April 1, 2019 Andrew C. Richardson Chief Financial Officer Safehold Inc. 1114 Avenue of the Americas 39th Floor New York, NY 10036 Re: Safety, Income & Growth Inc. Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 14, 2019 File No. 001-38122 Dear Mr. Richardson: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Real Estate and Commodities