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                            April 22, 2024

       Nathan D. DeBacker
       Chief Financial Officer
       CIM Real Estate Finance Trust, Inc.
       2398 East Camelback Road, 4th Floor
       Phoenix, AZ 85016

                                                        Re: CIM Real Estate
Finance Trust, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2023
                                                            File No. 000-54939

       Dear Nathan D. DeBacker:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2023

       Notes to Consolidated Financial Statements
       Note 10 - Repurchase Facilities, Notes Payable and Credit Facilities,
page F-36

   1.                                                   We note that you use
repurchase agreements to finance certain assets. Please consider
                                                        expanding your
disclosure to quantify the average quarterly balance of your repurchase
                                                        agreements for each
period included in your financial statements. In addition, consider
                                                        quantifying the period
end balance for each of those quarters, the maximum balance at any
                                                        month-end and
explaining the causes and business reasons for any significant variances
                                                        among these amounts.
              In closing, 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 William Demarest at 202-551-3432 or Isaac Esquivel
at 202-551-3395
       with any questions.
 Nathan D. DeBacker
CIM Real Estate Finance Trust, Inc.
April 22, 2024
Page 2



FirstName LastNameNathan D. DeBacker               Sincerely,
Comapany NameCIM Real Estate Finance Trust, Inc.
                                                   Division of Corporation
Finance
April 22, 2024 Page 2                              Office of Real Estate &
Construction
FirstName LastName