TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo March 10, 2021 Brandon E. Lacoff Chief Executive Officer Belpointe REIT, Inc. 125 Greenwich Avenue, 3rd Floor Greenwich, CT 06830 Re: Belpointe REIT, Inc. Post Qualification Amendment No. 13 on Form 1-A Filed February 26, 2021 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. Please contact Ruairi Regan at 202-551-3269 or Pam Long at 202-551-3765 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Vanessa Schoenthaler, Esq.