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                          April 5, 2024

       Mark Fogel
       President & Chief Executive Officer
       ACRES Commercial Realty Corp.
       390 RXR Plaza
       Uniondale, NY 11556

                                                        Re: ACRES Commercial 
Realty Corp.
                                                            Registration 
Statement on Form S-3
                                                            Filed April 1, 2024
                                                            File No. 333-278433

       Dear Mark Fogel:

              This is to advise you that we have not reviewed and will not 
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for 
acceleration. 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 Pearlyne 
Paulemon at 202-551-8714 with any questions.



                                                                                
                          Sincerely,

                                                                                
                          Division of Corporation Finance
                                                                                
                          Office of Real Estate & Construction
       cc:                                              Mark Rosenstein