United States securities and exchange commission logo May 8, 2024 David Thompson Chief Executive Officer Creative Media & Community Trust Corp 5956 Sherry Lane, Suite 700 Dallas, TX 75225 Re: Creative Media & Community Trust Corp Registration Statement on Form S-11 Filed April 11, 2024 File No. 333-278628 Dear David Thompson : We have conducted a limited review of your registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe the comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Form S-11 filed April 11, 2024 General 1. We note that there are outstanding comments on your Form 10-K for the fiscal year ended December 31, 2023. Please note we will not be in a position to accelerate the effectiveness of your registration statement until all comments are resolved. 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. David Thompson Creative Media & Community Trust Corp May 8, 2024 Page 2 Please contact Pearlyne Paulemon at 202-551-8714 or Stacie Gorman at 202-551-3585 with any questions. Sincerely, FirstName LastNameDavid Thompson Division of Corporation Finance Comapany NameCreative Media & Community Trust Corp Office of Real Estate & Construction May 8, 2024 Page 2 cc: Patrick S. Brown FirstName LastName