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                       September 29, 2020

       Brandon E. Lacoff
       Chief Executive Officer
       Belpointe REIT, Inc.
       125 Greenwich Avenue, 3rd Floor
       Greenwich, Connecticut 06830

                                                        Re: Belpointe REIT,
Inc.
                                                            Post-Qualification
Amendment on Form 1-A
                                                            Filed September 14,
2020
                                                            File No. 024-10923

       Dear Mr. Lacoff:

                                                        We have reviewed your
amendment and do not have any comments.

               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 Ruairi Regan at 202-551-3269 or Pam Long at
202-551-3765 with any
       questions.




                       Sincerely,


                       Division of Corporation Finance

                       Office of Real Estate & Construction
       cc:                                              Vanessa Schoenthaler,
Esq.