August 8, 2024

Anthony Marone Jr.
Chief Financial Officer
BLACKSTONE MORTGAGE TRUST, INC.
345 Park Avenue, 24th Floor
New York, New York 10154

       Re: BLACKSTONE MORTGAGE TRUST, INC.
           Form 10-K for the year ended December 31, 2023
           Filed on February 14, 2024
           File No. 001-14788
Dear Anthony Marone Jr.:

       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 year ended December 31, 2023
3. Loans Receivable, Net, page F-20

1.     We note that the provisions for your CECL reserve was approximately
$124.7
       million, $326.1 million and $576.9 million for the fiscal years 2021,
2022 and 2023,
       respectively. We further note that as of December 31, 2023 it appears
that you had an
       aggregate $417.7 million asset-specific CECL reserve related to 13 of
your loans
       receivable which have a risk rating of a "5" and for which you have
identified such loans
       as being impaired. This represents a significant increase from the 5 and
1 loan(s) with
       such classification as of December 31, 2022 and December 31, 2021
respectively. Please
       further expand your disclosures to discuss the factors that led to the
significant increase in
       the provision which appears to be driven by an increase in the number of
impaired loans.
        In that regard, please ensure that your disclosures highlight whether
such an increase in
       impaired loans is driven by the general macroeconomic conditions or
whether there were
       other specific circumstances contributing to the increase in the number
of impaired
       loans. Finally, please ensure your disclosures address whether you
expect the
       disproportionate fluctuations and increase in trends to recur. See Item
303(b)(2)(i) and (ii)
       of Regulation S-K.
 August 8, 2024
Page 2

        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 Ameen Hamady at 202-551-3891 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