July 18, 2025

Frank V. Saracino
Chief Financial Officer
BrightSpire Capital, Inc.
590 Madison Avenue, 33rd Floor
New York, NY 10022

       Re: BrightSpire Capital, Inc.
           Form10-K for the year ended December 31, 2024
           File No. 001-38377
Dear Frank V. Saracino:

       We have reviewed your filing 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 year ended December 31, 2024
Non-GAAP Supplemental Financial Measures
Undepreciated Book Value Per Share, page 60

1.     We note your presentation of undepreciated book value and undepreciated
book value
       per share as non-GAAP financial measures. In regards to your
presentation please
       address the following
           Revise your disclosure regarding the definition of undepreciated
book value as it
           does not appear to address all the items that are being adjusted
from the most
           directly comparable GAAP measure, which appears to be stockholders
 equity
           excluding noncontrolling interests in investment entities.
Specifically, your
           definition does not appear to discuss non-GAAP impairment of real
estate as an
           adjustment; and
           Expand your disclosure to indicate that the non-GAAP impairment
adjustment is
           itself a non-GAAP financial measure, provide a reconciliation to its
most directly
           comparable GAAP measure and expand your disclosure to discuss the
usefulness
           of such measure.
       Refer to Item 10(e) of Regulation S-K.
 July 18, 2025
Page 2

        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 Ameen Hamady at 202-551-3891 or Isaac Esquivel at
202-551-3395 if
you have questions regarding comments on the financial statements and related
matters.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Real Estate
& Construction