October 2, 2018


Ziv Sapir
Comrit Investments 1, LP
9 Ahad Ha'am Street
Tel Aviv, Israel 6129101

       Re:    Benefit Street Partners Realty Trust, Inc.
              Schedule TO-T filed on September 25, 2018
              Filed by Comrit Investments 1, LP
              File No. 5-89905

Dear Mr. Sapir:

       The Office of Mergers and Acquisitions has reviewed the filing listed
above. Our
comments follow. All defined terms have the same meaning as in the Offer to
Purchase included
as Exhibit 99(A)(1) to the Schedule TO-T.

       Please respond to this letter by revising your filing, by providing the
requested
information, or by advising us when you will provide the requested response. If
you do not
believe our comments apply to your facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

       After reviewing any amendment to your filing and the information you
provide in
response to these comments, we may have additional comments.

Offer to Purchase

Section 2. Acceptance for Payment and Payment for Shares; Proration, page 8

   1. You state that you will pay for shares tendered "upon confirmation from
the Corporation
      or its transfer agent that the Shares have been transferred to the
Purchaser." Disclose
      how long you expect this to take, and how you will comply with your
obligation under
      Rule 14e-1(c) to promptly pay for tendered Shares.

Section 4. Withdrawal Rights, page 10

   2. Given the language quoted in our first comment above, revise to disclose
that tendering
      shareholders also have the right to withdraw tendered Shares not accepted
for payment by
 Amos W. Barclay , Esq.
Holland & Hart LLP
October 2, 2018
Page 2


       the 60th day after commencement of this Offer (provide a date). See
Exchange Act
       Section 14(d)(5).
Section 10. Certain Information Concerning the Purchaser, page 12

      3. Provide the disclosure required by Item 1009(a) of Regulation M-A for
Plotkin Financial
         Advisors, LLC.

Section 12. Conditions of the Offer, page 13

      4. Revise the disclosure in the first paragraph on page 14 ("may be
asserted by the
         Purchaser or may be waived by the Purchaser at any time and from time
to time ...") to
         avoid the implication that Purchasers can avoid taking action on any
Offer condition
         when "triggered" by failing to assert it.

        We remind you that the filing person is responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Please contact me at (202) 551- 3263 with any questions about these comments.


                                                     Sincerely,

                                                     /s/ Christina Chalk

                                                     Christina Chalk
                                                     Senior Special Counsel
                                                     Office of Mergers and
Acquisitions



cc:      Amos W. Barclay, Esq. (via email)