United States securities and exchange commission logo





                             July 14, 2022

       Kristine R. Nario-Eng
       Chief Financial Officer
       New York Mortgage Trust, Inc.
       90 Park Avenue
       New York, New York 10016

                                                        Re: New York Mortgage
Trust, Inc.
                                                            Form 10-K for the
fiscal year ended December 31, 2021
                                                            Filed February 25,
2022
                                                            File No. 001-32216

       Dear Kristine R. Nario-Eng:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the fiscal year ended December 31, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Portfolio Net Interest Margin, page 64

   1.                                                   We note your
presentation of portfolio net interest margin. Please address the following:
                                                            Please tell us if
you determined this measure is a non-GAAP measure, and tell us
                                                             how you made that
determination.
                                                            To the extent you
determined this measure is a non-GAAP measure, please tell us
                                                             how your
disclosure complies with Item 10(e) of Regulation S-K.
                                                            Please tell us how
you determined it is appropriate to exclude the weighted average
                                                             cost of
subordinated debentures, convertible notes, and senior unsecured notes from
                                                             this measure.
                                                        This comment also
applies to your disclosure of portfolio net interest income and portfolio
                                                        net interest margin in
your earnings release.
       Notes to Consolidated Financial Statements
 Kristine R. Nario-Eng
New York Mortgage Trust, Inc.
July 14, 2022
Page 2
7. Use of Special Purpose Entities (SPE) and Variable Interest Entities (VIE)
Consolidated Real Estate VIEs, page F-38

2.       We note your initial consolidation of certain joint venture entities
during 2021 and the
         first quarter of 2022. Please tell us what consideration you gave to
providing audited
         financial statements of the acquired entities and unaudited pro forma
financial
         information. Reference is made to Rule 3-14 of Regulation S-X and
Article 11 of
         Regulation S-X.
       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.

      You may contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-
3295 with any questions.



FirstName LastNameKristine R. Nario-Eng                        Sincerely,
Comapany NameNew York Mortgage Trust, Inc.
                                                               Division of
Corporation Finance
July 14, 2022 Page 2                                           Office of Real
Estate & Construction
FirstName LastName