October 25, 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/A filed on October 25, 2018
              Filed by Comrit Investments 1, LP
              File No. 5-89905

Dear Mr. Sapir:

       The Office of Mergers and Acquisitions has reviewed the amended 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/A.

       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.

General

   1. We note that you have increased the offer price and extended the length
of the tender
      offer until November 30, 2018. Rule 14e-1(d) mandates that when you
extend a tender
      offer, you must announce such extension by press release or other public
announcement,
      which must include the number of securities deposited to date. Please
advise how you
      have complied with the requirements of Rule 14e-1(d), or take immediate
steps to comply
      with the requirements of that Rule.

   2. In numerous places in the revised Offer to Purchase, you state that by
tendering, security
      holders are agreeing to arbitrate any disputes that may arise between
them and any other
      party related to the Offer, to subject themselves to personal
jurisdiction in Maryland and
      are agreeing that the prevailing party will be entitled to recover
attorney's fees and costs.
 Amos W. Barclay , Esq.
Holland & Hart LLP
October 25, 2018
Page 2




       In your revised disclosure document, please address the following:

               Affirmatively state that by agreeing to the provision, tendering
holders will not be
               deemed to have waived compliance with the federal securities
laws and the rules
               and regulations promulgated thereunder;

               Identify the relevant forum for arbitration;

               Describe the risks to tendering holders associated with the
requirement to
               arbitrate, including but not limited to, increased costs to
bring a claim, limited
               access to information and other imbalances of resources between
the tendering
               holder and other entities such as the bidder, and that this
provision may
               discourage claims or limit or preclude security holders' ability
to bring a claim in
               a judicial forum they find favorable;

               Describe any uncertainty about whether or not a court would
enforce the
               arbitration provision; and

               Describe the impacts of limitations on claims arising under
other applicable state
               or federal laws.

        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)