United States securities and exchange commission logo October 11, 2022 Michael J. Mazzei Chief Executive Officer and Director BrightSpire Capital, Inc. 590 Madison Avenue, 33rd Floor New York, NY 10022 Re: BrightSpire Capital, Inc. Registration Statement on Form S-3 Filed October 4, 2022 File No. 333-267733 Dear Michael J. Mazzei: 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 Catherine De Lorenzo at 202-551-4079 or Jeffrey Gabor at 202-551- 2544 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: David Palame, Esq.