March 12, 2019

Jai Agarwal
Chief Financial Officer, Treasurer, Secretary
Apollo Commercial Real Estate Finance, Inc.
c/o Apollo Global Management, LLC
9 West 57th Street, 43rd Floor
New York, NY 10019

       Re: Apollo Commercial Real Estate Finance, Inc.
           Form 10-K for the Year Ended December 31, 2018
           Filed February 13, 2019
           File No. 001-34452

Dear Mr. Agarwal:

        We have limited our review of your filing to the financial statements
and related
disclosures 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 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 this comment, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2018

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Financial Measures, page 43

1.    We note your disclosure that your weighted-average diluted shares
outstanding used for
      Operating Earnings excludes shares issued from a potential conversion of
the Notes and
      that you believe this is a useful presentation for investors. Please tell
us and revise future
      filings to disclose why you believe this presentation is useful for
investors. In addition,
      please revise to disclose the amount of related interest expense on the
Notes that is not
      being adjusted from the numerator. Reference is made to Item 10(e) of
Regulation S-K.
       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.
 Jai Agarwal
Apollo Commercial Real Estate Finance, Inc.
March 12, 2019
Page 2

      You may contact William Demarest, Staff Accountant at 202-551-3432 or
Jennifer
Monick, Assistant Chief Accountant at 202-551-3295 with any questions.



                                                       Sincerely,
FirstName LastNameJai Agarwal
                                                     Division of Corporation
Finance
Comapany NameApollo Commercial Real Estate Finance, Inc.
                                                     Office of Real Estate and
March 12, 2019 Page 2                                Commodities
FirstName LastName