SecProbe.io

August 6, 2013

Via Email
Ms. Anne D. McCallion
Chief Financial  Officer
PennyMac Mortgage Investment Trust
6101 Condor Drive
Moorpark, CA  93021

Re: PennyMac Mortgage Investment Trust
 Form 10-K
Filed February 28, 2013
File No. 001 -34416

Form 10 -Q
Filed May 10, 2013
File No. 001 -34416

Dear Ms. McCallion :

We have reviewed your correspondence dated July 12, 2013 and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing s, 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 circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment s to your filing s and the information you provide in
respons e to these  comments, we may have  additional comments.

Form 10 -K for the year ended December 31, 2012

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 51

Net investment income, page 65

1. We h ave considered your response and proposed revisions to comment 1.   Given the
significance to your net investment income, we continue to believe an overall discussion
regarding the changes to net investment income should include and quantify the material
impact of fair value adjustments.   Currently it is focused on average investment size or

Anne D. McCallion
PennyMac Mortgage Investment Trust
August 6, 2013
Page 2

 increases in your correspondent lending business.   Please confirm you will revise future
periodic reports to further highlight the effect of non -cash fair value adjustme nts in your
periodic results.

Net Gain (Loss) on Investments, page 75

2. We note your response to comment 2 and proposed revisions.  In addition to quantifying
the defaults and repayments of mortgage loans modified in the prior year, please also
quantify de faults and repayments that occurred during the year for all previously
modified mortgages, regardless of when the modification occurred.  In addition, as
previously requested, please include a discussion of how the information presented
should be used in u nderstanding any trends and success rates of your modification
programs and their ability to generate cash flows from your nonperforming loan portfolio
for each period presented.

Cash Flows, page 92

3. We note your response to comment 3 and the intended purpose of the table on page 92.
Please consider disclosing the cost of managing the liquidated assets in the discussion
following the table.

Consolidated Statements of Income, page F -2

4. We note your response to comment 9 and continue to believe that you  should present net
interest income in future periodic filings in accordance with Rule 9 -04 of Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 Kristi Marrone  at (202) 551 -3429 or me at (202) 551 -3413 if you have
questions regarding comments on the financial statements and related matters.

Sincerely,

 /s/ Cicely LaMothe

Cicely LaMothe
Senior Assistant Chief Accountant