Mail Stop 3628

                                                               May 21, 2021

    Via E-mail
    Tobin Cobb
    President and Chief Executive Officer
    3650 REIT Commercial Mortgage Securities II LLC
    2977 McFarlane Road, Suite 300
    Miami, Florida 33133

           Re:    3650 REIT Commercial Mortgage Securities II LLC
                  Amendment No. 1 to Registration Statement on Form SF-3
                  Filed May 10, 2021
                  File No. 333-255181

    Dear Mr. Cobb:

           We have reviewed your amended registration statement and response
letter 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 May 7,
2021 letter.

    Registration Statement on Form SF-3

    General

        1. We note your responses and revisions to your registration statement
in response to our
           prior comments # 3 and 4 regarding forbearance agreements and other
temporary
           payment deferral arrangements. In particular, we note your
newly-added disclosure
           under       P&I Advances    on page 256 of your amended registration
statement, which
           draws a distinction between mortgage loans that are    subject to
forbearance agreements
           or other temporary deferrals or payment accommodations    and
mortgage loans whose
           terms    have been permanently modified to reduce or forgive a
monetary obligation.
 Tobin Cobb
3650 REIT Commercial Mortgage Securities II LLC
May 21, 2021
Page 2


       Your registration statement includes a number of other references to
modifications,    and
       it is not clear to us which of these references, if any, are intended to
include forbearance
       agreements and other temporary payment deferral arrangements as well as
permanent
       modifications. For example:

                 Will the servicer be entitled to receive modification fees
and/or workout fees in
               respect of mortgage loans that are subject to forbearance
agreements or other
               temporary payment deferral arrangements?

                 Do the risks described in your registration statement related
to modifications of
               mortgage loans (e.g., shortfall risk) also apply in the case of
mortgage loans that
               are subject to forbearance agreements or other temporary payment
deferral
               arrangements?

                 Certain modifications or waivers of monetary terms of a
mortgage loan are
               considered    major decisions    and may require consent of one
or more servicers
               and/or non-objection by the directing certificateholder. Would a
forbearance
               agreement or other temporary payment deferral arrangement
constitute a
               modification or waiver of the monetary terms of a mortgage loan,
such that it
               would be considered a    major decision   ?

       Please revise your registration statement to clarify whether these and
other references to
          modifications    in your registration statement are intended to
include forbearance
       agreements and other temporary payment deferral arrangements. If not,
please revise to
       clarify the appropriate treatment of forbearances and other temporary
deferral
       arrangements in these contexts, as appropriate.

Exhibits

   2. Please confirm that you have made conforming revisions to all transaction
documents, as
      applicable, and file any amended agreements as necessary with your next
pre-effective
      amendment.

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
 Tobin Cobb
3650 REIT Commercial Mortgage Securities II LLC
May 21, 2021
Page 3


      You may contact Benjamin Meeks, Special Counsel, at (202) 551-7146 or me
at (202)
551-3850 if you have any questions.


                                                       Sincerely,

                                                       /s/ Katherine Hsu

                                                       Katherine Hsu
                                                       Chief, Office of
Structured Finance


cc:   Mark Jefferis, Esq.
      3650 REIT

      Greg Prindle, Esq.
      Cadwalader, Wickersham & Taft LLP