United States securities and exchange commission logo

July 7, 2022

Bryan Donohoe
Chief Executive Officer
Ares Commercial Real Estate Corporation
245 Park Avenue, 42nd Floor
New York, NY 10167

Re: Ares Commercial
Real Estate Corporation
Registration
Statement on Form S-3
Filed June 30, 2022
File No. 333-265937

Dear Mr. Donohoe:

This is to advise you that we have not reviewed and will not
review your registration
statement.

Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 Shih-Kuei Chen at 202-551-7664 or Ruairi Regan at
202-551-3269 with
any questions.

Sincerely,

Division of Corporation Finance

Office of Real Estate & Construction
cc: Monica J. Shilling,
Esq.