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                              November 15, 2023

       Hubert J. Crouch
       Chief Executive Officer
       Invesco Commercial Real Estate Finance Trust, Inc.
       2001 Ross Avenue, Suite 3400
       Dallas, Texas 75201

                                                        Re: Invesco Commercial
Real Estate Finance Trust, Inc.
                                                            Amendment No. 2 to
Form 10-12G
                                                            Filed October 31,
2023
                                                            File No. 000-56564

       Dear Hubert J. Crouch:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Amendment No. 2 to Registration Statement on Form 10-12G filed October
31, 2023

       General

   1.                                                   We note your response
to prior comment 3 in your letter dated October 31, 2023 that
                                                        states all or a portion
of each debt-like preferred equity interest could be treated as a
                                                        qualifying asset, real
estate related asset or miscellaneous asset for purposes of Section
                                                        3(c)(5)(C) of the 1940
Act. Please include a sentence in your registration statement
                                                        disclosure stating how
the registrant intends to treat debt-like preferred equity interests,
                                                        making clear, however,
that preferred equity interest, including debt-like preferred equity
                                                        interest, would not be
considered a qualifying asset.
       Item 1. Business
       Investment Objectives, page 10

   2.                                                   We note your response
to prior comment 7, which included a detailed discussion of your
                                                        basis for not including
separate audited financial statements of the underlying property for
                                                        the $115.7 million
loan. In addition, we note your revision to your filing that you have
 Hubert J. Crouch
Invesco Commercial Real Estate Finance Trust, Inc.
November 15, 2023
Page 2
      now invested $378,970,000 in six commercial real estate loans. Please
address the
      following:
          Please provide us with a detail, by loan, that includes the committed
loan amount,
           principal balance, date upon which the company determined the
investment in the
           loan to be probable, and origination/acquisition date. This
information should be
           provided for every originated, acquired and probable loan.
          For any such loans that exceed 20% of total assets as of the latest
audited year-end
           balance sheet, please provide us with a detailed analysis of how you
determined that
           there is undue hardship and impracticality with respect to obtaining
financial
           statements of the properties securing these loans. Within your
response, please tell us
           the placed in service date of the property underlying the loan. Your
response should
           address each loan on an individual basis. Reference is made to SAB
Topic 1I.
Item 9. Market Price of and Dividends on The Registrant's Common Equity and
Related
Stockholder Matters
Distributions, page 101

3.    We note your revision to your filing that you intend to pay distributions
that would
      represent a stable return of 7.5% per annum. Please tell us how you
determined you have
      a reasonable basis to project a distribution rate. Within your response,
please address your
      limited operating history, the relatively limited number of loans owned,
the variable
      nature of the interest rates, the credit quality of the borrowers,
limited borrower repayment
      history, and any prepayment terms on the loans.
        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.

       Please contact Jeffrey Lewis at 202-551-6216 or Jennifer Monick at
202-551-3295 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Kibum Park at 202-551-6836 or Brigitte Lippmann at 202-551-3713 with
any other
questions.



                                                            Sincerely,
FirstName LastNameHubert J. Crouch
                                                     Division of Corporation
Finance
Comapany NameInvesco Commercial Real Estate Finance Trust, Inc.
                                                     Office of Real Estate &
Construction
November 15, 2023 Page 2
cc:       Brian Hirshberg, Esq.
FirstName LastName