February 7, 2019

Frederick Herbst
Chief Financial Officer
Ready Capital Corporation
1140 Avenue of the Americas, 7th Floor
New York, NY 10036

       Re: Sutherland Asset Management Corporation
           Form 10-K for the year ended December 31, 2017
           Filed March 16, 2018
           File No. 001-35808

Dear Mr. Herbst:

        We have reviewed your February 1, 2019 response to our comment letter
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. Unless we note otherwise, our references to prior comments are to
comments in our
January 31, 2019 letter.

Form 10-K for the year ended December 31, 2017

Consolidated Statements of Income, page 115

1.    We note your response to comment 3. We continue to be unclear how you
determined
      that the current presentation of "gains on residential mortgage banking
activities, net of
      variable loan expenses" is compliant with Rule 9-04 of Regulation S-X.
Please
      specifically address the following:
        Explain to us why realized and unrealized gains and losses on
residential mortgage
          loans and unrealized gains (loss) on IRLCs and other derivatives are
characterized as
          non-interest income while realized and unrealized gains on other
financial instruments
          are presented below total non-interest expense. Additionally, tell us
why a $4 million
          unrealized loss and a $6.9 million unrealized gain on residential
mortgage banking
          financial instruments were recorded in 2017 and 2016, respectively,
in "Net unrealized
 Frederick Herbst
Ready Capital Corporation
February 7, 2019
Page 2
             gain on financial instruments" rather than with the other
residential mortgage banking
             gains and losses recorded within non-interest income. Within your
response, please
             reference the authoritative literature management relied upon.
             Cite specific authoritative literature to support your position
that loan origination fee
             income on loans carried at fair value should not be classified as
interest income in
             accordance with Rule 9-04.1 of Regulation S-X. We note that
origination fees on
             loans carried at fair value are not deferred and amortized like
the origination fees on
             loans held for investment. However, please clarify for us how you
determined that the
             timing of revenue recognition would impact the characterization of
recognized fees on
             the statements of income.
             Cite specific authoritative literature to support your policy of
presenting
             "correspondent fees and other direct loan expenses, including the
provision for loan
             indemnification" as a reduction of the related income rather than
as an expense.
        You may contact Kristi Marrone at (202) 551-3429 or Jennifer Monick at
(202) 551-3295
if you have questions regarding comments on the financial statements and
related matters.



                                                               Sincerely,
FirstName LastNameFrederick Herbst
                                                               Division of
Corporation Finance
Comapany NameReady Capital Corporation
                                                               Office of Real
Estate and
February 7, 2019 Page 2                                        Commodities
FirstName LastName