October 24, 2019

Jilliene Helman
Chief Executive Officer
MogulREIT II, Inc.
10780 Santa Monica Blvd., Suite 140
Los Angeles, CA 90025

       Re: MogulREIT II, Inc.
           Post Qualification Amendment on Form 1-A
           Filed October 17, 2019
           File No. 024-10713

Dear Ms. Helman:

       We have reviewed your amendment and do not have any comments.

        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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.

       You may contact Ruairi Regan at 202-551-3269 or Brigitte Lippmann at
202-551-3713
with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Real
Estate & Construction
cc:    Lauren B. Prevost, Esq.