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      Dynex Capital Request for Extension of Response to SEC Comment Letter

      November
        17, 2005

      Jorge
        Bonilla

      Senior
        Staff Accountant

      Securities
        and Exchange Commission

      Division
        of Corporation Finance

      Washington,
        D.C. 20549

      Re: Dynex
        Capital, Inc.

      SEC
        comment letter on Form 10-K for Fiscal Year Ended December 31, 2004, Form

      10-Q
        for the Quarterly Period Ended March 31, 2005 and Form 10-Q for the

      Quarterly
        Period Ended June 30, 2005

      File
        No. 0-20507

      Dear
        Mr.
        Bonilla:

      Dynex
        Capital, Inc. (the “Company”) has received the comments of the staff of the
        Commission

      by
        letter
        dated November 3, 2005 with respect to the Company’s Annual Report and Quarterly

      Reports
        on Forms 10-K and 10-Q, respectively, referred to above.

      The
        Company is confirming that, following your telephone conversation with Jay
        Oakey
        of

      Williams
        Mullen yesterday, the Company has an extension on until December 14, 2005
        to
        submit

      its
        response to the comments.

      Thank
        you
        for your assistance. If you have any additional questions or comments, you
        may
        reach

      me
        at
        (804) 217-5837.

      Very
        truly yours,

      /s/
        Stephen J. Benedetti

      Stephen
        J. Benedetti

      Principal
        Executive Officer