TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo June 28, 2021 Paul Elenio Chief Financial Officer Arbor Realty Trust, Inc. 333 Earle Ovington Boulevard Suite 900 Uniondale, NY 11553 Re: Arbor Realty Trust, Inc. Form 10-K for the Fiscal Year Ended December 31, 2020 File No. 001-32136 Filed February 19, 2021 Dear Mr. Elenio: We have reviewed your filing 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 the comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2020 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 46 1. We note your disclosure of the cause of the increase in credit facilities and repurchase agreements on page 41. Please tell us what consideration you gave to also disclosing the average quarterly balance of your repurchase agreements for each of the past three years, the period end balance for each of those quarters, and the maximum balance at any month end. Paul Elenio Arbor Realty Trust, Inc. June 28, 2021 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. You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 if you have questions. FirstName LastNamePaul Elenio Sincerely, Comapany NameArbor Realty Trust, Inc. Division of Corporation Finance June 28, 2021 Page 2 Office of Real Estate & Construction FirstName LastName