United States securities and exchange commission logo

                             July 22, 2022

       Brett Kaufman
       Chief Financial Officer
       AFC Gamma, Inc.
       525 Okeechobee Blvd.
       Suite 1770
       West Palm Beach, FL 33401

                                                        Re: AFC Gamma, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed March 10,
                                                            File No. 001-39995

       Dear Brett Kaufman:

               We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment. In our comment, we may ask
you to provide us
       with information so we may better understand your disclosure.

              Please respond to the comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to the comment, we may have additional comments.

       Form 10-K for the fiscal year ended December 31, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operation
       Liquidity and Capital Resources, page 76

   1.                                                   We note your disclosure
on page F-11 that to maintain the Company   s status as a
                                                        REIT, payment-in-kind
interest, a non-cash source of income, must be paid out to
                                                        stockholders in the
form of dividends for the year earned, even though the Company has
                                                        not yet collected the
cash. We further note your dividends paid to stockholders exceeded
                                                        the net cash provided
by operating activities. To the extent your dividends were not paid
                                                        out of operating cash
flows, please tell us what consideration you gave to disclosing the
                                                        source of your dividend

              In closing, 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
 Brett Kaufman
AFC Gamma, Inc.
July 22, 2022
Page 2

absence of action by the staff.

      You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at
3295 with any questions.

FirstName LastNameBrett Kaufman                        Sincerely,
Comapany NameAFC Gamma, Inc.
                                                       Division of Corporation
July 22, 2022 Page 2                                   Office of Real Estate &
FirstName LastName