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Eversheds Sutherland (US) LLP
700 Sixth Street, NW, Suite 700
Washington, DC 20001-3980
D: +1 202.383.0472
F: +1 202.637.3593
cynthiabeyea@
eversheds-sutherland.com

November 30, 2022
VIA EDGAR

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re:
CIM Real Assets & Credit Fund
SEC File Nos. 333-229782 and 811-23425
Post-Effective Amendment No. 4
Commissioners:
On behalf of CIM Real Assets & Credit Fund (the “Registrant”), we are transmitting electronically for filing pursuant to the Securities Act of 1933 (the “1933 Act”) and the Investment Company Act of 1940 (the “1940 Act”), the Registrant’s Post-Effective Amendment No. 4 to its Registration Statement on Form N-2.

This Post-Effective Amendment is being filed pursuant to Rule 486(a) under the 1933 Act for the purpose of expanding the Registrant’s investment strategies to include international investing and to provide accompanying risk factors, as well as updating certain other information.

If you have any questions, please call the undersigned at the above number.
Sincerely,

/s/ Cynthia R. Beyea        

Cynthia R. Beyea


Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.