SecProbe.io

June 22, 2015

Via E -mail
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 year ended December 31, 2014
Filed March 2, 2015
File No. 1 -34416

Dear Ms. McCallion :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General
1. Please tell us how you complied with Rule 5 -04 of Regulation S -X, or tell us how you
determined it was not necessary to provide a Schedule IV.

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

Liquidity  and Capital Resources, page 84
2. You indicated in a response to the SEC Staff dated July 31, 2014 that in future annual
reports, you would provide the average quarterly balance for your asset repurchase
agreements for each of the past three years, the perio d-end balance for each of those
quarters, and the maximum balance outstanding during each quarter  and explain the
cause and business reasons for material variances of such repurchase agreements.  We are
unable to locate such disclosure; please advise.

Anne D. McCallion
PennyMac Mortgage Investment Trust
June 22, 2015
Page 2

 Contractual Obligations, page 86
3. It does not appear that you include interest expense related to certain debt agreements.  In
future periodic filings, p lease confirm that you will disclose the amount of interest related
to your debt in future filings , or tell  us why such information is not meaningful.  Refer to
footnote 46 of SEC Interpretive Release 33 -8350 dated December 19, 2003.

Consolidated Financial Statements

Note 8 —Fair Value, page F -27

Financial Statement Items Measured at Fair Value on a Recurring  Basis
4. We note that the mortgage loans at fair value consisting of fixed -rate jumbo loans held in
a VIE are categorized as level 2 in the fair value hierarchy.  Please tell us the differences
in the valuation characteristics of these mortgages to those that under lie the remaining
amount of mortgage loans at fair value categorized as level 3.

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 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 mad e.

 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 with 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.

You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at
202.551.3295 with any questions.

Sincerely,

 /s/ Jennifer Monick

Jennifer Monick
Staff Accountant