Ares Commercial Real Estate Corporation

245 Park Avenue, 42nd Floor

New York, NY 10167

July 22, 2022

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Ares Commercial Real Estate Corporation (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form S-3 (the “Registration Statement”), File No. 333-265937, as amended, to 4:00 p.m., Eastern Time, on July 26, 2022, or as soon thereafter as practicable.

Please contact Monica J. Shilling, of Kirkland & Ellis LLP, counsel to the Company, at (310) 552-4355 as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.

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