November 14, 2019

Brian Mitts
President
NexPoint Real Estate Finance, Inc.
300 Crescent Court
Suite 700
Dallas, Texas 75201

       Re: NexPoint Real Estate Finance, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-11
           Submitted October 22, 2019
           CIK No. 0001786248

Dear Mr. Mitts:

      We have reviewed your amended draft registration statement 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
October 10, 2019 letter.

Amendment No. 1 to Draft Registration Statement on Form S-11

Our Strategic Relationship with Our Sponsor3, page 3

1.     We note your response to prior comment 3 and continue to note the
disclosure in the
       summary regarding the enterprise values and increase in market
capitalization. Please
       revise to move this disclosure to the Business section and balance by
qualifying the
       leverage associated with these entities and a discussion of any losses
or adverse business
       developments specific to these entities. In addition, we note the return
information on
       page 105 from March 2015 to June 2019 and the comparison with RMZ from
June 2018
       to June 2019. With a view toward disclosure, please provide us a
comparison with RMZ
 Brian Mitts
FirstNameReal Estate Finance, Inc.
NexPoint LastNameBrian Mitts
Comapany 14, 2019
November NameNexPoint Real Estate Finance, Inc.
November 14, 2019 Page 2
Page 2
FirstName LastName
         for the entire period from March 2015 to June 2019 and provide annual
returns for the
         same period, including net income/loss for each year.
Our Financing Strategy, page 13

2.       We note your revised disclosure in response to prior comment 4. We
continue to believe
         you should consider adding a discussion of assets and liabilities on a
gross basis in places
         you have discussed them on a net basis. For instance, we note your
disclosure on page 2
         that SFR loans will be 86% of total assets upon completion of the
formation transactions.
         However, based on your pro forma financial statements, SFR loans
represent
         approximately 47% of total assets. Please further revise your
disclosure or explain to us
         why you do not believe additional disclosure is necessary.
Notes to the Unaudited Pro Forma Consolidated Financial Statements
Note 2. Formation Transaction and Initial Public Offering, page F-11

3.       We note your response to our prior comment 15. We are continuing to
consider your
         response and may have additional comments.
Note 4. Pro Forma Adjustments, page F-19

4.       We note that your calculation of interest revenue assumes no
prepayments during the
         period. Please tell us whether you have experienced any significant
prepayments with
         respect to your investment assets, and if so, explain to us why they
were not considered in
         your calculation of interest revenue.
5.       We have considered your response to our prior comment 17. We note in
your disclosure
         on page F-14 that you intend to elect the fair value option with
respect to the assets and
         liabilities held by the consolidated CMBS Entity. However, it appears
that your
         methodology for recognizing revenue with respect to the loans held by
the CMBS Entity
         assumes the loans are carried at amortized cost. Please clarify for us
how you determined
         your methodology for recording revenue related to the CMBS assets for
pro forma
         financial statements purposes reconciles with your decision to elect
the fair value option.
6.       We have considered your response to our prior comment 19. We remain
unclear how
         your adjustments related to the estimated distribution and corrporate
general and
         administrative expenses are factually supportable. Please revise your
pro forma financial
         statements to eliminate these adjustments or further explain to us how
they are factually
         supportable.
General

7.       We note your response to prior comment 5. We have referred your
response to the
         Division of Investment Management for further review and they will
contact you directly
         when they have completed their review.
8.       We note the revised disclosure on pages 3, 62 and 101 that Highland
filed for Chapter 11
 Brian Mitts
NexPoint Real Estate Finance, Inc.
November 14, 2019
Page 3
      bankruptcy protection and that your sponsor is affiliated through common
control with
      Highland. Please revise to more specifically describe how your sponsor is
affiliated with
      Highland, including identifying the certain directors and executive
officers that serve in
      various capacities at Highland or its affiliated entities. In addition,
please more
      specifically describe this bankruptcy filing and any potential conflicts
of interest.
       You may contact Isaac Esquivel, Staff Accountant, at (202) 551-3395 or
Robert
Telewicz, Accounting Branch Chief, at (202) 551-3438 if you have questions
regarding
comments on the financial statements and related matters. Please contact Folake
Ayoola, Senior
Counsel, at (202) 551-3673 or Jennifer Gowetski, Senior Counsel, at (202)
551-3401 with any
other questions.



                                                           Sincerely,
FirstName LastNameBrian Mitts
                                                           Division of
Corporation Finance
Comapany NameNexPoint Real Estate Finance, Inc.
                                                           Office of Real
Estate & Construction
November 14, 2019 Page 3
cc:       Charlie Haag
FirstName LastName