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                              June 6, 2022

       R. Ramin Kamfar
       Chief Executive Officer
       Bluerock Homes Trust, Inc.
       1345 Avenue of the Americas, 32nd Floor
       New York, NY 10105

                                                        Re: Bluerock Homes
Trust, Inc.
                                                            Amendment No. 1 to
Form 10-12B
                                                            Filed April 22,
2022
                                                            File No. 001-41322

       Dear Mr. Kamfar:

              We have reviewed your filing 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. References to prior comments refer to comments in our letter
dated April 8, 2022.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response and any amendment you may file in
response to these
       comments, we may have additional comments.

       Amendment No. 1 to Form 10-12B filed April 22, 2022

       Unaudited Pro Forma Combined Statement of Operations
       Adjustments to the Unaudited Pro Forma Combined Statement of Operations,
page 87

   1.                                                   We continue to consider
your response to comment 2.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Funds from Operations and Core Funds from Operations Attributable to
Common Stockholders
       and Unitholders, page 101

   2.                                                   We note your response
to comment 4. Please revise your tabular reconciliation to more
                                                        accurately describe the
adjustments that are presented net of your joint venture partners
                                                        noncontrolling interest
share.
 R. Ramin Kamfar
Bluerock Homes Trust, Inc.
June 6, 2022
Page 2
Business and Properties, page 103

3.       We note your amended disclosure in response to comment 7. We also note
your response
         that you do not believe it would be informative to investors to
specifically identify each
         unit or property that has planned renovations. Please quantify how
many properties or
         units renovations have been planned for or are currently undergoing
renovations.
Combined Financial Statements, page F-1

4.       We continue to consider your response to comment 9.
        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.

       You may contact Howard Efron at 202-551-3439 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Austin Wood at 202-551-5586 or Pam Long at 202-551-3765 with any other
questions.



FirstName LastNameR. Ramin Kamfar                             Sincerely,
Comapany NameBluerock Homes Trust, Inc.
                                                              Division of
Corporation Finance
June 6, 2022 Page 2                                           Office of Real
Estate & Construction
FirstName LastName