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United States securities and exchange commission logo





                            August 5, 2022

       Kristine R. Nario-Eng
       Chief Financial Officer
       New York Mortgage Trust, Inc.
       90 Park Avenue
       New York, New York 10016

                                                        Re: New York Mortgage
Trust, Inc.
                                                            Form 10-K for the
fiscal year ended December 31, 2021
                                                            Filed February 25,
2022
                                                            File No. 001-32216

       Dear Kristine R. Nario-Eng:

              We have reviewed your July 27, 2022 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       July 14, 2022 letter.

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

       Item 7, Management Discussion and Analysis of Financial Condition and
Results of Operations
       Portfolio Net Interest Margin , page 64

   1.                                                   We note your response
to comment 1. We note your revised presentation to reflect
                                                        portfolio interest
expense and portfolio net interest income as non-GAAP measures. You
                                                        adjust these measures
and portfolio net interest margin to exclude interest expense from
                                                        subordinated
debentures, convertible notes, senior unsecured notes and mortgages payable
                                                        on real estate. Please
address the following:
                                                            Please further
clarify for us how you determined it was appropriate to exclude interest
                                                            expense from
subordinated debentures, convertible notes and senior unsecured notes.
                                                            You stated that you
excluded these items because they do not directly and exclusively
                                                            finance your
interest earning investments. Please tell us how you determined that
 Kristine R. Nario-Eng
New York Mortgage Trust, Inc.
August 5, 2022
Page 2
              these investments should be excluded, in light of the fungible
characteristic of cash.
                You further stated that the senior unsecured notes currently
finance joint venture
              equity investments in multi-family properties. Please tell us how
you determined that
              these notes finance these particular equity investments.
2.       We note your response to our prior comment 1. Please address the
following:
             We note that you determined portfolio net interest margin is an
operating measure. It
            appears that the components in the formula to calculate portfolio
net interest margin
            may be derived from GAAP measures. Specifically, interest earning
assets and
            interest income are adjusted to exclude the impact from all
consolidated SLST assets
            and all consolidated K-Series assets other than those securities
owned by the
            Company. Further, interest bearing liabilities and interest expense
are adjusted to
            exclude the impact from subordinated debentures, convertible notes,
senior unsecured
            notes and mortgages payable on real estate. Please further clarify
for us how you
            determined the components are not derived from GAAP measures and
how you
            determined portfolio net interest margin is not a non-GAAP measure.
             We note your revised presentation to reflect portfolio interest
expense as a non-
            GAAP measure. Please clarify for us if portfolio interest expense
is a component of
            portfolio net interest margin. To the extent it is a component of
portfolio net interest
            margin, please reconcile for us how you determined that portfolio
interest expense is
            a non-GAAP measure and portfolio net interest margin is an
operating measure.

       You may contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295 if
you have any questions.



FirstName LastNameKristine R. Nario-Eng                        Sincerely,
Comapany NameNew York Mortgage Trust, Inc.
                                                               Division of
Corporation Finance
August 5, 2022 Page 2                                          Office of Real
Estate & Construction
FirstName LastName
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