CIM Real Estate Finance Trust, Inc.
2398 East Camelback Road, 4th Floor
Phoenix, Arizona 85016
November 9, 2020
VIA EDGAR
Division of Corporation Finance
Office of Real Estate and Construction
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ronald (Ron) Alper
| Re: | CIM Real Estate Finance Trust, Inc. |
Registration Statement on Form S-4
File No. 333-249294
Pursuant to Rule 461 of the General Rules and Regulations of the Securities and Exchange Commission promulgated under the Securities Act of 1933, as amended, CIM Real Estate Finance Trust, Inc. hereby requests that the effective date of the above-captioned Registration Statement on Form S-4, as amended, be accelerated to 4:00 p.m., Eastern Time, on November 10, 2020, or as soon as practicable thereafter.
Please contact Patrick S. Brown of Sullivan & Cromwell LLP via telephone at (310) 712-6603 or via e-mail at brownp@sullcrom.com with any questions you may have. In addition, please notify Mr. Brown when this request for acceleration has been granted.
| Sincerely, | ||
/s/ Nathan D. DeBacker | ||
| Name: | Nathan D. DeBacker | |
| Title: | Chief Financial Officer and Treasurer | |
| cc: | Patrick S. Brown |
A. Taylor Lackey
(Sullivan & Cromwell LLP)
