SecProbe.io

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 September 2, 2025

J. Michael McGillis
Chief Financial Officer
Claros Mortgage Trust, Inc.
60 Columbus Circle, 20th Floor
New York, NY 10023

 Re: Claros Mortgage Trust, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 File No. 001-40993
Dear J. Michael McGillis:

 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
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 CORRESP

 10250 Constellation Blvd., Suite 1100
 Los Angeles, California 90067 Tel: +1.424.653.5500 Fax:
+1.424.653.5501 www.lw.com

 FIRM / AFFILIATE OFFICES

 Austin

 Milan

 Beijing

 Munich

 Boston

 New York

 Brussels

 Orange County

 Chicago

 Paris

 Dubai

 Riyadh

 August 27, 2025

 Düsseldorf

 San Diego

 Frankfurt

 San Francisco

 Hamburg

 Seoul

 Hong Kong

 Silicon Valley

 Houston

 Singapore

 London

 Tel Aviv

 Via EDGAR

 Los Angeles

 Tokyo

 Madrid

 Washington, D.C.
 U.S. Securities and Exchange Commission
 Division of Corporation Finance Office of Real Estate &
Construction 100 F Street, N.E. Washington, DC 20549
 Attention: Jeffrey Lewis and Shannon Menjivar

 Re:
 Claros Mortgage Trust, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Form 10-Q for the quarterly period ended June 30, 2025
 File No. 001-40993
 Dear Mr. Lewis and Ms. Menjivar: On
behalf of our client, Claros Mortgage Trust, Inc., a Maryland corporation (the “ Company ”), set forth below is the Company’s response to the comment letter, dated August 15, 2025, from the staff of the Division of
Corporation Finance (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ SEC ”), relating to the Company’s prior response to your previous comment letter dated August 4, 2025.
 For convenience of reference, the text of the Staff’s comment has been reproduced below in bold and italics, followed by the
Company’s response thereto. Form 10-Q for the quarterly period ended June 30, 2025
 Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations
 Results of Operations, page 52

 1.
 We note your response to comment 1 and that operating expenses for the Company’s real estate owned
portfolio are regularly provided to the Chief Operating Decision Maker and represent a significant segment expense determined in accordance with ASC
 280-10-50-26A. As such, please revise your disclosure in future filings to include a detailed description of the components of
operating expenses within your consolidated results of operations for the periods presented.

 August 27, 2025
 Page
2

 Response :
 The Company acknowledges the Staff’s comment. The Company respectfully advises the Staff that it will revise its subsequent periodic reports to include a
detailed description of the components of operating expenses within its consolidated results of operations for the periods presented, beginning with the Company’s next Form 10-Q filing for the period
ending September 30, 2025. For the Staff’s reference, below is updated disclosure marked to show changes against the disclosure included on
pages 52 and 53 of the Company’s Form 10-Q for the period ended June 30, 2025 as an example, for illustrative purposes only, of how the Company intends to expand its disclosure in future filings
( bold underscored language indicates new disclosure). Similar expanded disclosure will be included in both the quarter-over-quarter and nine months year-over-year Results of Operations discussions in the Company’s Form 10-Q for the period ending September 30, 2025. Sample Disclosure:
 Expenses Expenses are primarily comprised
of base management fees payable to our Manager, general and administrative expenses, stock-based compensation expense, operating expenses from real estate owned, interest expense from debt related to real estate owned hotel portfolio, and
depreciation and amortization on real estate owned and related in-place and other lease intangible values. Operating expenses from real estate owned primarily include real estate taxes, utilities,
repairs and maintenance, labor, insurance, marketing, and general and administrative expenses specific to our real estate owned properties. Expenses decreased by $0.1 million during the six months ended June 30, 2025, as compared
to the six months ended June 30, 2024, primarily due to:

 (i)
 a decrease in depreciation and amortization from real estate owned of $3.9 million primarily due to
depreciation expense not being recognized on the hotel portfolio during the six months ended June 30, 2025, as it is classified as held-for-sale;

 (ii)
 a decrease in management fees of $1.6 million as a result of lower stockholders’ equity over the
comparative period;

 (iii)
 partially offset by an increase in operating expenses on real estate owned of $1.9 million during the
comparative period, due to higher variable operating expenses such as labor costs and franchise fees in connection with higher occupancy levels at the hotel portfolio, and operating expenses such as real estate taxes, utilities,
and repairs and maintenance expenses now incurred from the multifamily properties we foreclosed on during the six months ended June 30, 2025;

 (iv)
 further offset by an increase in interest expense on real estate owned of $1.5 million during the
comparative period, due to additional interest being incurred on the debt related to the hotel portfolio pursuant to forbearance agreements prior to its refinancing on June 9, 2025, and interest expense recognized on debt related to the
multifamily properties we foreclosed on during the six months ended June 30, 2025;
 2

 August 27, 2025
 Page
3

 (v)
 further offset by an increase in stock-based compensation of $1.5 million during the comparative period,
due to forfeitures during the six months ended June 30, 2024 and an increase in stock based compensation expense recognized during the six months ended June 30, 2025.
 *   *   *   *
 If you have any questions or comments with regard to this response or other matters, please call me at (213) 891-8185.
For any future written correspondence sent by email, please use the following address: brent.epstein@lw.com.

 Sincerely,

 /s/ Brent T. Epstein

 Brent T. Epstein
 of LATHAM & WATKINS LLP

 Cc:
 J. Michael McGillis, Claros Mortgage Trust, Inc.
 J.D. Siegel, Claros Mortgage Trust, Inc.
 Devon MacLaughlin, Latham & Watkins LLP
 3

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<TEXT>
 August 15, 2025

J. Michael McGillis
Chief Financial Officer
Claros Mortgage Trust, Inc.
60 Columbus Circle, 20th Floor
New York, NY 10023

 Re: Claros Mortgage Trust, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Form 10-Q for the quarterly period ended June 30, 2025
 File No. 001-40993
Dear J. Michael McGillis:

 We have reviewed your August 11, 2025 response to our comment letter 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.
Unless we note otherwise, any references to prior comments are to comments in
our August
4, 2025 letter.

Form 10-Q for the quarterly period ended June 30, 2025
Item 2. Management s Discussion and Analysis of Financial Condition and
Results of
Operations
Results of Operations , page 52

1. We note your response to comment 1 and that operating expenses for the
Company s
 real estate owned portfolio are regularly provided to the Chief
Operating Decision
 Maker and represent a significant segment expense determined in
accordance with
 ASC 280-10-50-26A. As such, please revise your disclosure in future
filings to
 include a detailed description of the components of operating expenses
within your
 consolidated results of operations for the periods presented.
 August 15, 2025
Page 2

 Please contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at
202-551-3856
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 CORRESP

 10250 Constellation Blvd., Suite 1100

 Los Angeles, California 90067

 Tel: +1.424.653.5500 Fax: +1.424.653.5501 www.lw.com

 FIRM / AFFILIATE OFFICES

 Austin

 Milan

 Beijing

 Munich

 Boston

 New York

 Brussels

 Orange County

 Chicago

 Paris

 Dubai

 Riyadh

 August 11, 2025

 Düsseldorf

 San Diego

 Frankfurt

 San Francisco

 Hamburg

 Seoul

 Hong Kong

 Silicon Valley

 Houston

 Singapore

 London

 Tel Aviv

 Los Angeles

 Tokyo

 Madrid

 Washington, D.C.
 Via EDGAR U.S.
Securities and Exchange Commission Division of Corporation Finance
 Office of Real Estate & Construction 100 F Street, N.E.
 Washington, DC 20549 Attention: Jeffrey Lewis and Shannon
Menjivar

 Re:
 Claros Mortgage Trust, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Form 10-Q for the quarterly period ended March 31, 2025
 File No. 001-40993
 Dear Mr. Lewis and Ms. Menjivar: On
behalf of our client, Claros Mortgage Trust, Inc., a Maryland corporation (the “ Company ”), set forth below is the Company’s response to the comment letter, dated August 4, 2025, from the staff of the Division of
Corporation Finance (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ SEC ”), relating to the Company’s Quarterly Report on Form 10-Q for the quarterly
period ended March 31, 2025 (the “ Form 10- Q ”). For convenience of reference, the text of the Staff’s
comment has been reproduced below in bold and italics, followed by the Company’s response thereto. All terms used but not defined
herein have the meanings assigned to such terms in the Form 10-Q. Form 10-Q for the quarterly period ended
March 31, 2025 Note 15. Segment Reporting, page 29

 1.
 We note your calculation of Distributable Loss for your loan and REO portfolios, as well as your
reconciliation to Net loss. Please tell us whether operating expenses represents a significant segment expense determined in accordance with ASC
 280-10-50-26A or if it represents “other segment items” in accordance with ASC 280-10-50- 26B. If the amount represents other segment items, please tell us how you complied with the guidance in ASC 280-10-50-26B, including disclosure of a qualitative description of the composition of other segment items.

 August 11, 2025
 Page 2

 Response :
 The Company acknowledges the Staff’s comment. The Company respectfully advises the Staff that operating expenses for the Company’s real estate owned
portfolio represent a significant segment expense determined in accordance with ASC 280-10-50-26A and are regularly provided to
the Chief Operating Decision Maker. *  *   *  *
 If you have any questions or comments with regard to this response or other matters, please call me at (213) 891-8185.
For any future written correspondence sent by email, please use the following address: brent.epstein@lw.com.

 Sincerely,

 /s/ Brent T. Epstein

 Brent T. Epstein of LATHAM & WATKINS
LLP

 Cc:
 J. Michael McGillis, Claros Mortgage Trust, Inc.
 J.D. Siegel, Claros Mortgage Trust, Inc.
 Devon MacLaughlin, Latham & Watkins LLP
 2

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<TEXT>
 August 4, 2025

J. Michael McGillis
Chief Financial Officer
Claros Mortgage Trust, Inc.
60 Columbus Circle, 20th Floor
New York, NY 10023

 Re: Claros Mortgage Trust, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 Form 10-Q for the quarterly period ended March 31, 2025
 File No. 001-40993
Dear J. Michael McGillis:

 We have limited our review of your filing to the financial statements
and related
disclosures 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-Q for the quarterly period ended March 31, 2025
Note 15. Segment Reporting, page 29

1. We note your calculation of Distributable Loss for your loan and REO
portfolios, as
 well as your reconciliation to Net loss. Please tell us whether
operating expenses
 represents a significant segment expense determined in accordance with
ASC 280-10-
 50-26A or if it represents "other segment items" in accordance with ASC
280-10-50-
 26B. If the amount represents other segment items, please tell us how
you complied
 with the guidance in ASC 280-10-50-26B, including disclosure of a
qualitative
 description of the composition of other segment items.
 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.
 August 4, 2025
Page 2

 Please contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at
202-551-3856
with any questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Real Estate &
Construction
</TEXT>
</DOCUMENT>

CORRESP
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 CORRESP

 Claros Mortgage Trust, Inc.
 c/o Mack Real Estate Credit Strategies, L.P.
 60 Columbus Circle, 20th Floor New
York, NY 10023 May 20, 2025 VIA EDGAR
 Securities and Exchange Commission Division of Corporation
Finance 100 F Street, N.E. Washington, D.C. 20549
 Attn: Stacie Gorman

 Re:
 Claros Mortgage Trust, Inc.
 Registration Statement on Form S-3
 Filed February 21, 2025
 File No. 333-285101
 Dear Ms. Gorman: In accordance with Rule
461 promulgated under the Securities Act of 1933, as amended, Claros Mortgage Trust, Inc. (the “ Company ”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Form S-3 (File No. 333-285101) (as amended, the “ Registration Statement ”). The Company respectfully requests that the Registration Statement become
effective as of 4:00 p.m., Eastern Time, on May 22, 2025 or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by
calling Brent T. Epstein of Latham & Watkins LLP at (213) 891-8185.

 Very truly yours,

 CLAROS MORTGAGE TRUST, INC.

 /s/ J.D. Siegel

 J.D. Siegel

 Executive Vice President, General Counsel and Secretary

 cc:
 Brent T. Epstein, Latham & Watkins LLP
 Devon L. MacLaughlin, Latham & Watkins LLP

February 26, 2025
J.D. Siegel
Executive Vice President, General Counsel & Secretary
Claros Mortgage Trust, Inc.
c/o Mack Real Estate Credit Strategies, L.P.
60 Columbus Circle
20th Floor
New York, NY 10023
Re:Claros Mortgage Trust, Inc.
Registration Statement on Form S-3
Filed February 21, 2025
File No. 333-285101
Dear J.D. Siegel:
            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 Stacie Gorman at 202-551-3585 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Brent T. Epstein, Esq.

CORRESP
1
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CORRESP

 CLAROS MORTGAGE TRUST, INC.

 60 Columbus Circle, 20th Floor

New York, NY 10023

 November 1, 2021

 VIA EDGAR AND EMAIL

 Mr. Ronald E. Alper

 Division of Corporation Finance – Office of Real Estate and Construction

U.S. Securities and Exchange Commission

 100 F Street, NE

Washington, DC 20549-3233

 Re: Registration Statement on Form S-11 (No. 333-260140) of Claros Mortgage Trust, Inc.

 Dear Mr. Alper:

On behalf of Claros Mortgage Trust, Inc. and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests
that the effective date of the above-referenced Registration Statement on Form S-11 be accelerated to November 2, 2021 at 4:00 pm Eastern Time, or as soon thereafter as practicable.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would inform William Cernius of Latham & Watkins LLP at
(949) 294-1699 or william.cernius@lw.com.

Very truly yours,

CLAROS MORTGAGE TRUST, INC.

By:

 /s/ Richard J. Mack

Name:

Richard J. Mack

Title:

Chief Executive Officer

 cc: William Cernius, Latham & Watkins LLP

CORRESP
1
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CORRESP

 November 1, 2021

VIA EDGAR

 United States Securities and Exchange
Commission

 Division of Corporate Finance

 100 F Street, N.E.

 Washington, D.C. 20549-6010

 Attention: Ron Alper

Re:    Claros Mortgage Trust, Inc.

Registration Statement on Form S-11 (File
No. 333-260140)

 Request for Acceleration of Effective Date

Dear Ladies and Gentlemen:

 In connection with the proposed
offering of the securities under the above-captioned Registration Statement on Form S-11 (the “Registration Statement”), we wish to advise you that we, as representatives of the underwriters, hereby
join with Claros Mortgage Trust, Inc.’s request that the effective date of the Registration Statement be accelerated so that the same will become effective on November 2, 2021 at 4:00 p.m. Eastern Time, or as soon as practicable
thereafter.

 Pursuant to Rule 460 under the Securities Act of 1933, please be advised that, as representatives of the underwriters, we have distributed
approximately 1,500 copies of the preliminary prospectus, dated October 26, 2021, through the date hereof.

 We, the undersigned, as representatives
of the several underwriters, will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Signature Page Follows]

Sincerely,

 MORGAN STANLEY & CO. LLC

J.P. MORGAN SECURITIES LLC

As representatives of the Underwriters

MORGAN STANLEY & CO. LLC

By:

 /s/ Michael Occi

Name:

Michael Occi

Title:

Managing Director

J.P. MORGAN SECURITIES LLC

By:

 /s/ Michael Rhodes

Name:

Michael Rhodes

Title:

Vice President

 [Signature Page to UW
Acceleration Request]

United States securities and exchange commission logo
July 23, 2021
Richard Mack
Chief Executive Officer
Claros Mortgage Trust, Inc.
c/o Mack Real Estate Credit Strategies, L.P.
60 Columbus Circle, 20th Floor
New York, NY 10023
Re:Claros Mortgage Trust, Inc.
Amendment No. 5 to
Draft Registration Statement on Form S-11
Submitted June 28, 2021
CIK No. 0001666291
Dear Mr. Mack:
            We have reviewed your amended draft registration statement and have the following
comment.  In our comment, 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 comment applies 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 this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.

 FirstName LastNameRichard Mack
 Comapany NameClaros Mortgage Trust, Inc.
 July 23, 2021 Page 2
 FirstName LastName
Richard Mack
Claros Mortgage Trust, Inc.
July 23, 2021
Page 2
Amendment No. 5 to Draft Registration Statement on S-11 submitted June 28, 2021
Financial Statements
Note 3. Loans Portfolio
Loan Modifications, page F-22
1.We note your disclosure regarding your loan modifications.  We further note that
approximately $1.25 billion, $1.36 billion and  $1.3 billion of unpaid principal balance
had a 4 risk rating as of June 30, 2020, December 31, 2020 and March 31, 2021
respectively.  Please tell us whether any of these loans were subject to modification, and if
so explain to us whether you concluded those modifications to be troubled debt
restructurings in accordance with ASC 310-40.  Your response should include a
discussion of how you determined the loan modification was or was not a troubled debt
restructuring.
            You may contact Babette Cooper at 202-551-3396 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

United States securities and exchange commission logo
October 8, 2020
Richard Mack
Chief Executive Office
Claros Mortgage Trust, Inc.
c/o Mack Real Estate Credit Strategies, L.P.
60 Columbus Circle, 20th Floor
New York, NY 10023
Re:Claros Mortgage Trust, Inc.
Amendment No. 4 to
Draft Registration Statement on Form S-11
Submitted September 18, 2020
CIK No. 0001666291
Dear Mr. Mack:
            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.
Amendment No. 4 to Draft Registration Statement on S-11 submitted September 18, 2020
Management's Discussion and Analysis
Introduction, page 116
1.We note your disclosure in footnote 6 that underwritten values and projected costs are
updated for certain loan modifications.  Please clarify for us, and consider disclosing,
whether the $1.7 billion in loan modifications entered into during the period ended July
31, 2020 resulted in an update to the related loan-to-value.

 FirstName LastNameRichard Mack
 Comapany NameClaros Mortgage Trust, Inc.
 October 8, 2020 Page 2
 FirstName LastName
Richard Mack
Claros Mortgage Trust, Inc.
October 8, 2020
Page 2
Asset Management, page 128
2.We note you have classified 12 loans as category "4" with a total unpaid principal balance
of $1.3 billion and entered into loan modifications representing $1.7 billion of unpaid
principal balance.  Please tell us what consideration you have given to providing further
disaggregated information for these loans including geographical location, industry,
property type, maturity, loan-to-value and class.
            You may contact Babette Cooper at 202-551-3396 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

January 15, 2020
Richard Mack
Chief Executive Office
Claros Mortgage Trust, Inc.
c/o Mack Real Estate Credit Strategies, L.P.
60 Columbus Circle, 20th Floor
New York, NY 10023
Re:Claros Mortgage Trust, Inc.
Draft Registration Statement on Form S-11
Submitted December 19, 2019
CIK No. 0001666291
Dear Mr. Mack:
            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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on S-11 submitted December 19, 2019
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.We note the discussion on page 30 regarding the applicability of the Investment Company
Act of 1940.  Note that we are considering this disclosure and may have additional
comments.

 FirstName LastNameRichard Mack
 Comapany NameClaros Mortgage Trust, Inc.
 January 15, 2020 Page 2
 FirstName LastNameRichard Mack
Claros Mortgage Trust, Inc.
January 15, 2020
Page 2
3.Please provide us with copies of all graphics, maps, photographs, and related captions or
other artwork including logos that you intend to use in the prospectus.
Summary, page 1
4.We note footnote 5 from the table on page 20.  If material please revise here or where
appropriate to clarify the factors you consider in determining whether LTV is calculated
using asset value or borrower's cost.
Management's Discussion and Analysis
Financial Highlights, page 107
5.Please tell us the additional compensation charge you expect to recognize as a result of the
vesting of your performance based RSUs.  In addition, please consider revising your
MD&A to include prominent disclosure of the charge you expect to recognize.
Key Financial Measures and Indicators, page 109
6.We note the discussion of Net Debt-to-Equity and Total Leverage Ratios and other key
measures.  Please revise the comparison discussion beginning on page 126 to address
material changes in the measures you use to evaluate your performance and financial
leverage.
Net Debt-to-Equity and Total Leverage Ratios, page 111
7.We note your disclosure on page 112 that you believe the inclusion of non-consolidated
senior interests sold and non-consolidated senior interests held by third parties provides a
meaningful measure of your financial leverage as in a liquidation of the collateral
underlying the subordinate loan, these senior interests would have priority in repayment.
As the non-consolidated senior interests represent loans receivable held by third parties,
and not liabilities of the company, or claims on the company's assets, we are unclear how
the inclusion of these amounts in your ratio provides a meaningful measure of the
company's leverage.  Please elaborate on your rationale for including these adjustments.
Portfolio Activity and Overview, page 112
8.Please explain the difference between the unfunded loan commitments as disclosed in
your table on page 113 and the amount reflected in your contractual obligations table on
page 128
Portfolio Financing, page 114
9.We note that you accounted for repurchase agreements as secured financing transactions.
Please consider expanding your disclosure to quantify the average quarterly balance of
your repurchase agreements for each period included in your financial statements.  In
addition, consider quantifying the period end balance for each of those quarters, the
maximum balance at any month-end and explaining the causes and business reasons for

 FirstName LastNameRichard Mack
 Comapany NameClaros Mortgage Trust, Inc.
 January 15, 2020 Page 3
 FirstName LastName
Richard Mack
Claros Mortgage Trust, Inc.
January 15, 2020
Page 3
any significant variances among these amounts.
Management Fees, Incentive Fees and Expense Reimbursements, page 176
10.Given the complexity of the base management fee calculation and the incentive fee
calculation, please provide a hypothetical example or other disclosure summarizing
the aggregate fees.
Certain Relationships and Related Transactions, page 190
11.Please revise Related Party Transaction Policies on page 192 or where appropriate to
address broader conflicts involving your manager, such as the conflicts identified in the
second and third summary risk factors on page 28.
12.We note the quantification of base management fees and incentive fees on page 190.
Please clarify whether you have paid expense reimbursements.
Exclusive Forum, page 205
13.We note the risk factor on page 86 states that the exclusive forum provision does not
apply to claims arising under the federal securities laws.  Please ensure that the provision
in your charter clearly indicates that the exclusive forum provision does not apply to
claims arising under the federal securities laws.
            You may contact Paul Cline at 202-551-3851 or Robert Telewicz at 202-551-3438 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction