February 3, 2020

Brian Mitts
President
NexPoint Real Estate Finance, Inc.
300 Crescent Court
Suite 700
Dallas, Texas 75201

       Re: NexPoint Real Estate Finance, Inc.
           Amendment No. 2 to Registration Statement on Form S-11
           Filed January 27, 2020
           File No. 333-235698

Dear Mr. Mitts:

      We have reviewed your amended registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our January 14,
2020 letter.

Amendment No. 2 to Form S-11 filed January 27, 2020

Unaudited Pro Forma Consolidated Financial Statement Information, page F-6

1.     We note your disclosure on page 82 that your operating partnership will
own an
       approximate 26.4% interest in the subsidiary partnerships after your
offering. Please tell
       us what consideration you have giving to adjusting your pro forma income
statement to
       reflect the allocation of net earnings between controlling and
non-controlling interest.
       Additionally, tell us what consideration you have given to adding
footnote disclosure to
       your pro forma financial statement information to more fully describe
the operating
       partnership's ownership interest in the subsidiary partnerships.
 Brian Mitts
NexPoint Real Estate Finance, Inc.
February 3, 2020
Page 2
General

2.    We note your revised disclosure on page 82 that the OP will contribute
the net proceeds in
      an amount equal to 28.0% to its first subsidiary partnership, 39.3% to
its second
      subsidiary partnership and 32.7% to its third subsidiary partnership and
will own
      approximately 26.4% of each of the subsidiary partnerships (assuming the
underwriters do
      not exercise their option to purchase additional shares). We further note
your disclosure
      on page 2 that, upon the completion of this offering, you will hold all
of the limited
      partnership interests in your OP. Please revise your summary and
throughout the
      prospectus to clarify, if true, that your OP will own approximately 26.4%
of each of the
      subsidiary partnerships, including revising the structure charts on pages
20 and 121 to
      include the ownership percentages and identify the owners of the
non-controlling
      interests. In addition, please clarify throughout, if true, that you only
hold the economic
      interest in approximately 26.4% of your initial portfolio.
       You may contact Isaac Esquivel at 202-551-3395 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ronald Alper at 202-551-3329 or Jennifer Gowetski at 202-551-3401 with
any other
questions.



                                                           Sincerely,
FirstName LastNameBrian Mitts
                                                           Division of
Corporation Finance
Comapany NameNexPoint Real Estate Finance, Inc.
                                                           Office of Real
Estate & Construction
February 3, 2020 Page 2
cc:       Charles T. Haag
FirstName LastName