September 18, 2009

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Apollo Commercial Real Estate Finance, Inc.

Registration Statement on Form S-11 (File No. 333-160533)

Ladies and Gentlemen:

As representatives to the underwriters of the Company’s proposed public offering of up to 23,000,000 shares of common stock, we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness for 4:00 p.m. (NYT) on September 22, 2009, or as soon thereafter as is practicable.

Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated September 9, 2009, through the date hereof:

Preliminary Prospectus dated September 9, 2009:

13,519 copies to prospective Underwriters, institutional investors, dealers and others

The undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934.

Very truly yours,
J.P. MORGAN SECURITIES INC.
CITIGROUP GLOBAL MARKETS INC.
BARCLAYS CAPITAL INC.
As Representatives of the several Underwriters
By:	BARCLAYS CAPITAL INC.
By:	/s/ Victoria Hale
	Victoria Hale
	Vice President