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                           December 23, 2022

       Jilliene Helman
       Chief Executive Officer, President and Director
       RealtyMogul Apartment Growth REIT, Inc.
       10573 W. Pico Blvd.
       PMB #603
       Los Angeles, CA 90064

                                                        Re: RealtyMogul
Apartment Growth REIT, Inc.
                                                            Amended Offering
Statement on Form 1-A
                                                            Filed December 21,
2022
                                                            File No. 024-11298

       Dear Jilliene Helman:

                                                        This is to advise you
that we do not intend to review your amendment.

               We will consider qualifying your offering statement at your
request. If a participant in
       your offering is required to clear its compensation arrangements with
FINRA, please have
       FINRA advise us that it has no objections to the compensation
arrangements prior to
       qualification.

               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.

              Please contact Joseph Ambrogi at 202-551-4821 or Jeffrey Gabor at
202-551-2544 with
       any questions.





                           Sincerely,


                           Division of Corporation Finance

                           Office of Real Estate & Construction
       cc:                                              Lauren B. Prevost, Esq.