February 18, 2021
Via E-mail

Amos W. Barclay, Esq.
Holland & Hart LLP
1800 Broadway, Suite 300
Boulder, CO 80302

       Re:     CNL Healthcare Properties, Inc.
               Schedule TO-T filed February 10, 2021 by Comrit Investments 1,
Limited
                      Partnership and Comrit Investments Ltd.
               File No. 005-90567

Dear Mr. Barclay:

       The staff in the Office of Mergers and Acquisitions has reviewed the
filing listed above,
and we have the comments set forth below. All defined terms used herein have
the same
meaning as in the Offer to Purchase attached as Exhibit (a)(1) to the Schedule
TO-T. 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 filing, by providing the
requested
information, or by advising us when you will provide the requested response. 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 filing and the information you
provide in
response to these comments, we may have additional comments.

Schedule TO-T
Exhibit (a)(1), Offer to Purchase

1. Revise the disclosure here and in the Notice of Offer to Purchase to correct
the statement that
   withdrawal rights will    expire    on March 30, 2021. As you correctly
describe on page 11,
   tendering shareholders also have the right to withdraw tendered Shares not
accepted for
   payment by the 60th day after commencement of this Offer. See Exchange Act
   Section 14(d)(5).

2. Please disclose that you previously conducted a tender offer for shares of
the Company and
   state the per share purchase price for that offer.
 Amos W. Barclay, Esq.
Holland & Hart LLP
February 18, 2021
Page 2

Section 3. Procedures for Tendering Shares

3. Please tell us whether the offer has    commenced    within the meaning of
Rule 14d-2(a). In
   this respect, it appears that you have provided shareholders with the means
to tender by filing
   the Assignment Form as exhibit (a)(2), identifying the CTT Auctions website
where
   shareholders can access another copy of the form, and directing shareholders
how to deliver
   the form.

4. In your response letter, please tell us how and when you complied or will
comply with the
   dissemination requirements set forth in Rule 14d-4. To the extent that the
bidder relied upon
      Summary publication    as described in Rule 14d-4(a)(2) to disseminate
the tender offer to
   security holders, please advise us of the medium through which the notice
was distributed.

                                              *   *    *

       We remind you that the bidders are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

        Please direct any questions to me at (202) 551-7951.


                                                      Sincerely,

                                                      /s/ Joshua Shainess

                                                      Joshua Shainess
                                                      Special Counsel
                                                      Office of Mergers and
Acquisitions