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 April 3, 2025

Tayfun Tuzun
Chief Financial Officer
Bank of Montreal
100 King Street West, 1 First Canadian Place
Toronto, Ontario, Canada M5X 1A1

 Re: Bank of Montreal
 Form 40-F for Fiscal Year Ended October 31, 2024
 Reponse dated March 14, 2025
 File No. 001-13354
Dear Tayfun Tuzun:

 We have reviewed your March 14, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our March 3,
2025 letter.

Form 40-F for Fiscal Year Ended October 31, 2024
Note 10: Acquisitions, page 171

1. We have reviewed your response to our previous comment. We note your
disclosure
 on page 171 that the fair value hedges, coupled with other actions taken
to manage
 your interest rate risk profile to you target position, crystallized a
$5.7 billion loss on
 the U.S. Treasuries and other instruments which you accrete as a
reduction to net
 interest income over their remaining life through accounting for the new
fair value
 hedges. Please provide the reference to the applicable literature to
support the
 crystallization of this loss (as amortized cost instruments) and provide
an illustrative
 example with journal entries showing how this loss is accreted as a
reduction to net
 interest income using the effective interest method. Additionally,
please quantify the
 impacts on your net interest income in each of the past two fiscal years
as well as the
 expected impact in fiscal year 2025 and future annual periods and tell
us how you
 April 3, 2025
Page 2

 considered disclosing these impacts in the MD&A included in Exhibit 99.2
to your
 annual report.
2. Please tell us how you determined the net interest income for the U.S.
Treasuries and
 other instruments carried at amortized cost and why those were negative
for certain
 periods. As part of your response, please consider providing
illustrative examples of
 the calculation for a period that resulted in net interest income and a
period that
 resulted in net interest expense.
3. Please summarize for us the general working principles of your Quasi
Fair Value
 Swap ( QFV Swap ) model and how you assess the hedging effectiveness
under IAS
 39. As part of your response, please contrast this approach with the
hypothetical
 derivative method discussed in paragraph B6.5.5 of IFRS 9 and
consider providing
 illustrative examples in your response.
 Please contact Mengyao Lu at 202-551-3471 or Lory Empie at 202-551-3714
if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
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