April 22, 2025

Daniel Neville
Chief Executive Office
Advanced Flower Capital Inc.
477 S. Rosemary Ave.
Suite 301
West Palm Beach, FL 33401

       Re: Advanced Flower Capital Inc.
           Registration Statement on Form S-3
           Filed April 17, 2025
           File No. 333-286604
Dear Daniel Neville:

       This is to advise you that we have not reviewed and will not review your
registration
statement.

        Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Stacie Gorman at 202-551-3585 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Jeeho M. Lee, Esq.