SecProbe.io

July 28, 2011
 VIA E-Mail

Ms. Anne D. McCallion Chief Financial Officer PennyMac Mortgage Investment Trust 27001 Agoura Road Calabasas, CA  91301
Re: PennyMac Mortgage Investment Trust
  Form 10-K for the year  ended December 31, 2010
Filed on March 7, 2011 File No. 001-34416

Dear Ms. Anne D. McCallion:
We have reviewed your response letter dated July 21, 2011 and have the following
comments.  In our comments, we may ask you to provide us with information so we may better
understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us why in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.
 FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2010

 Net Investment Income, pages 57 – 59

1. We have reviewed your response to commen ts 3 and 4 and the corresponding proposed
revisions to future filings.   In future filings , with regards to your tabular presentation of
key factors influencing valuation changes, pleas e provide an additional level of detail to
enable a reader to understand inputs used  by management on assets with similar
characteristics instead of providing one ra nge for MBS and mortgage loans in the
aggregate.  In addition, discuss in greater detail the factors that contribut ed to the change
and why these factors support the co rresponding change in key inputs.

Anne D. McCallion
PennyMac Mortgage Investment Trust July 28, 2011 Page 2

 2. We have considered your response to comment  6 and remain unclear how a reader could
assess the effectiveness of your  strategy over the entire holding period of the loan when it
does not take into account cash outflows beyond the original cash outlay upon acquisition
of the loan.   To the extent you plan to in clude this measure in future filings, you should
provide a balanced presentation that quantif ies the expenses or cash outflows along with
cash inflows associated with the settled loans.

Liquidity and Capital Resources, page 65

3. We note your response to comment 11 from our  letter dated July 7, 2011, including your
proposed disclosure.  In future Exchange  Act periodic reports please provide more
detailed disclosure regarding your agreemen ts where a margin call may result from any
decline in the market value of the assets, in cluding any applicable haircut provisions, as
well as your agreements where you may agr ee with the lender upon certain thresholds
(and disclose such thresholds, if applicable and material).

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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.

You may contact Wilson K. Lee at (202) 551-3468 or me at (202) 551-3413 if you have
questions regarding comments on th e financial statements and rela ted matters.  Please contact
Kristina Aberg at (202) 551-3404 or  Angela McHale at (202) 551- 3402 with any other questions.

Sincerely,
  /s/ Cicely LaMothe
        C i c e l y  L a M o t h e          Senior Assistant Chief Accountant