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                        July 23, 2021

       Richard Mack
       Chief Executive Officer
       Claros Mortgage Trust, Inc.
       c/o Mack Real Estate Credit Strategies, L.P.
       60 Columbus Circle, 20th Floor
       New York, NY 10023

                                                        Re: Claros Mortgage
Trust, Inc.
                                                            Amendment No. 5 to
                                                            Draft Registration
Statement on Form S-11
                                                            Submitted June 28,
2021
                                                            CIK No. 0001666291

       Dear Mr. Mack:

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

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.
 Richard Mack
FirstName  LastNameRichard
Claros Mortgage Trust, Inc. Mack
Comapany
July       NameClaros Mortgage Trust, Inc.
     23, 2021
July 23,
Page  2 2021 Page 2
FirstName LastName
Amendment No. 5 to Draft Registration Statement on S-11 submitted June 28, 2021

Financial Statements
Note 3. Loans Portfolio
Loan Modifications, page F-22

1.       We note your disclosure regarding your loan modifications. We further
note that
         approximately $1.25 billion, $1.36 billion and $1.3 billion of unpaid
principal balance
         had a 4 risk rating as of June 30, 2020, December 31, 2020 and March
31, 2021
         respectively. Please tell us whether any of these loans were subject
to modification, and if
         so explain to us whether you concluded those modifications to be
troubled debt
         restructurings in accordance with ASC 310-40. Your response should
include a
         discussion of how you determined the loan modification was or was not
a troubled debt
         restructuring.
       You may contact Babette Cooper at 202-551-3396 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any
other
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Real
Estate & Construction