United States securities and exchange commission logo

                     May 17, 2022

       Brett Asnas
       Chief Financial Officer
       Safehold Inc.
       1114 Avenue of the Americas, 39th Floor
       New York, NY 10036

                                                        Re: Safehold Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed February 15,
                                                            File No. 001-38122

       Dear Mr. Asnas:

              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.


                     Division of Corporation Finance

                     Office of Real Estate & Construction