United States securities and exchange commission logo December 20, 2021 Matthew Partridge Chief Financial Officer CTO Realty Growth, Inc. 1140 N. Williamson Blvd. Suite 140 Daytona Beach, FL 32114 Re: CTO Realty Growth, Inc. Form 10-K for the Fiscal Year Ended December 31, 2020 Filed March 5, 2021 File No. 001-11350 Dear Mr. Partridge: 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 & Construction