Advanced Flower Capital Inc.

477 S. Rosemary Ave., Suite 301

West Palm Beach, FL 33401

April 22, 2025

Via EDGAR Transmission

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request the acceleration of the effective date of the above-referenced Registration Statement so that it will become effective on April 25, 2025, at 4:00 p.m., Eastern Time, or as soon thereafter as practicable, or at such later time as Advanced Flower Capital Inc. (the “Company”) or its counsel may request via telephone call to the staff.

Please contact Jeeho Lee of O’Melveny & Myers LLP, counsel to the Company, at 212-326-2266, to provide notice of effectiveness, or if you have any other questions or concerns regarding this matter.

cc:          Jeeho M. Lee, Esq.

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