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                               January 15, 2021

       Brandon Dutch Mendenhall
       President and Chief Executive Officer
       RAD Diversified REIT, Inc.
       211 N. Lois Avenue
       Tampa, FL 33609

                                                        Re: RAD Diversified
REIT, Inc.
                                                            Offering Statement
on Form 1-A
                                                            Post-qualification
Amendment No. 1
                                                            Filed December 30,
2020
                                                            File No. 024-11020

       Dear Mr. Mendenhall:

              We have reviewed your amendment 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 this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response. After reviewing any amendment to your offering statement and
the information you
       provide in response to these comments, we may have additional comments.

       Post-qualification Amendment No. 1 to Offering Statement on Form 1-A

       General

   1.                                                   We note that you have
adjusted the price four times since your Form 1-A was qualified
                                                        on November 1, 2019. It
does not appear that you filed any offering circular supplements
                                                        or post-qualification
amendments to reflect these price adjustments. Please give us your
                                                        detailed analysis on
whether offers and sales made after the first price adjustment
                                                        complied with
Regulation A and were not made in violation of Section 5.
   2.                                                   We note that you have
removed your summary risk factor section. Since your risk factor
                                                        discussion is longer
than 15 pages, please revise to provide a section with a series of
                                                        concise, bulleted or
numbered statements that is no more than two pages summarizing the
                                                        principal factors that
make an investment in the registrant or offering speculative or risky.
                                                        See Item 105(b) of
Regulation S-K.
 Brandon Dutch Mendenhall
RAD Diversified REIT, Inc.
January 15, 2021
Page 2
Results of Operation, page 90

3.     We note your revised disclosure in response to comment 4. You disclose
that you have
       generated $339,862 of revenue as of June 30, 2020; however, you also
disclose that you
       have recognized $319,176 of revenue for the interim period ended June
30, 2020.
       Additionally, you disclose that you recognized $16,687 in rental
revenues for the year
       ended December 31, 2019; however, according to your financial statements
you
       recognized $67 in revenue. Please reconcile.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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 Ronald (Ron) Alper at 202-551-3329 or Jonathan Burr at
202-551-5833
with any questions.



                                                             Sincerely,
FirstName LastNameBrandon Dutch Mendenhall
                                                             Division of
Corporation Finance
Comapany NameRAD Diversified REIT, Inc.
                                                             Office of Real
Estate & Construction
January 15, 2021 Page 2
cc:       Fanni Koszeg
FirstName LastName