United States securities and exchange commission logo March 30, 2022 Frank Saracino Chief Financial Officer BrightSpire Capital, Inc. 590 Madison Avenue, 33rd Floor New York, NY 10022 Re: BrightSpire Capital, Inc. Form 10-K for the fiscal year ended December 31, 2021 Filed February 22, 2022 File No. 001-38377 Dear Mr. Saracino: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Real Estate & Construction