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                               March 4, 2024

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

                                                        Re: Invesco Commercial
Real Estate Finance Trust, Inc.
                                                            Amendment No. 3 to
Form 10-12G
                                                            Filed December 15,
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 and any amendment you may file in
response to this letter,
       we may have additional comments.

       Amendment No. 3 to Registration Statement on Form 10-12G filed December
15, 2023

       Item 1. Business
       Investment Objectives, page 10

   1.                                                   We note your response
to comment 2. Please address the following with respect to the
                                                        three related loans
that are cross collateralized and cross defaulted under a Master Credit
                                                        Agreement with a single
borrower.
                                                            Please clarify for
us the legal structure of the entities involved with these three related
                                                            loans. Your
response should address, but not be limited to, clarifying ownership
                                                            and/or
relationships between the borrower, the subsidiary guarantor entity, the
                                                            guarantor entity,
and the property.
                                                            Within your
response, you state    [t]he sole business activity of each subsidiary
                                                            guarantor entity is
ownership of a single real estate property.    Please clarify for us the
                                                            activity of any
other entities involved in the Master Credit Agreement. Your response
                                                            should address, but
not be limited to, if the guarantor entity or the borrower engage in
                                                            activity unrelated
to the properties underlying the related loans.
 Hubert J. Crouch
Invesco Commercial Real Estate Finance Trust, Inc.
March 4, 2024
Page 2
2.    We note your response to comment 2. Please address the following with
respect to each of
      the properties underlying the three related loans that are cross
collateralized and cross
      defaulted under a Master Credit Agreement with a single borrower.
          Please explain the property status at the in-service date (e.g.,
fully leased and
           occupied, vacant, percentage leased, percentage occupied).
          Please clarify the nature of the property (e.g., industrial).
3.    We note your response to comment 2. Please provide an updated analysis of
any
      significant loans as of December 31, 2023. Please also tell us if you
intend to provide any
      audited financial statements related to these loans within your Form 10-K
for the fiscal
      year ended December 31, 2023.
General

4.    We note your response to comment 1 in your letter dated December 15, 2023
and
      comment 3 in your letter dated October 31, 2023. Please note that SEC
staff has not taken
      the position that preferred equity interests, including debt-like
preferred equity interests,
      can be qualifying assets. Accordingly, please replace the current
disclosure regarding
      debt-like preferred equity interests with disclosure stating that
preferred equity interests,
      including debt-like preferred equity interests, will not be considered
qualifying assets.
5.    We note that you added Class F shares under Item 11. Description of
Registrant's
      Securities to Be Registered. Please add Class F shares on the cover page
of the Form 10 or
      advise.
        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
March 4, 2024 Page 2
cc:       Brian Hirshberg, Esq.
FirstName LastName