gtlaw.com

 October
17, 2016

 VIA EDGAR AND UPS

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention:

Kim McManus, Senior Attorney

Office of Real Estate and Commodities

Re:
Rodin Global Property Trust, Inc.

 Amended Confidential Draft Registration Statement
on Form S-11

 Submitted September 14, 2016

CIK No. 0001664780

 Dear Ms. McManus:

 On behalf of Rodin Global Property Trust, Inc., a Maryland corporation (the “Company”), and pursuant to the applicable
provisions of the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder (the “Securities Act”), please find attached for filing with the Securities and Exchange Commission (the “Commission”) via
EDGAR the Company’s initial public registration statement on Form S-11 (the “Registration Statement”).

 The Registration
Statement includes revisions in response to the comment letter from the Staff of the Commission (the “Staff”) to Mr. Michael Lehrman of the Company, dated October 6, 2016 (the “Comment Letter”) relating to the above-referenced
amended draft registration statement confidentially submitted to the Commission on September 14, 2016 (the “Third Amended Submission”). This letter provides responses to the Comment Letter, with responses keyed to the numbered comments in
the Comment Letter.

 For the Staff’s convenience, the Company is providing the Staff with four copies of the Registration Statement,
which have been marked to indicate the location of changes from the Third Amended Submission, together with four copies of this response letter as submitted to the Commission.

General

1.
 We note your response to prior comment 1. Please tell us, with a view toward revised disclosure, why you refer
to the board’s ability to use funds on a monthly basis despite the

 Kim McManus, Esq.

October 17, 2016

  Page
 2
 of 7

plan being based on each quarter, not each month. Also, please tell us why you will “attempt to honor” requests on a pro rata basis when you are otherwise unable to purchase all shares
requested to be repurchased during a quarter. Finally, we reissue the portion of the prior comment in which we sought your analysis of your ability to automatically repurchase shares from holders who would hold fewer shares than the minimum purchase
requirements as a result of an existing repurchase request.

 Response:

In response to the Staff’s comment, the Company has revised the Registration Statement to note the ability of the board of directors of the Company to use
funds from the distribution reinvestment plan on a quarterly basis on pages 24 and 163 of the Registration Statement. In addition, the Company has revised the disclosure to (i) change the reference to “attempt to honor” to “will
honor” on pages 23 and 163 of the Registration Statement and (ii) delete references to the Company’s ability to automatically repurchase shares from holders of the Company’s common stock who would hold fewer shares than the minimum
purchase requirements as a result of an existing repurchase request on pages 24 and 163 of the Registration Statement.

2.
Please add disclosure regarding the timing and circumstances surrounding your change in name from Rodin Global Access Property Trust, Inc. to Rodin Global Property Trust, Inc.

Response:

 In response to the Staff’s
comment, the Company has added disclosure referencing the original name of the Company on page [●] of the Registration Statement. The Company supplementally advises the Staff that the determination to change the name of the Company was
based on marketing considerations. Accordingly, since the Registration Statement is not effective, no shares of the Company are being offered or sold to investors and changing the name of the Company is not a substantive modification to the
terms of the proposed offering, the Company does not believe any additional disclosure is necessary.

 Questions and Answers About this Offering

 What kind of offering is this?, page 2

3.
If known, please disclose throughout the prospectus when during each quarter you expect to publish any adjustments to the offering prices or, if you do not expect this to occur at the same time each quarter, please
disclose this fact.

 Response:

The Company advises the Staff that, as noted on page 2 of the Registration Statement under the heading “What kind of offering is this?” in the
section titled “Questions and Answers About this Offering,” the Company expects to determine its NAV within 45 days after each completed fiscal quarter and publish any adjustment to the NAV and the corresponding adjustments to the

 Kim McManus, Esq.

October 17, 2016

  Page
 3
 of 7

offering prices for the classes of shares on or around the 45th day after each completed fiscal quarter. The Company has revised the disclosure on pages 123 and 169 of the Registration
Statement to disclose this expectation.

 Risk Factors

Risks Related to an Investment in us

Valuations and appraisals of our properties…, page 29

4.
We note your disclosure that “[b]ecause the price you will pay for Class T Shares or Class I Shares…are based on our estimated NAV per share….” Please revise to reflect that the price investors
will pay for each share class will be based on your estimated NAV per share after you commence valuations.

 Response:

In response to the Staff’s comment, the Company has revised the disclosure on page 29 of the Registration Statement to disclose that the price investors
will pay for each class of shares will be based on the estimated NAV per share for each class of shares only after the Company commences valuations.

Estimated Use of Proceeds, page 64

5.
Please remove the adjustment for sponsor support of selling commissions and dealer manager fees from the use of proceeds table. The contingent reimbursement to your advisor is a cost to the business; it is our
view that these amounts should be reflected in the Use of Proceeds Table. Please ensure that the Use of Proceeds Table deducts the selling commissions and dealer manager fees in computing the amount available for investment given the fact that
the advisor is not gifting this amount to the issuer, but instead will receive a contingent reimbursement right. Footnote disclosure may convey the sponsor support; however, this amount should not be added back into net proceeds in the table.

 Response:

 In response to
the Staff’s comment, the Company has removed the adjustment for sponsor support of selling commissions and dealer manager fees and deducted such amounts in computing the amounts available for investment from the Use of Proceeds tables on pages
65, 66 and 68 of the Registration Statement. In addition, in further response to the Staff’s comment, the Company has added footnote disclosure giving effect to the sponsor support on page 65, 66 and 68 of the Registration Statement.

 Kim McManus, Esq.

October 17, 2016

  Page
 4
 of 7

6.
In a footnote to the table on page 65, please provide a description of the acquisition expenses you intend to pay to your Advisor or its affiliates.

Response:

 In response to the Staff’s
comment, the Company has added new footnotes to the “Use of Proceeds” tables on pages 66, 67 and 69 of the Registration Statement to describe the acquisition expenses the Company intends to pay its advisor or its affiliates.

Management

 The Advisory
Agreement, page 76

7.
We note your statement that compensation to your advisor may be increased “subject to approval by our independent directors and the other limitations in our advisory agreement and our charter.” Please
revise to disclose, if true, that the company may increase fees payable to the advisor without shareholder consent.

 Response:

 In response to the Staff’s comment, the Company has revised the disclosure on pages 78 and 88 to disclose that the Company may increase fees
payable to the advisor without stockholder approval.

 Certain Prior Experience

Cantor Commercial Real Estate, page 78

8.
We note your response to comment 2. To the extent you believe that CCRE’s 2015 and 2016 CMBS securitization performance is a material adverse business development or condition with respect to CCRE, please
disclose this development in your prospectus.

 Response:

Although the Company does not believe that CCRE’s 2015 and 2016 CMBS securitization performance is a material adverse business development within the
meaning of Guide 5, the Company has added disclosure on page 79 of the Registration Statement regarding CCRE and its 2015 and 2016 securitization performance.

Net Asset Value Calculation and Valuation Procedures, page 118

9.
 We note your disclosure that, with the approval of your board of directors, including a majority of your
independent directors, you will engage an independent valuation firm to calculate your NAV. Please confirm that your quantitative NAV disclosures will be

 Kim McManus, Esq.

October 17, 2016

  Page
 5
 of 7

expertised. If your NAV disclosures will be expertised, please confirm that you will file the third party consent and revise your expert section to identify the expert and the disclosures being
expertised, when appropriate.

 Response:

The Company advises the Staff that the final determination of the fair value of its real estate properties and assets ultimately will be made by the
Company’s board of directors. Accordingly, the Company does not believe it is appropriate to attribute the calculation of its NAV to the independent valuation firm. However, the Company will identify and expertise the independent
valuation firm and quantitative NAV disclosures in a subsequent amendment to the Registration Statement. The Company also confirms that it will file the consent of the independent valuation firm with the amendment.

10.
Please provide us, on a supplemental basis, with your template for future NAV disclosures.

Response:

 The Company will supplementally provide
the Staff with its proposed template for future NAV disclosures by separate correspondence.

11.
Please revise to clarify how you intend to value the sponsor reimbursement right for purposes of calculating NAV.

Response:

 The Company advises the Staff that it
has revised the disclosure on page 121 of the Registration Statement to clarify that the contingent reimbursement of sponsor support will not be recorded as a liability until such time as it becomes an obligation that can be reasonably estimated and
that the likelihood of any such reimbursement payment is probable. The Company only becomes obligated to reimburse the sponsor for sponsor support after the full return of invested capital (which equals the full gross proceeds of the primary
and DRIP offerings) plus a 6.0% cumulative, non-compounded annual pre-tax return on such invested capital to stockholders. As a result, the Company does not anticipate that it will accrue any liability for the reimbursement of sponsor support
for the foreseeable future, and, as a result, the contingent reimbursement will not affect the calculation of NAV for the foreseeable future.

Plan of Distribution, page 169

12.
 We note your disclosure that “[p]romptly following any adjustment to the offering prices per
share, we will file a prospectus supplement or post-effective amendment to the registration statement with the SEC disclosing the adjusted offering prices and the effective date of such adjusted offering prices, and we will also post the updated

 Kim McManus, Esq.

October 17, 2016

  Page
 6
 of 7

information on our website at www.rodinglobalpropertytrust.com.” We also note your disclosure on page 30 that “[i]nvestors will purchase shares at the offering price that is effective
at the time that his or her completed subscription agreement has been accepted by our dealer manager. As a result, the offering price may change prior to the acceptance of such subscription by our dealer manager from the price that was effective at
the time such investor submitted his or her subscription agreement.” Please tell us how you intend to update investors if there has been a change in NAV after the time an investor submits a subscription agreement and prior to the subscription
agreement being accepted by your dealer manager. Please also tell us how you determined that this is an appropriate pricing mechanism for a continuous offering since the investor is not provided with an opportunity to withdraw the subscription after
notification of the new price..

 Response:

The Company advises the Staff that it anticipates that changes to the NAV for each of its classes of shares will be announced at the same time as any changes
in prices for each of the share classes. As previously disclosed in the Registration Statement, we will file a prospectus supplement or post-effective amendment to the registration statement with the SEC disclosing the adjusted offering prices
and the effective date of such adjusted offering prices, and we will also post the updated information on our website at www.rodinglobalpropertytrust.com (see pages 30 and 169 of the Registration Statement).] The
Company further advises the Staff that it has revised the disclosure on pages 2, 123 and 169 of the Registration Statement to provide for a withdrawal right during the five (5) business day period immediately prior to the effectiveness of the new
share prices for investors who have not had received notification of acceptance of their subscription agreements prior to the Company’s public announcement of such pricing changes.

***

 Kim McManus, Esq.

October 17, 2016

  Page
 7
 of 7

 If you should have any questions about this letter or require any further information, please call me at
(212) 801-6926.

Sincerely,

/s/ Joseph A. Herz

Joseph A. Herz

cc:
Tom Kluck, Esq.

 Bryan Hough, Esq.

Mr. Jorge L. Bonilla

 Ms. Shannon
Sobotka

 Mr. Michael Lehrman, Rodin Global Property Trust, Inc.

Judith D. Fryer, Esq., Greenberg Traurig, LLP

Mail Stop 3233
October 6, 2016

Via E -mail
Michael Lehrman
Chairman and Chief Executive Officer
Rodin Global Property Trust, Inc.
110 E. 59th Street
New York, NY 10022

Re: Rodin Global Property Trust, Inc.
Amendment No. 3 to
Draft Registration Statement on Form S-11
Submitted September 14, 2016
  CIK No. 001666244

Dear Mr. Lehrman :

We have reviewed your amended draft registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us w ith information so we
may better understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  If yo u do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have additional
comments.

General

1. We note your response to prior comment 1. Please tell us, with a view toward revised
disclosure, why you refer to the board’s abili ty to use funds on a monthly  basis despite
the plan being based on each quarter, not each month. Also, please tell us why you will
“attempt to honor” requests on a pro rata basis when you are otherwise unable to
purchase all shares requested to be repurchased during a quarter. Finall y, we reissue the
portion of the prior comment in which we sought your analysis of your ability to
automatically repurchase shares from holders who would hold fewer shares than the
minimum purchase requirements as a result of an existing repurchase request .

Michael Lehrman
Rodin Global Property Trust, Inc.
October 6, 2016
Page 2

 2. Please add disclosure regarding the timing and circumstances surrounding your change in
name from Rodin Global Access Property Trust, Inc. to Rodin Global Property Trust, Inc.

Questions and Answers About this Offering

What kind of offering is this?, p age 2

3. If known, please disclose throughout the prospectus when during each quarter you expect
to publish any adjustments to the offering prices or, if you do not expect this to occur at
the same time each quarter, please disclose this fact.

Risk Factors

Risks Related to an Investment in Us

Valuations an d appraisals of our properties…, page 29

4. We note your disclosure that “[b] ecause the price you will pay for Cl ass T Shares or
Class I Shares… are based on our estimated NAV per share ….”  Please revise to reflect
that the price investors will pay for each share class will be based on your estimated NAV
per share after you commence valuations.

Estimated Use of Proceeds, page 64

5. Please remove the adjustment for sponsor support of selling commissions and dealer
manager fees from the use of proceeds table.  T he contingent reimbursement to your
advisor is a cost to the business; it is our view that these amounts should be reflected in
the Use of Proceeds Table.   Please ensure that the Use of Proceeds Table d educts the
selling commissions and dealer manager fees  in computing the amount available for
investment given the fact that the advisor is not gifting this amount to the issuer, but
instead will receive a contingent reimbursement right.   Footnote disclosur e may convey
the sponsor support; however, this amount should not be added back into net proceeds in
the table.

6. In a footnote to the table on page 65, please provide a description of the acquisition
expenses you intend to pay to your Advisor or its affi liates.

Management

The Advisory Agreement, page 76

7. We note your statement that compensation to your advisor may be increased “subject to
approval by our independent directors and the other limitations in our advisory agreement

Michael Lehrman
Rodin Global Property Trust, Inc.
October 6, 2016
Page 3

 and our charter.”  Please revise to disclose, if true, that the company may increase fees
payable to the advisor without shareholder consent.

Certain Prior Experience

Cantor Commercial Real Estate, page 78

8. We note your response to comment 2.  To the extent you believe that CCR E’s 2015 and
2016 CMBS securitization performance is a material adverse business development or
condition with respect to CCRE, please disclose this development in your prospectus.

Net Asset Value Calculation and Valuation Procedures, page 118

9. We note your disclosure that, with the approval of your board of directors, including a
majority of your independent directors, you will engage an independent valuation firm to
calculate your NAV.  Please confirm that your quantitative NAV disclosures will be
expertised. If your NAV disclosures will be expertised, please confirm that you will file
the third party consent and revise your expert section to identify the expert and the
disclosures being expertised, when appropriate.

10. Please provide us, on a supplementa l basis, with your template for future NAV
disclosures.

11. Please revise to clarify how you intend to value the sponsor reimbursement right for
purposes of calculating NAV.

Plan of Distribution, page 169

12. We note your disclosure that “[p] romptly  following any adjustment to the offering prices
per share, we will file a prospectus supplement or post -effective amendment to the
registration statement with the SEC disclosing the adjusted offering prices and the
effective date of such adjusted offering  prices, and we will also post the updated
information on our website at www.rodinglobalpropertytrust.com .”  We also note your
disclosure on page 30 that “[i] nvestors will purchase shares at the offering price that is
effective at the time that his or her completed subscription agreement has been accepted
by our dealer manager. As a result, the offering price may change prior to the acceptance
of such subscription by our dealer manager from the price that was effective at the time
such investor submitted hi s or her subscription agreement. ”  Please tell us how you intend
to update investors if there has been a change in NAV after the time an investor submits a
subscription agreement and prior to the subscription agreement being accepted by your
dealer manager . Please also tell us how you determined that this is an appropriate pricing
mechanism for a continuous offering since  the investor is not provided with an
opportunity to withdraw the subscription after notification of the new price.

Michael Lehrman
Rodin Global Property Trust, Inc.
October 6, 2016
Page 4

 You may contact Jorge  L. Bonilla, Staff Accountant, at (202) 551 -3414 or Shannon
Sobotka, Staff Accountant, at (202) 551 -3856 if you have questions regarding comments on the
financial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202)
551-8625 or me at (202) 551 -3215 with any other questions.

Sincerely,

 /s/ Kim McManus

Kim McManus
Senior Attorney
Office of Real Estate and
Commodities

cc: Judith D. Fryer, Esq.
 Joseph A. Herz, Esq.
 Greenberg Traurig, LLP

Mail Stop 3233
August 5, 2016

Via E -mail
Michael Lehrman
Chairman and Chief Executive Officer
Rodin Global Access Property Trust, Inc.
110 E. 59th Street
New York, NY 10022

Re: Rodin Global Access Property Trust, Inc.
Amendment No. 2 to
Draft Registration Statement on Form S-11
Submitted July 19, 2016
  CIK No. 0001666244

Dear Mr. Lehrman :

We have reviewed your amended draft registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in re sponse to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

General

1. We note your response to comment 5 in our letter dated March 16, 2016.  Please provide
us support for the f ollowing features of your share repurchase program: the establishment
of the share repurchase price based on a holder’s account statement; the restriction of the
price based on a public offering price for an ongoing offer; the requirement to submit a
repur chase request at least five business days prior to the end of a month; and, your
ability to repurchase shares from holders who would hold fewer shares than the minimum
purchase requirements as a result of an existing repurchase request. Also, please revise
your disclosure to clarify the availability of withdrawal rights and any deadline to
exercise such rights. Finally, we also note a reference to a holding period in your
disclosure: please tell us, with a view toward revised disclosure, the basis for impos ing

Michael Lehrman
Rodin Global Access Property Trust, Inc.
August 5, 2016
Page 2

 such a period and your legal analysis for waiving such a holding period in certain
described circumstances.

2. We note your response to comment 3.   We also note that you highlight CCRE’s business
in the summary and when discussi ng Cantor’s prior experien ce, however, this disclosure
is limited to only a discrete subset of information.   Please revise to disclose if CCRE has
experienced any material adverse business developments or conditions and to ensure that
the information presented about Cantor’s past e xperience and performance is balanced.

Prospectus Summary

Compensation to Our Advisor and its Affiliates

Special Units – Rodin Global Access Property Trust OP Holdings, LLC, page 21

3. We note your response to comment 5.  Please provide examples of how an individual
stockholder may receive more or less than the 6.0% cumulative, non -compounded annual
pre-tax return on their net contributions prior to the commencement of distributions to t he
holder of the special units.

4. We note your response to comment 6.  Please revise your disclosure to clarify if the “6%
return on their shares of common stock” is calculated in the same manner as the “6.0%
cumulative, non -compounded annual pre -tax return  on invested capital.”

Management

Executive Officers and Directors, page 78

5. Please provide the disclosure required by Item 401 of Regulation S -K for the executive
officers of Cantor Global Property Advisors, LLC .

Management Compensation

Special Units – Rodin Global Access Property Trust OP Holdings, LLC , page 96

6. Please clarify footnote 10 to confirm, if true, that  Rodin Global Access Property Trust OP
Holdings, LLC will  not be entitled to 15% of the remaining consideration that would be
deemed to have  been distributed to the  holders of the shares of common stock after such
holders have received a return of capital and a 6% return on their shares of common stock
if the advisory agreement is terminated for “cause.”

Michael Lehrman
Rodin Global Access Property Trust, Inc.
August 5, 2016
Page 3

 You may contact Jorge L. Bonilla, St aff Accountant, at (202) 551 -3414 or Shannon
Sobotka, Staff Accountant, at (202) 551 -3856 if you have questions regarding comments on the
financial statements and related matters. Please contact Bryan Hough, Staff Attorney, at (202)
551-8625 or Kim McManus , Senior Attorney,  at (202) 551 -3215 with any other questions.

Sincerely,

 /s/ Tom K luck

Tom Kluck
Legal Branch Chief
Office of Real Estate and
Commodities

cc: Judith D. Fryer, Esq.
Joseph A. Herz, Esq.
Greenberg Traurig, LLP

Mailstop 3233
June 6, 2016

Via E -mail
Michael Lehrman
Chairman and Chief Executive Officer
Rodin Global Access Property Trust, Inc.
110 E. 59th Street
New York, NY 10022

Re: Rodin Global Access Property Trust, Inc.
Amendment No. 1 to Draft Registration Statement on Form S -11
Submitted May 12, 2016
  CIK No. 0001666244

Dear Mr. Lehrman :

We have reviewed your amended draft registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  If you do  not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

General

1. We are continuing to evaluate your response to comment 5 and may have further
comment.

2. Throughout the prospectus you state that the selling commissions on the Class T shares
are limited to 3.0%.  The distribution fee, however, is a form of underwriting
compensation that you will pay the Dealer Manager for the “distribution” or “sale” of
your shares.  It appears that the primary dif ference between the “selling commission” and
the “distribution fee” is the manner of calculation and timing of payment.  If true, please
revise your disclosure throughout the prospectus to clarify that the distribution fee is also
part of the selling commi ssion.

Michael Lehrman
Rodin Global Access Property Trust, Inc.
June 6, 2016
Page 2

3. We note your response to comment 7 of our letter and that you determined that neither
CCRE nor RRP is a program for purposes of Guide 5.   We further note your disclosure
that:

 Cantor Fitzgerald, L.P. is the indirect parent of your sponsor and adv isor, and
controls Cantor Commercial Real Estate and BGC Partners, Inc. (which includes
Newmark Grubb Knight Frank).
 Mr. Lehrman, your chairman, was a co -founder of CCRE and served as Co -CEO
from April 2014 -2016.

We understand that CCRE was a joint ve nture managed by Cantor and that your
chairman was a co -founder and CEO of CCRE.  Thus, please provide the disclosure
required by Industry Guide 5, including any relevant prior performance disclosure, or
provide us with a detailed analysis as to why CCRE n ot should be considered a prior
program sponsored by Cantor or its affiliates under Industry Guide 5.   We may have
further comment.

Prospectus Summary

Compensation to Our Advisor and its Affiliates

Special Units – Rodin Global Access Property Trust OP Holdings, LLC , page 19

4. We note your r esponse to comments 17, 18, and 19 of our letter.  It appears that the
disclosure in this section relates to two potential forms of compensation: (i) subordinated
distributions  to the special unit holder  equal to 15% o f your net cash flows  payable under
certain circumstances, and (ii) payments to the special unit holder upon redemption of the
special units under certain circumstances.  Please revise your disclosure in this section
and under the heading “Management Compe nsation” starting on page 84 to describe
these two forms of compensation separately, or advise.

5. We note your disclosure in this section stating that the special unit holder will be entitled
to receive 15% of your net cash flows after your stockholders h ave received “or are
deemed to have received,” in the aggregate, cumulative distributions equal to their
invested capital plus a 6% cumulative, non -compounded annual pre -tax return on such
invested capital  and y our sponsor has received reimbursement for th e payment of certain
selling commissions .  Please revise to clarify what you mean by “are deemed to have
received” and to further elaborate upon how the 6% cumulative, non -compounded annual
pre-tax return on invested capital  is calculated.  Additionally, p lease revise to clarify
whether an individual stockholder should expect to receive distributions equal to his or its
invested capital plus a 6% cumulative, non -compounded annual pre -tax return on such
invested capital  prior to payment to the special unit h older of 15% of net cash flows.

Michael Lehrman
Rodin Global Access Property Trust, Inc.
June 6, 2016
Page 3

 6. We note your response to comment 20 of our letter, and your disclosure in this section
stating that the special unit holder will be entitled to receive “15% of the remaining
consideration that would be deemed to have been distributed to the holders of the shares
of common stock after such holders have received a return of capital and a 6% return on
their shares of common stock ” upon the occurrence of certain liquidity events or the
termination or non -renewal of the advisory  agreement.  Please revise to clarify what you
mean by “ would be deemed to have been distributed ” and to further elaborate upon how
the 6% return is calculated in this context.

7. We note your disclosure in this section, stating “ If the triggering event is the termination
or non -renewal of our advisory agreement other than for cause, the enterprise valuation
will be calculated based on an appraisal or valuation of our assets. ”  We further note your
risk factor disclosure under the heading “ Our advisor faces conflicts of interest relating to
incentive compensation and sponsor support structure  . . .” on page 34, stating “ Upon
termination of our advisory agreement for any reason, including for cause, . . . the special
unit holder may be entitled to a one -time p ayment upon redemption of the special units
(based on an appraisal or valuation of our portfolio) in the event that the special unit
holder would have been entitled to a subordinated distribution had the portfolio been
liquidated on the termination date ,” as well as similar disclosure on pages 78 -79.  Please
revise to reconcile these disclosures and to clarify the circumstances when the special
unit holder will receive the redemption payment in the event that the advisory agreement
is terminated for cause.

Estimated Use of Proceeds, page 67

8. We note your response to comment 23 of our letter. We continue to note that your
sponsor can be reimbursed for the selling commissions under certain circumstances in
connection with certain liquidity events or upon the termination of the advisory
agreement by you or by the advisor.  As the contingent reimbursement of selling
commissions to your sponsor is a cost to the business, it is our view that these amounts
should be reflected in the Use of Proceeds tables.  We ther efore respectfully reissue our
prior comment.  Please ensure that the Use of Proceeds tables deduct the selling
commissions without adding them back as “Sponsor Support of Selling Commissions” in
computing the amount available for investment given the fact  that the sponsor is not
gifting this amount to the issuer, but instead will receive a contingent reimbursement
right.

9. We note your response to comment 25. Please revise your disclosure in footnote (6), (7)
and (5) on pages 68, 70, and 71, respectively, to include the clarification provided in your
response and show how you determined the amounts of acquisition fees and acquisition
expenses presented in these footnotes.

Michael Lehrman
Rodin Global Access Property Trust, Inc.
June 6, 2016
Page 4

 Management Compensation, page 84
10. We note your response to comment 27, which seems t o focus on the manner in which you
will notif y shareholders of changes to advisory compensation.  Please also revise to
clarify if the company may increase fees payable to the advisor without shareholder
consent.

Plan of Distribution, page 168

11. We note your response to comment 33 and disclosure on page 172 stating that your
officers, directors, as well as officers and employees of your sponsor and advisor, etc.
may purchase shares in the offering and that “they would expect to hold such shares as
stockholders for investment and not for distribution.”  Please revise to clarify that they
“will hold” such shares for inve stment and not for distribution.

You may contact Jorge L. Bonilla, Staff Accountant, at (202) 551 -3414 or Shannon
Sobotka, Staff  Accountant, at (202) 551 -3856 if you have questions regarding comments on the
financial statements and related matters.  Please contact Bryan Hough, Staff Attorney , at (202)
551-8625  or me at (202) 551 -3215 with any other questions.

Sincerely,

 /s/ Kim McManus

 Kim McManus
Senior Attorney
Office of Real Estate and
Commodities
cc: Judith D. Fryer, Esq.
Joseph A. Herz, Esq.
Greenberg Traurig, LLP

Mailstop 3233
March 16, 2016

Via E -mail
Michael Lehrman
Chairman and Chief Executive Officer
Rodin Global Access Property Trust, Inc.
110 E. 59th Street
New York, NY 10022

Re: Rodin Global Access Property Trust, Inc.
Draft Registration Statement on Form S -11
Submitted February 18, 2016
  CIK No. 0001666244

Dear Mr. Lehrman :

We have reviewed your draft registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your  registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to th ese comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.

General

1. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities  Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications.

2. Please provide us with copies of any graphics, maps,  photographs, and related captions or
other artwork including logos that you intend to use in the prospectus. Such graphics and
pictorial representations should not be included in any preliminary prospectus distributed
to prospective investors prior to our  review.

Michael Lehrman
Rodin Global Access Property Trust, Inc.
March 16, 2016
Page 2

 3. Please submit all written sales materials proposed to be transmitted to prospective
investors, orally or in writing, including that intended for broker -dealer use only. Please
be aware that we will need time to review these materials. In addition , note that sales
materials must set forth a balanced presentation of the risks and rewards to investors and
should not contain any information or disclosure that is not contained in or derived from
the prospectus. For guidance, please refer to Item 19.D o f Industry Guide 5. Please also
confirm that you will continue to provide us sales materials prior to use for the duration
of the registered offering.

4. We note that you have included disclosure indicating that you may invest in loans related
to net leased commercial properties and commercial real estate related securities, and that
you may acquire properties through a joint venture ownership structure. We further note
that you intend to operate your business in a manner that will permit you to maintain an
exemption from registration under the 1940 Act. Please provide us with a detailed
analysis of the exemption that you and your subsidiaries intend to rely on and how your
investment strategy will support that exemption. Please note that we will refer your
response to the Division of Investment Management for further review.

5. Please provide us with a detailed legal analysis of the applicability of the tender offer
rules, including Rule 13e -4 and Regulation 14E, to your share repurchase plan. We urge
you to con sider 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. See, for example, T REIT Inc. (Letter dated June 4, 2001) and Wells
Real Estate Investment Trust II, Inc. (Letter dated December 3, 2003). To the extent you
have questions as to whether the program is entirely consistent with the relief previously
granted by the Division of Corporation Financ e, you may contact the divisio n’s Office of
Mergers and Acquisitions. Please note that we will refer your response to the Office of
Mergers and Acquisition for further review.

6. We note that you may conduct the share repurchase program during the offering period of
the shares being regi stered under this registration statement. Please be advised that you
are responsible for analyzing the applicability of Regulation M to your share repurchase
program. We urge you to consider all the elements of your share repurchase program 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 program is
entirely cons istent with that class exemption you may contact the Division of Trading and
Markets at 202 -551-5777.

7. We note your disclosure on page 10, stating “Our advisor ’s executives possess a unique
combination of real estate and corporate credit evaluation and in vestment expertise and,
throughout their careers, have collectively acquired, originated, structured and/or
managed over $100 billion of real estate investments consistent with our company ’s
investment strategy and over numerous real estate cycles. ”  We fu rther note your

Michael Lehrman
Rodin Global Access Property Trust, Inc.
March 16, 2016
Page 3

 disclosure on page 31, under the heading “Our sponsor and its affiliates have not
sponsored prior real estate investment programs that otherwise would be required to be
disclosed under applicable rules and regulations of the SEC, which mean s that you will
be unable to assess their prior performance with other investment programs. ”  Please
provide the disclosure required by Industry Guide 5, including any relevant prior
performance disclosure, or provide us with a detailed analysis of you bel ieve it is not
required. Please also refer to CF Disclosure Guidance: Topic No. 6.

8. Please revise the outside back cover page of the prospectus to advise dealers of their
prospectus delivery obligation, including the expiration date specified by Section 4( 3) of
the Securities Act.  Please refer to Item 502(b) of Regulation S -K.

9. We note your disclosure that you reserve the right to reallocate shares of common stock
between the classes identified.  Please provide us your analysis as to why you believe the
classes of shares are the same security for registration purposes.  We note that the classes
differ in offering price, underwriting commissions and distribution amounts.

10. Please expand your disclosure to describe factors considered in determining the offerin g
price.  See Item 505(a) of Regulation S -K.

Prospectus Cover Page

11. We note your disclosure under the heading “Liquidity” on page 24 and under the heading
“If we do not successfully implement a liquidity transaction, you may have to hold your
investment for an indefinite period ” on page 37.  Please include a summary risk factor on
your cover page to clarify, if true, that you are not required to pursue or effect a liquidity
event within a specified time frame or at all.

12. The tabular disclosure outlining proceeds to the issuer indicates that if only the minimum
offering amount is raised the company will pay no selling commissions or dealer
manager fees, and that that issuer will incur no organizational and offering costs.  This is
not consistent with discl osure on pages 15, 30, and 68.  Please revise to reconcile and
ensure the cover page includes all information required by Item 501(b)(3) of Regulation
S-K.

13. Please revise the cover to describe your escrow arrangements and disclose that if the $2
million mi nimum sales threshold is not met within one year from the date of the
prospectus, the offering will terminate and you will promptly return funds to subscribers.
Please refer to Item 501(b)(8)(iii).

Michael Lehrman
Rodin Global Access Property Trust, Inc.
March 16, 2016
Page 4

 Prospectus Summary

Compensation to Our Advisor and it s Affiliates, page 14

14. Please revise your disclosure in this table to clarify the recipient of each type of
compensation.

Reimbursement of certain offering expenses to our sponsor and its affiliates, page 19

15. Please revise to clarify the liquidity events that could trigger a reimbursement of selling
commissions paid by your sponsor.

16. We note your disclosure that you cannot determine the minimum or maximum amounts
of reimbursement of selling commissions at this time.  However, we note that in the
tables under “Estimated Use of Proceeds ” on page 67 you have quantified the minimum
and max imum amounts of the sponsor support of selling commissions and indicated that
such amounts are subject to a reimbursement under certain circumstances.  Please revise
this section to reconcile these disclosures or advise us why you believe such
reconciliati on is not necessary.

Special Units, page 19

17. We note your disclosure that Rodin Global Access Property Trust OP Holdings, LLC was
issued special units and will receive distributions on such special units equal to 15% of
your net cash flows under the circu mstances described in this section “in consideration of
services to be provided by [your] advisor. ”  Please revise to clarify the services for which
the special units and distributions thereon are consideration.

18. Please revise your disclosure to clarify a t what time(s) and with what frequency Rodin
Global Access Property Trust OP Holdings, LLC will be entitled to receive distributions
equal to 15% of your net cash flows under the circumstances described in this section.

19. We note your disclosure in this sec tion stating, “In addition, Rodin Global Access
Property Trust OP Holdings, LLC will be entitled to a separate payment if it redeems its
special units. ”  Please revise to clarify whether this “separate payment ” is the redemption
payment described in this s ection or a different payment in addition to the redemption
payment and, in the latter case, please revise to describe in more detail and to quantify
this separate payment payable upon redemption.

20. We note your disclosure in this section describing the re demption payment as the
“amount that Rodin Global Access Property Trust OP Holdings, LLC would have been
entitled to receive had our operating partnership disposed of all of its assets at the
enterprise valuation as of the date of the event triggering the redemption. ”  Please revise
to clarify how you will determine the share of the enterprise valuation to which Rodin

Michael Lehrman
Rodin Global Access Property Trust, Inc.
March 16, 2016
Page 5

 Global Access Property Trust OP Holdings, LLC will be entitled at the time of a
triggering event.

Distributions, page 22

21. Please revise your  disclosure to clarify whether the Class I shares purchased by your
sponsor pursuant to the distribution support commitment will be eligible to participate in
all distributions paid on Class I shares.

Risk Factors

If we pay cash distributions from sour ces other than our cash flow from operations, we will have
less funds available for investments and your overall return may be reduced, page 27

22. Please revise to specifically address the dilution to new investors caused by distributions
made to stockholder s that are in excess of taxable income.

Estimated Use of Proceeds, page 67

23. Please revise the table to eliminate the adjustment for the sponsor support of selling
commissions given the fact that the advisor is not gifting this amount to the issuer, but
instead will receive a contingent reimbursement right.  Since your sponsor can be
reimbursed for the selling commissions under certain circumstances in connection with a
liquidity event or upon termination of the advisory agreement by you without cause or by
the advisor with good reason, the contingent reimbursement is a cost to the business.  It is
our view that this amount should be reflected in the Use of Proceeds Table.

24. Please revise the table presenting information about use of proceeds raised in the offering
with respect to Class T shares, and footnote 4 thereto, to include a separate footnote
discussing the distribution fees payable to your dealer manager.  Additionally, please
include a reference to the new footnote in the rows labeled “Selling Comm issions” and
“Dealer Manager Fee. ”

25. Please refer to your disclosure in footnote 6 on pages 68 and 70, and footnote 5 on page
71. Please tell us how you determined the amounts of acquisition fees and acquisition
expenses presented in these footnotes and clarify whether these amounts reflect
acquisition fees and acquisition expenses that would be applicable to the entire portfolio
or just the leveraged portion.

Management, page 72

26. Please provide separate disclosure regarding the significant employees of  your advisor, or
advise us why no such disclosure is material to stockholders.  Please refer to Item 401(c)
of Regulation S -K.

Michael Lehrman
Rodin Global Access Property Trust, Inc.
March 16, 2016
Page 6

Management Compensation, page 83

27. We note your disclosure in footnote 6 on pages 68 and 70, and footnote 5 on page 71, that
compensation to be paid to your advisor may be increased subject to approval by your
independent directors and the other limitations in your advisory agreement and your
charter.  Please disclose whether you may increase the compensation payable to your
adviso r and its affiliates without notice to , or consent of,  your stockholders.

28. We note your disclosure in footnote 6, stating “maximum amount of underwriting
compensation from all sources is $90,500,000 million, which is 90.5% of the maximum
amount of gross o ffering proceeds . . . . ”  Please revise to clarify, if true, that the
maximum amount of underwriting compensation reflected in the table is 9.05% of the
maximum gross offering proceeds.  Additionally, we note your disclosure elsewhere that
you may, under certain circumstances, continue paying the distribution fee until either
total underwriting compensation paid with respect to all Class, A, Class T, and Class I
shares would be in excess of 10% of gross primary offering proceeds or total
underwriting compe nsation with respect to a particular stockholder ’s Class T shares
would be in excess of 10% of total gross offering price at the time of the investment in
the Class T Shares held in such account.  Please reconcile that disclosure to your
disclosure in foot note 6 indicating that you have assumed for purposes of this table that
total maximum underwriting compensation will be 9.05% of maximum gross offering
proceeds.

Stock Ownership, page 90

29. In a footnote to the table, please disclose the name(s) of the natural person(s) that have
ultimate voting or dispositive control over the company ’s common shares that are held by
Cantor Real Estate Investment Management, LLC.

Conflicts of Interest, page 91

30. Please revise your disclosure in this section to include al l of the disclosures required by
Item 404 of Regulation S -K or cross -references to the sections where such information
may be found.

Investment Objectives and Criteria, page 98

31. We note your disclosure that your board may revise your investment policies without the
approval of your stockholders.  Please revise to clarify how you will notify stockholders
of changes in your investment policies.

Michael Lehrman
Rodin Global Access Property Trust, Inc.
March 16, 2016
Page 7

 Underwriting Process, page 104

32. We note that you intend to invest primarily in single -tenant net leased commerc ial
properties.  We further note your disclosure regarding your procedures for evaluating
tenant creditworthiness.  Please revise to disclose whether, and if so how, you plan to
monitor the creditworthiness of your net lease tenants on an ongoing basis.

Plan of Distribution, page 167

33. We note that your executive officers and directors, as well as officers and employees of
your sponsor, your advisor and your sponsor ’s and advisor ’s affiliates and their
respective immediate family members, may pur