October 3, 2024

Avraham Dreyfuss
Chief Financial Officer
Fortress Credit Realty Income Trust
1345 Avenue of the Americas
New York, NY 10105

       Re: Fortress Credit Realty Income Trust
           Registration Statement on Form 10-12G
           Filed September 6, 2024
           File No. 000-56685
Dear Avraham Dreyfuss:

       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.

Registration Statement on Form 10-12G filed September 6, 2024
Item 1. Business
Leverage, page 11

1.     Please disclose your target leverage ratio, as this term is used on page
13 and in several
       risk factors. We note that you have disclosed Fortress's historical
average leverage of 50-
       65% for commercial and residential real estate debt investments. Please
also revise to
       disclose whether there is an upper limit to the amount of leverage you
may utilize, and if
       so, please specify such limit. In this regard, we note your statement
that you could add
       more leverage in certain instances where a transaction can support it.
Also revise to
       briefly discuss how you would determine a transaction can support
additional
       leverage and strategies you may use to manage the risks of using
leverage, such as
       "match-funded" structures and/or hedging, as you explain on pages 84 and
87,
       respectively.
 October 3, 2024
Page 2
Fortress Credit Realty Income Trust Structure, page 15

2.     Please revise the ownership structure chart on page 16 to reflect the
following, as
       applicable:
           The ownership of FIG LLC by Fortress;
           The ownership of the company by each of FIG LLC and BTG, as of the
most recent
           practicable date, as a result of their purchases of shares pursuant
to the FIG
           Subscription Agreement and the BTG Subscription Agreement,
respectively;
           The Administration Agreement between the company and FCR Advisors
LLC; and
           The ownership by the company of various subsidiaries/investments.
Management Fee, page 18

3.     Please revise here and under the heading "Our Independent Valuation
Advisor" on page
       131 to identify your independent valuation advisor.
Term and Termination Rights, page 18

4.     Please revise here and your associated risk factor on page 75 to clarify
whether there
       would be a penalty if the company were to terminate the Management
Agreement (i)
       without cause or (ii) upon less than 60 days' written notice. Also
revise to clarify what
       constitutes "cause" under the Management Agreement, as it does not
appear to be defined
       in Exhibit 10.1
Organization and Offering Expense Reimbursement, page 19

5.     Please revise to disclose, as of the most recent practicable date, all
organization
       and offering expenses advanced by the Adviser on behalf of the company.
In this regard,
       we note your financial statement disclosure that as of July 16, 2024,
the Adviser has
       incurred $2.9 million of organization and offering expenses on behalf of
the company.
Performance Fee, page 19

6.     Please revise to further explain how Core Earnings is calculated. More
specifically, define
       "certain non-cash adjustments" and "certain material non-cash income or
expense items."
       Also clarify or explain your statement, "in each case after discussions
between the
       Adviser and our independent trustees and approved by a majority of our
independent
       trustees," which suggests that despite Core Earnings for a given quarter
being the result of
       a defined calculation or formula, the Adviser and your independent
trustees nevertheless
       retain the discretion to modify Core Earnings. Also revise to disclose
who calculates Core
       Earnings and who is ultimately and solely responsible for determining
Core Earnings.
7.     Please revise to disclose, if true, that the Adviser is entitled to
receive compensation under
       the performance fee for a given year even if shareholders experienced a
decline in NAV
       per share. In this regard, we note your disclosure on page 124 that it
is possible that
       certain service providers or Sourcing Partners may receive incentive
compensation from
       the company, even though the company, as a whole, does not have net
capital
       appreciation.
 October 3, 2024
Page 3
Share Repurchase Plan, page 23

8.     Please be advised that you are responsible for analyzing the
applicability of the tender
       offer rules, including Rule 13e-4 and Regulation 14E, to your share
repurchase plan.
       We urge you to consider all the elements of your share repurchase plan
in determining
       whether the plan is consistent with relief granted by the Division of
Corporation Finance
       in prior no action letters. To the extent you are relying on Blackstone
Real Estate Income
       Trust, Inc. (Letter dated September 12, 2016), Rich Uncles NNN REIT,
Inc. (Letter dated
       December 21, 2016), Hines Global REIT II, Inc. (Letter dated April 26,
2017), or Black
       Creek Diversified Property Fund Inc. (Letter dated September 1, 2017),
please provide us
       with an analysis as to how your program is consistent with such relief.
To the extent you
       have questions as to whether the plan is entirely consistent with the
relief previously
       granted by the Division of Corporation Finance, you may contact the
Division   s Office of
       Mergers and Acquisitions at 202-551-3440.
9.     We note that you may conduct the share repurchase program during the
offering period of
       your continuing private placement offering. Please be advised that you
are responsible for
       analyzing the applicability of Regulation M to your share repurchase
plan. We urge you to
       consider all the elements of your share repurchase plan in determining
whether the plan is
       consistent with the class relief granted by the Division of Market
Regulation in the class
       exemptive letter granted Alston & Bird LLP dated October 22, 2007. To
the extent you
       have questions as to whether the plan is entirely consistent with that
class exemption, you
       may contact the Division of Trading and Markets at 202-551-5777.
Our Declaration of Trust does not provide for the annual election of trustees
by our shareholders .
. ., page 79

10.    Please expand this risk factor, as applicable, to discuss the potential
consequences to you,
       your business, and/or your shareholders if a trustee may be removed for
"cause" but
       sufficient votes to remove the trustee are not obtained.
Item 6. Executive Compensation, page 112

11.    We note that you reimburse the Adviser or its affiliates for an
allocable portion of the
       compensation paid by the Adviser or its affiliates to your executive
officers. In future
       filings that require Item 404 of Regulation S-K disclosure, please break
out the amounts
       paid pursuant to the reimbursement of expenses to your Adviser and
specify any amounts
       reimbursed for salaries or benefits of each of your named executive
officers. Refer to Item
       402(a)(2) of Regulation S-K.
Item 7. Certain Relationships and Related Transactions, and Trustee
Independence
Dealing with Potential Conflicts of Interest, page 116

12.    Please revise to further explain how conflicts will be resolved between
you, Fortress
       Affiliates, and Fortress Managed Accounts. More specifically, discuss
when, under your
       Declaration of Trust or investment guidelines, transactions would be
required to be
       presented to your board of trustees for approval. We note your risk
factor on page 81
       regarding your conflict of interest policy. However, it is unclear
whether your Declaration
       of Trust and/or investment guidelines impose any similar or different
requirements.
 October 3, 2024
Page 4

       Additionally, please revise here to disclose that you waive the
corporate opportunity
       doctrine, as you discuss on page 144.
Allocation of Investment Opportunities, page 118

13.    Please revise to quantify the size of the funds that may compete with
you for investment
       opportunities.
Certain Business Relationships, page 128

14.    Please revise to identify which of your current trustees and officers
are directors, officers,
       or employees of the Adviser, Fortress, other Fortress-affiliated
investment advisers,
       and/or other Fortress-sponsored programs. Disclose, if true, (i) that as
a result they owe
       fiduciary duties to each of these entities, their stockholders,
partners, members, and/or
       Fortress-advised investors, as the case may be, and (ii) that these
fiduciary duties may
       from time-to-time conflict with the fiduciary duties that they owe to
you.
Note 3. Related Party Transactions
Due to Affiliate, page F-5

15.    We note that the Company will reimburse the Adviser for the use of
accounting,
       information technology and operational services, software or other
assets utilized to
       provide such services to the Company based on an allocation by the
Adviser, but that
       through July 16, 2024, the Company has not reimbursed the Adviser for
such
       expenses. Please disclose the amount of expense incurred by the Advisor
to date that will
       be allocated to the Company and the terms of repayment.
Subsequent Events, page F-6

16.    We note that you have entered into a subscription agreement for an
investment in a
       conventional mortgage servicing rights portfolio and that you have
agreed to an aggregate
       capital commitment of $150 million. Please clarify who controls the
portfolio and if the
       subscription agreement is with an affiliate or a third party.
Additionally, tell us how you
       will record your interest in the portfolio within your financial
statements.
General

17.    Please revise to define abbreviations and acronyms at first use. For
example, on page 22
       define DBSO Funds, FCO Funds, FROF Funds, and FLF Funds. Also revise,
where
       appropriate, to identify the legal entities comprising the Fortress
Managed Accounts or
       otherwise explain the term.
18.    We note your use of periodic NAV pricing for both your offerings and
share repurchase
       plan. Please clarify how you will communicate your NAV price changes.
19.    Please provide a good faith calculation of the Company   s investment
securities as a
       percentage of total assets in accordance with Section 3(a)(1)(C) of the
Investment
       Company Act. Please explain any assumptions relevant to the
calculations. This
       discussion should include how the Company intends to classify various
applicable
       holdings in view of Section 3(c)(5)(C) and relevant Commission and staff
guidance.
20.    We note the Company states that it may make investments through joint
ventures.
       Specifically, on page 12, the Company states:    In certain cases, we
may not control the
 October 3, 2024
Page 5

       management of joint ventures in which we invest, but we may have the
right to approve
       major decisions of the joint ventures. We will not participate in joint
ventures in which we
       do not have or share control to the extent that we believe such
participation would
       potentially threaten our status as a non-investment company exempt from
the Investment
       Company Act.

       Please discuss supplementally the structure of any such joint venture
investments, the
       nature of the co-participants in any such joint ventures, and the manner
of the
       Company's participation in any such joint ventures. Please also discuss
whether the
       Company   s interests in such joint ventures are (or will be) investment
securities for
       purposes of Section 3(a)(2) of the Investment Company Act. This
discussion should apply
       any Commission or staff guidance relevant to the analysis of whether a
security is an
       investment security.
21.    Please provide supplementally an organization chart showing the
relationships among
       relevant entities, including any existing and anticipated subsidiaries
of the Company.
22.    Please discuss supplementally the nature of the anticipated Company
subsidiaries
       intending to rely on Rule 3a-7, including the anticipated relative
percentage of Company
       holdings in such subsidiaries. This discussion should address how such
subsidiaries
       implicate the definition of investment company in Section 3(a)(1)(A) of
the Investment
       Company Act.
23.    Please note that your registration statement becomes effective
automatically 60 days after
       its initial filing. You will then be subject to the reporting
requirements of the Exchange
       Act of 1934 even if comments remain outstanding. In that case, please
consider
       withdrawing the Form 10 before it becomes effective automatically and
submitting a new
       registration statement when you respond to our comments.
        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 Howard Efron at 202-551-3439 or Kristina Marrone at
202-551-3429 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Benjamin Holt at 202-551-6614 or Pam Long at 202-551-3765 with any
other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:   Ross M. Leff, P.C.