SecProbe.io

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 VIA EDGAR

 March 13, 2025

 United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549

 Re: Community Healthcare Trust Incorporated
Acceleration Request for Registration Statement on Form S-3
File No. 333-285041

 Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended (the " Act "), Community Healthcare Trust Incorporated (the " Company ")
hereby requests that the effective date of the above-referenced registration statement (the " Registration Statement ")
be accelerated to March 17, 2025 at 4:30 pm, Eastern Time, or as soon thereafter as practicable, unless we or our outside counsel,
Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, request by telephone that such Registration Statement be declared effective
at some other time. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.

 If you have any questions,
or once the Registration Statement is effective, please contact our counsel, Tonya Mitchem Grindon of Baker, Donelson, Bearman, Caldwell &
Berkowitz, PC, by email at tgrindon@bakerdonelson.com or by telephone at (615) 726-5607.

 Sincerely,

 Community Healthcare Trust Incorporated

 /s/ David H. Dupuy

 David H. Dupuy

 Chief Executive Officer and President

 cc: Tonya Mitchem Grindon

 Baker, Donelson, Bearman, Caldwell & Berkowitz, PC

February 24, 2025
David H. Dupuy
Chief Executive Officer
Community Healthcare Trust Incorporated
3326 Aspen Grove Drive
Suite 150
Franklin, Tennessee 37067
Re:Community Healthcare Trust Incorporated
Registration Statement on Form S-3
Filed February 19, 2025
File No. 333-285041
Dear David H. Dupuy:
            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 Ruairi Regan at 202-551-3269 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Tonya Mitchem Grindon, Esq.

June 7, 2019
David Dupuy
Executive Vice President and Chief Financial Officer
Community Healthcare Trust Inc
3326 Aspen Grove Drive, Suite 150
Franklin, TN 37067
Re:Community Healthcare Trust Inc
Form 10-K for the year ended December 31, 2018
Filed February 26, 2019
File No. 001-37401
Dear Mr. Dupuy:
            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 and
Commodities

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		Document

June 4, 2019

Mr. Eric McPhee

Mr. Daniel Gordon

Office of Real Estate and Commodities

Division of Corporation Finance

United States Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549-3561

VIA: EDGAR

Re:     Community Healthcare Trust Incorporated

Form 10-K for the year ended December 31, 2018

Filed February 26, 2019

File No. 001-37401

Dear Mr. McPhee and Mr. Gordon:

This letter is offered in response to the letter, dated June 3, 2019, from the staff of the Division of Corporation Finance (the “Staff”) to Community Healthcare Trust Incorporated (the “Company”) regarding the above referenced filing.

The Company’s responses to the Staff’s comments follow:

Form 10-K for the year ended December 31, 2018

Liquidity and Capital Resources, page 52

Comment No. 1: We note that your dividend payments have exceeded Net cash provided by operating activities for each full year since you commenced operations. In future filings, please discuss the sources of these payments, and to the extent there is a material risk that you will have to reduce your dividend payments, provide a discussion of such risk.

Response: In future filings, the Company will discuss the sources of our dividend payments which exceed Net cash provided by operating activities. Also, if management believes there is a material risk that the Company will have to reduce its dividend payments, the Company will provide a discussion of such risk.

Suite 150

 3326 Aspen Grove Drive

 Franklin

 TN

 37067

Should you wish to further discuss your comments and our responses thereto, please feel free to call me at (615) 807-2403.

Sincerely,

/s/ David H. Dupuy

David H. Dupuy

Executive Vice President and Chief Financial Officer

Suite 150

 3326 Aspen Grove Drive

 Franklin

 TN

 37067

June 3, 2019
David Dupuy
Executive Vice President and Chief Financial Officer
Community Healthcare Trust Inc
3326 Aspen Grove Drive, Suite 150
Franklin, TN 37067
Re:Community Healthcare Trust Inc
Form 10-K for the year ended December 31, 2018
Filed February 26, 2019
File No. 001-37401
Dear Mr. Dupuy:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the year ended December 31, 2018
Liquidity and Capital Resources, page 52
1.We note that your dividend payments have exceeded Net cash provided by operating
activities for each full year since you commenced operations.  In future filings, please
discuss the sources of these payments, and to the extent there is a material risk that you
will have to reduce your dividend payments, provide a discussion of such risk.
            In closing, 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.
            You may contact Eric McPhee at 202-551-3693 or Daniel Gordon at 202-551-3486 with
any questions.

 FirstName LastNameDavid Dupuy
 Comapany NameCommunity Healthcare Trust Inc
 June 3, 2019 Page 2
 FirstName LastName
David Dupuy
Community Healthcare Trust Inc
June 3, 2019
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities

Mail Stop 3233
September 22, 2016

Via E -mail
Timothy G. Wallace
Community Healthcare Trust Incorporated
3326 Aspen Grove Drive, Suite 150
Franklin, Tennessee 37067

Re: Community Healthcare Trust Incorporated
  Registration Statement on Form S-3
Filed  September 13, 2016
  File No.  333-213614

Dear Mr. Wallace :

This is to advise you that we have not  reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;

 the action of the Commission or the 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 th e filing; and

 the company may not assert staff comments and 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 refer to Rules 460 and 4 61 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities u nder

Timothy G. Wallace
Community Healthcare Trust Incorporated
September 22, 2016
Page 2

 the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please  contact me at (202) 551 -3799 with any questions.

Sincerely,

 /s/ Rahul K. Patel

 Rahul K. Patel
 Staff Attorney
Office of Real Estate and
Commodities

cc: Tonya Grindon, Esq.

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COMMUNITY HEALTHCARE TRUST INCORPORATED

COMMUNITY HEALTHCARE OP, LP

3326 Aspen Grove Drive

Suite 150

Franklin, Tennessee 37067

September 22, 2016

VIA EDGAR

Mr. Rahul Patel

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Re:                             Community Healthcare Trust Incorporated and Community Healthcare OP, LP

Registration Statement on Form S-3

File Number 333-213614 and 333-213614-1

REQUEST FOR ACCELERATION OF EFFECTIVENESS

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Community Healthcare Trust Incorporated and Community Healthcare OP, LP (together, the “Registrants”) hereby request acceleration of effectiveness of the registration statement on Form S-3 (File No. 333-213614 and 333-213614-1) to 4:00 p.m., Eastern Time, on September 26, 2016 or as soon as practicable thereafter.

In connection with this request, the Registrants acknowledge that:

·                  should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·                  the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·                  the Registrants may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact our legal counsel, Tonya Mitchem Grindon, of Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, at (615) 726-5607, if you have any questions concerning this request.

Very truly yours,

Community Healthcare   Trust Incorporated

By:

/s/ Timothy G. Wallace

Name:

Timothy G. Wallace

Title:

Chief Executive Officer   and President

Community Healthcare   OP, LP

By:

Community Healthcare   Trust Incorporated,

its sole general   partner

By:

/s/ Timothy G. Wallace

Name:

Timothy G. Wallace

Title:

Chief Executive Officer   and President

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[LETTERHEAD OF SANDLER O’NEILL & PARTNERS]

April 5, 2016

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:                             Community Healthcare Trust Incorporated

Registration Statement on Form S-11 (Registration Number 333-210397)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended (the “Act”), we hereby join Community Healthcare Trust Incorporated (the “Company”) in requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 5:00 p.m. on April 6, 2016, or as soon thereafter as may be practicable.

Pursuant to Rule 460 of the Act, we wish to advise you that we and the other underwriters have effected the following distribution of the Company’s Preliminary Prospectus, dated March 31, 2016, through the date hereof:

Preliminary Prospectus, dated March 31, 2016:

588 copies to prospective underwriters, institutional investors, dealers and others.

The undersigned advise 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.  This letter replaces our letter to you dated April 4, 2016 regarding the above-referenced Registration Statement.

Very   Truly Yours,

Sandler   O’Neill & Partners, L.P.

Evercore   Group L.L.C.

SunTrust   Robinson Humphrey, Inc.

By:

Sandler   O’Neill & Partners, L.P.,

As   representative of the several underwriters

By:

Sandler   O’Neill & Partners, Corp.,

the   sole general partner

/s/   Jennifer Docherty

Jennifer   Docherty

Authorized   Signatory

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April 4, 2016

VIA EDGAR

U.S. Securities and   Exchange Commission

Division of Corporation   Finance

100 F. Street, N.E.

Washington, D.C. 20549

Re:

Community Healthcare Trust Incorporated

Registration Statement on   Form S-11

File Number 333-210397

REQUEST FOR ACCELERATION OF   EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, Community Healthcare Trust Incorporated (the “Company”) hereby respectfully requests acceleration of the effectiveness of the Company’s Registration Statement on Form S-11, File Number 333-210397, so that it will be declared effective on Wednesday, April 6, 2016 at 4:00 p.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company acknowledges that:

·                  should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·                  the action of the Commission or the 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

·                  the Company may not assert staff comments and 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 our legal counsel, Tonya Mitchem Grindon, of Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, at (615) 726-5607, if you have any questions concerning this request.

Very truly yours,

Community Healthcare   Trust Incorporated

By:

/s/ Timothy G. Wallace

Name:

Timothy G. Wallace

Title:

Chief Executive Officer   and President

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[LETTERHEAD OF SANDLER O’NEILL & PARTNERS]

April 4, 2016

VIA EDGAR

Securities   and Exchange Commission

100   F Street, N.E.

Washington,   D.C. 20549

Re:

Community Healthcare Trust Incorporated

Registration Statement on Form S-11 (Registration   Number 333-210397)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended (the “Act”), we hereby join Community Healthcare Trust Incorporated (the “Company”) in requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 4:00 p.m. on April 6, 2016, or as soon thereafter as may be practicable.

Very Truly   Yours,

Sandler   O’Neill & Partners, L.P.

Evercore Group L.L.C.

SunTrust Robinson Humphrey, Inc.

By:

Sandler   O’Neill & Partners, L.P.,

As representative of   the several underwriters

By:

Sandler   O’Neill & Partners, Corp.,

the sole general   partner

/s/ Jennifer Docherty

Jennifer Docherty

Authorized Signatory

Mail Stop 3233
March 29, 2016

Via E -mail
Timothy G. Wallace
Community Healthcare Trust Incorporated
3326 Aspen Grove Drive
Suite 150
Franklin, Tennessee 37067

Re: Community Healthcare  Trust Incorporated
  Registration Statement on Form S-11
Filed  March 24, 2016
  File No.  333-210397

Dear Mr. Wallace :

This is to advise you that we have not  reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are  in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In the event you request acceleration of the effective date of the pending regist ration
statement , please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action wit h respect
to the filing;

 the action of the Commission or the 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 th e filing; and

 the company may not assert staff comments and 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 refer to Rules 460 and 4 61 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation

Timothy G. Wallace
Community Healthcare Trust Incorporated
March 29, 2016
Page 2

 of the fact that those requesting acceleration are aware of their respective responsibilities u nder
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

Please  contact Rahul Patel, Staff Attorney,  at (202) 551 -3799  with any questions.

Sincerely,

 /s/ Tom Kluck

 Tom Kluck
Legal Branch Chief
Office of Real Estate and
Commodities

cc: Tonya Mitchem Grindon, Esq. (via E -mail)
 Baker, Donelson, Bearman, Caldwell & Berkowitz, PC

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[LETTERHEAD OF SANDLER O’NEILL & PARTNERS]

May 18, 2015

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Community Healthcare Trust Incorporated

Registration Statement on Form S-11 (Registration   Number 333-203210)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended (the “Act”), we hereby join Community Healthcare Trust Incorporated (the “Company”) in requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 4:00 p.m. on May 20, 2015, or as soon thereafter as may be practicable.

Pursuant to Rule 460 of the Act, we wish to advise you that we and the other underwriters have effected the following distribution of the Company’s Preliminary Prospectus, dated May 6, 2015, through the date hereof:

Preliminary Prospectus, dated May 6, 2015:

2,517 copies to prospective underwriters, institutional investors, dealers and others.

The undersigned advise 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.  This letter replaces our letter to you dated May 15, 2015 regarding the above-referenced Registration Statement.

Very   Truly Yours,

Sandler   O’Neill & Partners, L.P.

Evercore   Group L.L.C.

SunTrust   Robinson Humphrey, Inc.

As   representatives of the several underwriters

By:

Sandler   O’Neill & Partners, Corp.,

the   sole general partner of Sandler O’Neill & Partners, L.P.

/s/   Jennifer Docherty

Jennifer   Docherty

An   Officer of the Corporation

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Community Healthcare Trust

Incorporated

May 15, 2015

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Re:                             Community Healthcare Trust Incorporated

Registration Statement on Form S-11

File Number 333-203210

REQUEST FOR ACCELERATION OF EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, Community Healthcare Trust Incorporated (the “Company”) hereby respectfully requests acceleration of the effectiveness of the Company’s Registration Statement on Form S-11, File Number 333-203210, so that it will be declared effective on Wednesday, May 20, 2015 at 4:00 p.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company acknowledges that:

·                  should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·                  the action of the Commission or the 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

·                  the Company may not assert staff comments and 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 our legal counsel, Tonya Mitchem Grindon, of Baker, Donelson, Bearman, Caldwell & Berkowitz, PC, at (615) 726-5607, if you have any questions concerning this request.

Very   truly yours,

Community   Healthcare Trust Incorporated

By:

/s/   Timothy G. Wallace

Name:

Timothy   G. Wallace

Title:

Chief   Executive Officer and President

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[LETTERHEAD OF SANDLER O’NEILL & PARTNERS]

May 15, 2015

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Community Healthcare Trust Incorporated

Registration Statement on Form S-11 (Registration   Number 333-203210)

Request for Acceleration of Effectiveness

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, we hereby join Community Healthcare Trust Incorporated in requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 4:00 p.m. on May 20, 2015, or as soon thereafter as may be practicable.

Very   Truly Yours,

Sandler   O’Neill & Partners, L.P.

By:

Sandler   O’Neill & Partners, Corp.,

the   sole general partner

/s/   Jennifer Docherty

Jennifer   Docherty

An   Officer of the Corporation

May 4, 2015

Via E -mail
Timothy G. Wallace
President
Community Healthcare Trust Incorporated
Suite 106
354 Cool Springs Blvd.
Franklin, Tennessee 37067

Re: Community Healthcare Trust Incorporated
Amendment No. 1 to Registration Statement on Form S-11
Filed April 28, 2015
  File No. 333 -203210

Dear Mr. Wallace :

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 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.   Unless  we note
otherwise , our references to prior comments are to comments in our April 22, 2015  letter .

Distribution Policy

1. We note your line item disclosure in response to comment 1 of estim ated additional
general and administrative costs and estimated tenant improvements, leasing
commissions and capital expenditures.  Please revise to include footnotes explaining how
you estimated these items, including an explanation of how you define recur ring capital
expenditures and examples of items included or excluded.

2. Please revise your filing to present estimated cash available for distribution, as adjusted
on a trailing 12 months basis.

3. We note your response to comment 7.  Please revise  the title of the line item that is within
the table  and currently titled  ‘Estimated cash available for distribution’ to ‘Estimated cash
available for distribution as adjusted.’

Timothy G. Wallace
Community Healthcare Trust Incorporated
May 4, 2015
Page 2

 Financial Statements

Unaudited Pro Forma Consolidated Financial Statements, page F -3

4. We note your response to comment 11.  Please tell us how you determined it is not
necessary to value tenant improvements separately from building.  To the extent you do
not value them separately because you determined that separate classification is not
mate rial, please tell us how you made t hat determination.

5. We note your adjustment (3).  Please tell us and revise your filing to disclose how these
estimated acquisition costs and estimated offering costs are factually supportable.

6. We note your disclosure on page 92 that you are assuming the lease for Prairie Star
Medical Facility II and you will acquire all of the Series A Bonds and Series B Bonds.
Please tell us how you have reflected your acquisition of Prairie Star Medical Facil ity II
within your pro forma financial information.  Within your response, please reference any
authoritative accounting literature management relied upon.

You may contact Jorge Bonilla, Staff Accountant,  at (202) 551 -3414 or Jennifer Monick,
Senior Staff  Accountant,  at (202) 551 -3295 if you have questions regarding comments on the
financial statements and related matters.  Please contact Rahul Patel, Staff Attorney,  at (202)
551-3799 or me at (202) 551 -3655 with any other questions.

Sincerely,

 /s/ Sonia Gupta Barros

 Sonia  Gupta Barros
Assistant Director

cc: Tonya Mitchem Grindon, Esq.

April 22, 2015

Via E -mail
Timothy G. Wallace
President
Community Healthcare Trust Incorporated
Suite 106
354 Cool Springs Blvd.
Franklin, Tennessee 37067

Re: Community Healthcare Trust Incorporated
Registration Statement on Form S -11
Filed April 2, 2015
  File No. 333 -203210

Dear Mr. Wallace :

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
circumstances or do not bel ieve 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 March 18, 2015 letter .

Distribution Policy, page 57

1. We note your response to comments 5 and 6. Consistent with your response, please revise
to clarify why you have not incl uded the adjustments referenced in those comments and
the reason for the omission.

2. We note your response to comments 5 and 6.   We note that 19 leases are scheduled to
expire in 2016, which represents 26.2% of your revenue.  Please tell us what percentage
of your total annualized lease revenue will expire in each of the quarters in 2016.

3. We note your response to comments 5 and 6 and that based on management’s historical
experience and initial conversations with tenants, you anticipate that most of this space
will be renewed with minimal tenant improvements or leasing commissions.  To the

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 2

 extent that the leases expiring in the next 12 months would have a material impact on
your Estimated Cash Available for Distributions , please  tell us how your assumption  that
most of the leases expiring in the next 12 months will be renewed is consistent with the
3-year historical retention rate  for these properties .  Additionally, to the extent material,
please quantify for us your historical experience with respect to i ncurring tenant
improvements or leasing commission for renewing leases at these properties.  We may
have further comment.

4. We note your response to our comment 5 that existing owners expended only a minimal
amount of capital expenditures during 2014 and th at you expect that the Company will be
responsible for minimal recurring capital expenditures, if any.  Please tell us the amount
of capital expenditures that were incurred during 2014.  Further, please provide us with
the three year historical average of recurring capital expenditures for these properties.
We may have further comment.

5. It appears from the disclosure in the first paragraph on page 58 that the calculation of
estimated CAD includes recurring capital expenditures. Please revise to clarify how  your
calculation reflects those expenditures.

6. Please tell us why you refer to FFO in footnote (1) to the table on page 58 given that it is
not presented in your calculation of estimated CAD.

7. We note your response to comment 7.  Please further revise the line item ‘Estimated cash
available for distribution for the year ended December 31, 201 4’ to refer to it ‘as
adjusted. ’

8. We note your disclosure in footnote (1) on page 58 that states cash available for
distribution is intended to measure a REIT’s cash flow generated by operations and
available to pay dividends.   Please tell us if you intend to present CAD in future
filings.   If so, please note if you view CAD as a liquidity measure, it  should be reconciled
to a co mparable GAAP liquidity measure .  If you do not intend  to present CAD in future
filings, please tell us the purpose of including the discussion of CAD in this footnote.   We
note that estimated CAD for purposes of the Dividend P olicy section indicates that
estimated CAD is not a liquidity measure, but it appears that you view CAD as a liquidity
measure.   Please tell us how you were able to determine that estimated CAD is not a
liquidity measure but CAD is a liquidity measure.

Financial Statem ents

Unaudited Pro Forma Consolidated Financial Statements, page F -3

9. We note your revisions to your Rule 3 -14 financial statements indicate that certain
amounts in rental revenue include operating expense recoveries.  Please revise your P ro

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 3

 Forma Consolidated Statement of Income and your Rule 3 -14 financial statements to
disaggregate rental income and operating expense recoveries.

10. We note your response to comment 19.  As previously requested, please revise to include
a column reflect ing the historical result of operations of the Initial Properties separate
from pro forma adjustments resulting from business combination accounting and other
assumptions.  For example, as indicated in your response to comment 5, renewals and
replacements of leases that expired during the past 12 months have been reflected in the
pro forma calculation; thus, your adjustment (5) for rental income should be
disaggregated based on historical rental income and adjustments to historical rental
income.  Your revi sion to your filing should include your basis for any adjustments to
historical amounts.

11. We note your response to comment 22.  Please tell us how you considered the tenant
improvements, if any, in your allocation of the purchase price.

12. We note your r esponse to comment 23.  Please revise to clarify that you are not giving
effect to the credit facility because you have not received commitments from any lenders
consistent with your response to comment 11 and disclosure on page 68.

13. We note your response to comment 25.  Please expand footnote (7) to disclose the range
of amortization periods  and average amortization period for intangible assets.

14. We note your response to comment 26 and your revision to footnote (8).  We note that
this adjustment gives effect to the expected incremental costs of being a public company,
certain components of the adjustment for general and administrative expenses are based
on estimates and management’s prior experience managing a public REIT, and
anticipated property visit s.  The above items do not appear to be factually supportable.
Accordingly, please revise to exclude the expenses  that are not factually supportable .
However, you may disclose your estimate of the items that are not factually supportable
in a footnote.

Community Healthcare Trust Incorporated Consolidated Financial Statements

Notes to Consolidated Financial Statements

Purchase of Investment Properties, page F -16

15. We note your response to comment 27 and your revision to Note 3 on page F -17. Please
revise to clarify how you determine if the intangible should include any fixed rate
renewal options.

16. We note your response to comment 29. We await the inclusion of audited Regulation S -X
Rule 3 -14 financial statements for Provena  Medical Center for the three months ended

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 4

 March 31, 2015 in your next amendment to the registration statement. We refer you to
the letter of the Division of Corporation Finance, Chief Accountant’s Office, dated March
31, 2015 in response to your Rule 3 -14 waiver request.

Exhibits

17. We note that you have entered into purchase agreements to acquire the Initial Portfolio.
Please include these agreements as exhibits to the registration statement or tell us why
you believe they are not required.

We urge a ll persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its manag ement are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made .

Notwithstanding our comments, in the event you request acceleration of the effective date
of the  pending regist ration statement , please provide  a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any act ion with respect
to the filing;

 the action of the Commission or the 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

 the company may not assert staff comments and 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 refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respe ctive responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any  amendment prior to the requested effective date of the
registration statement.

Timothy  G. Wallace
Community Healthcare Trust Incorporated
April 2 2, 2015
Page 5

 You may contact Jorge Bonilla, Staff Accountant,  at (202) 551 -3414 or Jennifer Monick,
Senior Staff Accountant,  at (202) 551 -3295 if you have questions regarding comments on  the
financial statements and related matters.  Please contact Rahul Patel, Staff Attorney,  at (202)
551-3799 or me at (202) 551 -3655 with any other questions.

Sincerely,

 /s/ Sonia Gupta Barros

 Sonia Gupta Barros
Assistant Director

cc: Tonya Mitchem Grindon, Esq.

March 18, 2015

Via E -mail
Timothy G. Wallace
President
Community Healthcare Trust Incorporated
Suite 106
354 Cool Springs Blvd.
Franklin, Tennessee 37067

Re: Community Healthcare Trust Incorporated
Draft Registration Statement on Form S -11
Submitted February 17, 2015
  CIK No. 0001631569

Dear Mr. Wallace :

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 disclosu re.

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. 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 Securitie s Act, whether or
not they retain copies of the communications.

2. Please provide us with support for all quantitative and qualitative business and industry
data used in the registration statement.  As examples only, we note on page 8 you state,
“[s]tudies by the Medicare Payment Advisory Commission and others have shown that
healthcare is delivered more cost effectively and with higher patient satisfaction when it is
provided on an outpatient basis,” and on page 65 you state, “[o]ver 61.0% of Non -Urban
residents live in counties adjacent to urban areas.  Another 29.0% of Non -Urban residents

Timothy G. Wallace
Community Healthcare Trust Incorporated
March 18, 2015
Page 2

 live in counties that contain regional population centers, or micropolitan areas, that do not
directly border larger urban areas.” Clearly mark the specific language in t he supporting
materials that support each statement. Further, please tell us if any of the supporting
materials were prepared specifically for you in connection with this offering.  The
requested information should be filed as EDGAR correspondence or, alte rnatively, should
be sent in paper form accompanied by a cover letter indicating that the material is being
provided pursuant to Securities Act Rule 418 and that such material should be returned to
the registrant upon completion of the staff review process .

Prospectus Summary, page 1

3. We refer to the table of initial properties beginning on page 9 and the column titled
“Annualized Lease Revenue.”  We note per your disclosure in note 2 to the table that
annualized lease revenue was calculated using contract ual base rent. Please include, if
material, a discussion on the impact of tenant concessions and any free rent periods.  Please
make conforming changes to the Our Business section when discussing annualized lease
revenue.

Distribution Policy, page 57

4. Please revise to include the following disclosure:

 an introductory narrative that describes the purpose of the table and what it shows;

 summarize the cash items that may occur in next 12 months but which are excluded
from the table, such as changes in work ing capital and cash for/from acquisitions/
dispositions; and

 cautionary language that the table should not be considered an actual projection of cash
flows.

5. Please revise to clarify why you have not included adjustments for investing and financing
activ ities, if applicable, such as tenant improvements and leasing commissions
contractually required in next 12 months and estimates of these costs with respect to any
assumed renewals, estimated recurring capital expenditures on whole portfolio, and
scheduled  loan principal amortization payments.

6. Please revise to clarify why you have not included adjustments for operating cash flow
changes expected in next 12 months, if applicable, such as leases expiring in the next 12
months.  Additionally, to the extent there are any leases that expired during the past 12
months that have not been renewed, please tell us why you have not included an adjustment
for these expired leases.

Timothy G. Wallace
Community Healthcare Trust Incorporated
March 18, 2015
Page 3

 7. Please revise to present estimated, rather than pro forma, cash available for distribu tions.
Additionally, please revise to indicate that estimated cash available for distribution is either
for the year ended December 31, 2015 or for the year ended December 31, 2014, as
adjusted.

Selected Historical and Pro Forma Financial and Other Data,  page 60

8. Please revise to clarify that the pro forma information assumes the underwriters' option to
purchase additional shares of common stock is not exercised, consistent with your pro
forma capitalization information on page 58.

9. Please revise your dis closure on pages 18 and 61 to delete the line item Organization costs
from assets as we presume such cost will be expensed as incurred. Refer to ASC 720 -15-
25-1.

Management’s Discussion and Analysis of Financial Condition and Results of Operations , page 6 3

10. We note your disclosure on pages 23 and 99 that nine leases are scheduled to expire in
2015 and nineteen leases are scheduled to expire in 2016, which represent 2.9% and 26.2%
of your total annualized lease revenue, respectively.  Please revise your disclosure to
discuss your lease rollover expectations and the relationship between market rents and
expiring rents, or advise.

Liquidity and Capital Resources, page 67

11. To the extent that any relevant terms of the new credit facility are known although n ot
finalized, please provide such material terms including amounts available, related interest
rates, maturity dates, collateral requirements (if any), and any other material terms.

Funds from Operations , page 71 and Net Operating Income, page 72

12. Please revise the introductory narrative to these tables to delete the reference to historical
FFO and historical NOI since you are presenting only pro forma information.

Our Business, page 77

13. We note your risk factor disclosure on page 43 that you may change y our business,
investment, and financing strategies without stockholder approval.  Please disclose whether
shareholders will be notified of changes and, if so, how.  Please also disclose what factors
management may consider before making such changes.

14. We note that substantially all of your revenues will be derived from triple net leases.
Please discuss how you intend to monitor the credit quality of your tenants.

Timothy G. Wallace
Community Healthcare Trust Incorporated
March 18, 2015
Page 4

 Properties Under Evaluation, page 83

15. We note that you are in the process of evaluating approximately $125.7 million of potential
property acquisitions.  Please expand your disclosure to discuss the status of  these
purchase negotiations, if any, including your relationship to the seller and whether you
have a right of first offer or refusal for the properties, how you determined a property is
under evaluation for purposes of this disclosure, and how you assessed the aggregate
potential purchase price of such properties.  Please also supplementally tell us the impact of
any timing and due dili gence concerns and your historical timing and success rate of
pipeline completion.  Finally, please tell us what consideration you gave to including a risk
factor as to the uncertainty of these acquisitions.

Underwriting, page 182

16. When the full syndicati on has been determined, please revise to identify each underwriter
that has a prior or existing material relationship with you and state the nature of the
relationship.

Financial Statements

Unaudited Pro Forma Consolidated Financial Statements , page F-3

17. We note your disclosure that the pro forma financial statements give effect to the transfer
of properties based on the definitive agreements and the current agreements in principle.
We also note your disclosure on page 83 that you have identified and are in various stages
of evaluating approximately $125.7  million of potential acquisitions of properties of
healthcare providers none of which are subject to binding agreement. Please clarify
whether the major terms for the potential acquisitions have been agr eed to in principle and
how you considered FRC 506.02(c) .  Within your response, please provide to us
management’s analysis of the probability of closing these acquisitions including
management’s historical rate of closing such acquisitions.

18. Please revi se to disclose whether the initial Properties were acquired from unrelated parties.

19. Please revise the pro forma statement of income  to include a column reflecting the
historical result of operations of Initial Properties before adjustments related to the offering
and acquisition of the Initial Properties.

20. Please revise the pro forma statement of income  to present rental income and operating
costs on a gross basis, and revise adjustment (5) on page F -6 accordingly.

21. We note your disclosure on page 82 that certain lease s will be executed upon the
acquisition of the property. Please tell us how these leases were considered in preparing the
pro forma financial statements.

Timothy G. Wallace
Community Healthcare Trust Incorporated
March 18, 2015
Page 5

22. Please revise to disclose the allocation of the purchase price, including recognition of any
intangible assets, how you determined the valuation of assets, and the accounting guidance
you relied upon to determine the allocations.  Please address the valuation method for each
type of asset separately.

23. With respect to adjustment (4) to the balance sheet and adjustment (6) to the statement of
income, please tell us your basis for giving effect to the credit facility given your disclosure
on page 67 that you have not received commitments from any lenders for the anticipated
credit f acility.

24. We note your adjustment (6).  To the extent the actual interest rates could vary from the
interest rate depicted , please revise your filing to disclose the effect of a 1/8 percent
variance in interest rate.

25. We note you have included adjustment ( 7) for depreciation of buildings. Please tell us why
no adjustments have been included for amortization expense relating to intangible assets.

26. Please revise adjustment (8) to separately quantify each component of the adjustment and
the related assumption you used in estimating such amounts, including how you measured
the non -cash share -based compensation expense.  Additionally, please tell us how you
determined each item is factually supportable.

Community Healthcare Trust Incorporated  Consolidated Fina ncial Statements

Notes to Consolidated Financial Statements

Purchase of Investment Properties , page F -15

27. We note your disclosure that the value of above -or-below market leases is measured over a
period equal to the estimated remaining term of the lease.  Please revise to disclose how you
estimate the remaining term of the lease and the basis for your determination.  Your
revision should address, but not necessarily be limited to, any fixed rate renewal options.

Other Financial Statements , pages F -18 – F-61

Notes to Historical Statement of Revenues and Certain Direct Operating Expenses , page F -21

(3) Revenues, page F -21

28. For each of the properties for which you present a statement of revenues and certain direct
operating expenses, please disclose the difference between the rental revenue recorded and
the amount of lease payments due.

Timothy G. Wallace
Community Healthcare Trust Incorporated
March 18, 2015
Page 6

 Provena Medical Center Historical Statement of Revenues and Certain Direct Operating Expenses,
page F -58

29. In light of your inabilit y to provide a full year of financial information for Provena Medical
Center, pl ease provide us with your analysis of how you have complied with Rule 3 -14 of
Regulation S -X.

Exhibits

30. Please file all required exhibits as promptly as possible.  If you ar e not in a position to file
your legal and tax opinions in the next amendment, please provide a draft copy for us to
review.

You may contact Jorge Bonilla, Staff Accountant,  at (202) 551 -3414  or Jennifer Monick,
Senior Staff Accountant,  at (202) 551 -3295  if you have questions regarding comments on the
financial statements and related matters.  Please contact Rahul Patel, Staff Attorney,  at (202) 551 -
3799  or me at (202) 551 -3404  with any other questions.

Sincerely,

 /s/ Kristina Aberg

Kristina Aberg
Senior Counsel

cc:  Tonya Mitchem Grindon
 Baker, Donelson, Bearman, Caldwell  & Berkowitz, PC