SecProbe.io

July 17, 2014

Via E -Mail
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 for the Fiscal Ye ar Ended December  31, 20 13
Filed February 28, 2014
File No. 001-34416

Dear M s. McCallion :

We have reviewed your filing an d 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, 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
circumstance s or do not believe an amendment is appropriate, please tell us why in your
response.

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

Form 10 -K for the Fiscal Year Ended December 31, 2013 filed February 28, 2014

Liquidity and Capital Resources, page 87

1. We note that you disclosed your leverage ratio in your 2013 Q4 earnings call.   To
the extent used by management, please disclose your leverage coverage r atio in
future Exchange Act periodic filings.

2. We note your quantification of the average balance outstanding and maximum
daily amount outstanding for repurchase agreements on an annualized basis here
and in the notes to the financial statements.  Please e xpand your disclosure in
future filings to quantify the average quarterly balance for each category of
repurchase agreement for each of the past three years.  In addition, quantify the

Ms. Anne D. McCallion
PennyMac Mortgage Investment Trust
July 17, 2014
Page 2

 period end balance for each of those quarters and the maximum balance a t any
month -end.  Explain the causes and business reasons for significant variances
among these amounts.

Consolidated Balance Sheets, page F -1

3. We note that you separately present the assets and liabilities held by your
consolidated variable interest enti ty on the balance sheet.  In future filings, please
recast your balance sheet to present the consolidated totals for each line item
required by Rule 5 -02 of Regulation S -X.  Please note that you may state
parenthetically after each line item the amount tha t relates to consolidated VIEs,
or you may include a table following the consolidated balance sheets to present
assets and liabilities of consolidated VIEs that have been included in the
preceding balance sheet.

Consolidated Statements of Income, page F -2

4. To the extent that Other expenses remains material to the income statement,
please consider disaggregating its components on the face of the statement or in a
note to the financial statements.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require.   Since the compa ny
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.

 In responding to our comments, please provide a written statement  from the
company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action w ith respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.

Ms. Anne D. McCallion
PennyMac Mortgage Investment Trust
July 17, 2014
Page 3

 You may contact Jorge L. Bonilla , Staff Accountant,  at (202) 551 -3414 or me at
(202) 551 -3429 if you have questions regarding comments on the financial statements
and related matters.  Please contact  Sandra Hunter , Attorney -Advisor , at (202) 551 -3758
or Thomas Kluck , Branch Chief , at (202) 551 -3233 with any other questions.

                                                                                    Sincerely,

        /s/ Kristi Marrone

Kristi Marrone
                                                                         Staff Accountant