Secured Real Estate Income Strategies CORRESP Correspondence with SEC

299 S. Main Street, Suite 1300 | Salt Lake City, Utah 84111 | 801-534-4435

August 4, 2017

Tom Kluck

United States Securities and Exchange Commission

Office of Real Estate and Commodities

Mail Stop 3233

Washington, D.C. 20549

Re:Secured Real Estate Income Strategies, LLC

Amendment No. 8 to Offering Statement on Form 1-A

Filed July 28, 2017

File No. 024-10623

Dear Mr. Kluck:

We are in receipt of your comment letter dated July 21, 2017, regarding Amendment No. 7 to the Offering Statement on Form 1-A filed by Secured Real Estate Income Strategies, LLC (formerly Secured Real Estate Income Fund II, LLC)(the “Company”). This letter sets forth the Company’s responses to your comments. In order to assist you in your review of the amendment, we will respond to each of the comments contained in your letter in the order presented. All initially capitalized terms in this letter have the same meanings given them in the eighth amendment to the Offering Statement (“Offering Statement”), unless the context otherwise requires.

Your comments and the Company’s responses to them are as follows:

Description of Our Class A Units

Redemptions, page 130

1. We note your response to comment 7. Please add disclosure defining the term “redemption request date.” Also, we note from the hypothetical you provided in your response that it seems as though redeeming investors will forfeit the value of the distributions declared on the Class A Units subject to the redemption request with record dates between the redemption request date and the Redemption Date. If true, please add appropriate disclosure, including disclosure in your Risk Factors section, describing this.

We have revised the Offering Statement to remove “redemption request date” as a defined term, and have added the terms “Redemption Effective Date,” which is the first day of the quarter in which the redemption is to be made and “Redemption Payment Date,” which is the date on which the redemption payment is made and is approximately fifteen (15) (but no more than thirty (30)) days after the Redemption Effective Date. We believe the 15 day (but no more than thirty

day) period will enable the Issuer to manage its capital liquidity needs and be in line with the guidance in the various no-action letters.

The redemption request date would be the actual day on which a member makes a redemption request, which can be any time up to 3 days prior to the end of the quarter. The offering circular has been revised accordingly and contains the following example:

For example, if a request is on May 25th, the Redemption Effective Date would be July 1st and the Redemption Payment Date would be July 15^th (but no later than July 30^th). A member making a redemption request would be entitled to receive any distributions made between May 25th and June 30th and such distributions would not affect the redemption price. If such member receives a quarterly distribution on or after July 1st Redemption Effective Date, the redemption price paid on the Redemption Payment Date would be reduced to reflect such distribution.

2. We note your response to comment 8. With a view toward revised and expanded disclosure, please provide support for the following features of your share repurchase program:

the requirement to provide 90 days’ notice to redeem;

subtracting from the redemption price any distributions declared with record dates during such 90 day period without a minimum time period after such a reduction in the offer price occurs to allow security holders to take action in response to the change in price;

the fact that at the time the right to withdraw a redemption request expires, redeeming investors may not know the redemption price;

your Managing Member’s ability, in its sole discretion, to amend, suspend or terminate the redemption plan at any time without notice; and

your Managing Member’s discretion to decline any particular redemption request if it believes such action is necessary to preserve or facilitate your tax status.

Please also disclose in more detail under what circumstances the Managing Member may, on your behalf, require a member requesting redemption prior to twelve months following the purchase of its Class A Units to pay a redemption fee of 10% of the amount of the redemption request. Finally, please tell us where redeeming investors will be able to access the redemption price. We may have further comments.

We have revised our disclosure in the Offering Circular to address the issues as follows:

We have removed the requirement of a 90 day notice. Redemption requests can be made at any time during the preceding quarter up to three (3) days prior to the end of the quarter.

The redemption price will be adjusted only for distributions after the end of the quarter, but prior to the payment date.

Redeeming investors will receive notice of a change to the NAV or redemption price via email, posting on the website and the filing of a supplement to the Offering Circular.

The Managing Member must provide notice to any amendment, suspension or termination of the plan by filing an amendment to the Offering Circular at least thirty (30) days prior to such amendment, termination or suspension.

The Managing Member may decline a redemption request as set forth in the disclosure.

Redeeming Members may withdraw their redemption request at any time prior to the payment date.

We have also removed the 10% redemption fee for redemptions made prior to 12 months.

We are providing in connection herewith, a copy of the changed pages, marked to show the proposed revisions. We respectfully request that you provide your input on the acceptability of such changes as soon as possible as the Company would like to file an amendment incorporating these revisions shortly.

We hope that this will resolve all of the remaining issues and that the offering can be qualified as soon as possible.