United States securities and exchange commission logo

                              December 9, 2021

       Leonard Tannenbaum
       Chief Executive Officer
       AFC Gamma, Inc.
       525 Okeechobee Blvd.
       Suite 1770
       West Palm Beach, FL 33401

                                                        Re: AFC Gamma, Inc.
                                                            Draft Registration
Statement on Form S-11
                                                            Submitted November
12, 2021
                                                            CIK No. 0001822523

       Dear Mr. Tannenbaum:

              We have conducted a limited review of your draft registration
statement. In our
       comment, we may ask you to provide us with information so we may better
understand your

               Please respond to this letter by providing any requested
information and by publicly
       filing your registration statement and non-public draft submission on
EDGAR. If you do not
       believe our comment applies 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 this
comment and your filed
       registration statement, we may have additional comments.

       Draft Registration Statement on Form S-11

       Prospectus Summary
       Collateral Overview, page 8

   1.                                                   We note the statement
on page 2 that your "portfolio of loans had weighted average real
                                                        estate collateral
coverage of approximately 1.2 times our aggregate committed principal
                                                        amount." Please expand
your disclosure to clarify with specificity the limitations on your
                                                        ability to foreclose
under applicable state law and identify the material regulatory and
                                                        legal risks associated
with the jurisdictions in which your collateral is located. Further,
                                                        please clarify whether
listing standards would prevent you from foreclosing and taking
                                                        possession of the real
estate or other collateral. Please clarify whether the coverage ratio
 Leonard Tannenbaum
AFC Gamma, Inc.
December 9, 2021
Page 2
       would be achievable under circumstances where, for example, you were to
sell the loan or
       force the borrower to sell the collateral in the event of a delinquency
or default.
        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.

        We also remind you that your registration statement must be on file no
later than 48 hours
prior to the requested effective date and time. 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.

       Please contact Stacie Gorman at 202-551-3585 or James Lopez at
202-551-3536 with any

FirstName LastNameLeonard Tannenbaum
                                                            Division of
Corporation Finance
Comapany NameAFC Gamma, Inc.
                                                            Office of Real
Estate & Construction
December 9, 2021 Page 2
cc:       Jeeho M. Lee, Esq.
FirstName LastName