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    Cadwalader, Wickersham
                                            & Taft LLP

                           650 South Tryon Street, Charlotte,
                           NC 28202

                           Tel +1 704 348 5100 Fax +1 704 348
                           5200

                           www.cadwalader.com

August 30, 2024

Rolaine Bancroft

Office Chief

Office of Structured Finance

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

      Re: J.P. Morgan Chase Commercial Mortgage Securities Corp.

Registration Statement on Form SF-3

Filed June 18, 2024

File No. 333-280318

Dear Ms. Bancroft:

We are counsel to J.P.
Morgan Chase Commercial Mortgage Securities Corp. (the “Registrant”). We have reviewed (i) your letter dated July 15,
2024 (the “Initial Comment Letter”) transmitting comments of the Staff of the Division of Corporation Finance (the
“Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”)
to the Registrant’s registration statement (File No. 333-280318) on Form SF-3 as initially filed on July 18, 2024, and (ii) your
letter dated August 7, 2024 (together with the Initial Comment Letter, the “Comment Letters”) related to the pre-effective
amendment to the registration statement submitted in connection with the Initial Comment Letter (the “Amendment No. 1”).
We have discussed the comments contained in the Comment Letters with various representatives of the Registrant. Capitalized terms used
herein without definition have the meanings given them in the form of prospectus contained in our pre-effective amendment to the registration
statement (the “Amendment No. 2”) submitted herewith.

For your convenience, the
Staff’s comments are repeated in italics below, followed by the Registrant’s responses.

Amendment No. 1 to Registration Statement on Form SF-3

Risk Factors

Risks Related to Conflicts of Interest

Interests and Incentives of the Underwriter Entities May Not Be Aligned
With Your Interests, page 112

David Burkholder   Tel 704
348 5309   Fax 704 348 5200   david.burkholder@cwt.com

Rolaine Bancroft, Esq.

August 30, 2024

  1.
  We note your revisions in response to prior comment 6 and re-issue in part. As revised, the risk factor notes that Securities Act
Rule 192 prohibits certain conflicted transactions and that "certain exemptions" may be available. The revisions do not, however,
appear to qualify your disclosure that that the underwriter entities may execute short transactions, modify or terminate such transactions,
and otherwise act with respect to such transactions "without regard" to whether any such action might have an adverse effect
on the offered certificates or the certificateholders. Please revise to qualify the disclosure as subject to applicable law or explain
how these statements are consistent with Securities Act Rule 192.

The Registrant has revised Amendment No. 2
accordingly.

Part II - Information Not Required in Prospectus

Item 14. Exhibits

Exhibit 5.1 Opinion of Cadwalader, Wickersham & Taft LLP, page
1

 2. We note your legal opinion is limited to New York and Federal law. Please revise to also provide
an opinion that covers Delaware law.

Item 601(b)(5) of Regulation S-K describes
the applicable opinion required in connection with a registration on Form SF-3 as follows: “An opinion of counsel as to the legality
of the securities being registered, indicating whether they will, when sold, be legally issued, fully paid and non-assessable, and, if
debt securities, whether they will be binding obligations of the registrant.”

The securities to be issued under the registration
statement are pass-through trust certificates (“Certificates”) that will be issued by a Trust created under a Pooling
and Servicing Agreement to be entered into at the time a particular series of Certificates is issued by the Registrant, as depositor,
one or more servicers, a trustee and certain other parties. The Trust will be the “issuing entity” within the meaning of Regulation
AB for that particular series of Certificates, and the trustee for that particular series of Certificates will execute, authenticate and
deliver the Certificates on behalf of the Trust. The authorization for the issuance of the Certificates, the terms and conditions applicable
to the Certificates, and the benefits afforded to the holders of the Certificates will all be governed by the terms of the Pooling and
Servicing Agreement, which is a New York law governed agreement.

In light of the foregoing, we believe the questions
that are required to be addressed by the opinion of counsel required by Item 601(b)(5) of Regulation S-K are (1) whether the Certificates
will be legally issued by the Trust, and (2) whether the terms and conditions provided in the Pooling and Servicing Agreement provide
that the Certificates will be fully

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Rolaine Bancroft, Esq.

August 30, 2024

paid and non-assessable, both of which are questions of New York law, notwithstanding that the Registrant,
who will be a party to the Pooling and Servicing Agreement as the depositor, is organized in the State of Delaware. While there are opinions
delivered with respect to the Registrant, as depositor, entering into the Underwriting Agreement and Pooling and Servicing Agreement as
more fully described below, since the Certificates are not issued by the Registrant and are not “obligations of the Registrant”,
the law of the jurisdiction of the Registrant’s organization is not implicated by Item 601(b)(5) of Regulation S-K. Accordingly,
we do not believe that an opinion as to Delaware law is applicable in this context.

At the closing of each securitization transaction
relating to the Certificates, counsel to the Registrant (who may be in-house or outside counsel) will, however, deliver an opinion of
counsel that will address the Registrant’s authorization of the offering and issuance of the Certificates (“Registrant’s
Corporate Opinion”). Specifically, the Registrant’s Corporate Opinion will include an opinion to the effect that: (1)
the Registrant is duly organized, validly existing and in good standing under the laws of the State of Delaware; and (2) the Registrant
has full corporate power and authority to execute and deliver the Underwriting Agreement and Pooling and Servicing Agreement and to perform
its obligations thereunder and the Underwriting Agreement and Pooling and Servicing Agreement have been duly authorized, executed and
delivered by the Registrant. Since (a) the offering of the Certificates will be made by the underwriters pursuant to the terms of the
related Underwriting Agreement, (b) the Trust will be formed and the related mortgage loans will be transferred to the Trust pursuant
to the Pooling and Servicing Agreement, and (c) the Certificates will be issued by the Trust (executed, authenticated and delivered by
the Trustee, the Certificate Registrar and/or Authenticating Agent) pursuant to the Pooling and Servicing Agreement, the delivery of the
Registrant’s Corporate Opinion as to the due execution and delivery by the Registrant of the Underwriting Agreement and the Pooling
and Servicing Agreement provides legal assurance that the Registrant has authorized the offering and issuance of the Certificates.

If you have any questions
concerning the foregoing, please contact the undersigned.

    Very truly yours,

    /s/ David S. Burkholder

    David S. Burkholder

 cc: Kunal K. Singh (w/o enclosures)

      William H. Dunn, Esq. (w/o enclosures)

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