SecProbe.io

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Mail Stop 3561

      	July 18, 2005

Via U.S. Mail

Robert Gerald Buchanan, President
Genco Shipping and Trading Limited
35 West 56th Street
New York, New York  10019

Re: 	Genco Shipping and Trading Limited
	Registration Statement on Form S-1
	Filed July 6, 2005
	File No. 333-124718

Dear Mr. Buchanan,

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      The purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to
enhance
the overall disclosure in your filing.  We look forward to working
with you in these respects and welcome any questions you may have
about our comments or on any other aspect of our review.  Feel
free to
call us at the telephone numbers listed at the end of this letter.

Registration Statement Cover Page
1. It appears that the maximum aggregate offering price of your
offering has increased.  In the next amendment, please revise your
fee
calculation and pay the additional fee.  Please refer to Rule
457(o)
of Regulation C.

Dividend Policy, page 5
2. We note that you expect to declare your first quarterly
dividend of
54 cents per share by November 2005 based on your operations for
the
third quarter of 2005.  As you have no history of dividend
payments at
this date and as dividend payments are solely at the discretion of
the
board, please specifically state these facts in an accompanying
sentence.  In addition, please clarify in this section the extent
to
which reserves for debt repayment, drydocking and other such
obligations have been deducted when deriving your estimate.  In
other
words, if this payment takes into account only available cash from
operations less cash expenses for the quarter, please so state.

Equity Incentive Plan, page 81
3. In the first sentence of the last paragraph, clarify if the
exercise price of the restricted shares to be awarded to Messrs.
Buchanan and Wobensmith will be the initial public offering price.
Further, if the various awards described in the final paragraph
are
expected to result in significant compensation expense, it appears
that appropriate disclosure should be provided in the
Capitalization
table on page 29.  Please revise or advise.
Principal and Selling Shareholders, page 82
4. Please revise your table to add columns depicting the number of
shares to be sold and the percent of class after the offering
considering the over-allotment option.

Underwriting, page 107
General
5. We note your supplemental responses to prior comments 23 and 24
from our letter to you dated June 6, 2005.  Please provide us with
copies of all information concerning your company or prospectus
that
has appeared on the websites.

Directed Share Program, page 108
6. We note your response to prior comment 10; however, per a phone
call received from your counsel on July 8, 2005, we note that the
lock-up terms of your directed share program may have changed.
Please
provide us with an updated response.

Over-Allotment Option, page 108
7. Please revise to disclose the number of shares available to the
underwriters through the over-allotment option.

Lock-up Agreements, page 108
8. Please update this section considering your changes to the
directed
share program.  Please file any lock-up agreements as exhibits to
the
registration statement.

Report of Independent Registered Public Accounting Firm, page F-2
9. Prior to requesting effectiveness of the Registration
Statement,
please provide in an amended filing, an unrestricted accountants`
report and accountants` consent.

Exhibit 5
10. Please provide an opinion with respect to the shares offered
by
the selling shareholder and the shares offered by the selling
shareholder through the over-allotment option.

Exhibit 23.2
11. Amendments should contain currently dated accountants`
consents.
Manually signed consents should be kept on file for five years.
Please
refer to Rule 402 of Regulation C.

Other
12. Please continue to consider the financial statement updating
requirements set forth in Rule 3-12 of Regulation S-X.

* * * * *

      As appropriate, please amend the registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have
made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, acting pursuant to
delegated authority in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* The company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal
securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in connection with our review of your
filing or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Beverly Singleton at (202) 551-3328 or
Margery
Reich at (202) 551-3347 if you have questions regarding comments
on
the financial statements and related matters.  Please contact
Rolaine
Bancroft at (202) 551-3313 or me at (202) 551-3755 with any other
questions.

      	Regards,

      	Max A. Webb
      	Assistant Director

cc:	Gary J. Wolfe, Esq.
      Seward & Kissel LLP
	via facsimile:  (212) 480-8421
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Mr. Robert Gerald Buchanan
Genco Shipping and Trading Limited
July 18, 2005
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