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CORRESP
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CORRESP

 September 27, 2013

Ms. Cicely LaMothe

 Senior Assistant Chief Accountant

United States Securities and Exchange Commission

 100 F Street,
NE

 Washington, D.C. 20549

SUBJECT:
File No. 001-34416

Response to your comment letter

PennyMac Mortgage Investment Trust

Form 10-K for the year ended December 31, 2012, filed on February 28, 2013

Form 10-Q for the quarter ended March 31, 2013, filed May 10, 2013

 Dear Ms. LaMothe:

I am writing in response to your letter dated September 16, 2013 regarding your review of the Annual Report on Form 10-K of PennyMac Mortgage Investment
Trust (the “Company”) for the year ended December 31, 2012 as filed on February 28, 2013.

 Following is our response to your comment.
For ease of review, we have reprinted your comment in bold face followed by our response.

 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 Gain (Loss) on Investments, page 75

1.
We note your response to comment 2 and proposed revisions. As previously requested, please include a discussion of how the information presented should be used in understanding 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.

 Ms. Cicely LaMothe

September 27, 2013

 Page 2
of 4

 In future filings, we will include a discussion similar to the following discussion, which pertains to activity for the periods
ended June 30, 2013 and 2012, (additions in bold face) in response to your comments:

 The following tables present a summary of loan
modifications completed for the periods presented:

Quarter ended June 30,

Six months ended June 30,

2013

2012

2013

2012

 Modification type(1)

Number
of
loans

Balance
of
loans(2)

Number
of
loans

Balance
of
loans(2)

Number
of
loans

Balance
of
loans(2)

Number
of
loans

Balance
of
loans(2)

(dollar amounts in thousands)

 Rate reduction

149

$
32,226

83

$
21,886

272

$
59,131

268

$
70,799

 Term extension

127

28,816

64

16,494

238

51,396

157

40,926

 Capitalization of interest and fees

250

54,442

155

37,204

468

100,627

422

103,259

 Principal forbearance

60

16,157

14

4,527

109

25,088

51

15,570

 Principal reduction

122

28,056

68

17,489

196

48,397

206

51,538

 Total

250

54,442

155

37,204

468

100,627

422

103,259

 Defaults of mortgage loans modified in the prior year period

$
2,796

$
828

$
7,134

$
1,818

 As a percentage of balance of loans before modification

10
%

7
%

9
%

11
%

 Defaults during the period of mortgage loans modified since acquisition(3)

$
11,060

$
3,913

$
20,983

$
5,673

 As a percentage of balance of loans before modification

6
%

5
%

11
%

7
%

 Repayments and sales of mortgage loans modified in the prior year period

$
6,438

$
1,043

$
17,997

$
2,238

 As a percentage of balance of loans before modification

18
%

7
%

18
%

12
%

(1)
Modification type categories are not mutually exclusive, and a modification of a single loan may be counted in multiple categories if applicable. The total number of modifications noted in the table is therefore lower
than the sum of all of the categories.

(2)
Before modification.

(3)
Represents defaults of mortgage loans during the period that have been modified by us at any point since acquisition.

The following table summarizes the average impact of the modifications noted above to the terms of the loans modified for the periods
presented:

Quarter ended June 30,

Six months ended June 30,

2013

2012

2013

2012

 Category

Before
Modification

After
Modification

Before
Modification

After
Modification

Before
Modification

After
Modification

Before
Modification

After
Modification

(Dollar amounts in thousands)

 Loan balance

$
218

$
197

$
240

$
226

$
215

$
197

$
245

$
226

 Remaining term (months)

311

447

306

366

312

445

309

365

 Interest rate

5.89
%

4.18
%

6.35
%

4.29
%

5.93
%

4.17
%

6.56
%

4.04
%

 Forbeared principal

$
—

$
7

$
—

$
4

$
—

$
6

$
—

$
7

 2

 Ms. Cicely LaMothe

September 27, 2013

 Page 3
of 4

 Implementing long-term, sustainable loan modifications is one means by which we strive to enhance the value of the distressed
mortgage loans which we have generally purchased at discounts to their unpaid principal balance. We receive cash on modified loans initially through borrowers’ monthly payments. Subsequently, we may receive cash through repayments of the
modified loans when the borrowers refinance their mortgage or sell the property securing a loan, and through receipt of incentives provided in connection with modification programs sponsored by the U.S. Department of the Treasury. Unlike liquidation
of a defaulted mortgage loan, we expect that recovery of our investment in a performing modified mortgage loan will take place generally over a period of several years, during which we earn and collect interest income on the loan.

Due to the recent addition of new loan modification programs, both through HAMP and proprietary programs, trends in default performance are
difficult to discern. However, the addition of these new modification programs has resulted in the volume of our modification activity increasing in the most recent quarter.

We continue to explore methods of accelerating recovery of our investment in modified mortgage loans through solicitations of refinancings
of such loans into Agency-eligible loans which results in a full or partial repayment of our investment. Modified mortgage loans require a period of acceptable borrower performance, generally 12 months of timely mortgage payments, for consideration
in most Agency refinance programs.

 Generally, borrowers who have recently modified their mortgage loans have credit profiles that
do not qualify them for refinancing or have loans on properties whose loan-to- value ratios exceed current underwriting guidelines for new mortgage loans. Therefore, large-scale refinancing of modified mortgage loans is not expected to occur for an
extended period. However, certain programs such as the FHA’s Negative Equity Refinance Program allow homeowners whose modified mortgage amount exceeds the value of the property securing the loan to refinance immediately following a
modification. Our utilization of this program has increased in 2013, as indicated by the increase in payoffs both on a quarterly and six-month comparative basis.

Before the disruption of the mortgage securitization markets in 2008, an active market in securitizations of reperforming and modified
mortgage loans existed. As a result of the disruptions that occurred in 2008, the market for securities backed by such loans has become illiquid. We continue to monitor and explore the market for securitizations backed by reperforming and modified
mortgage loans as a means of recovering our investment in such loans in the future. However, this form of recovery of our investment in modified mortgage loans has not been a practical alternative for us through this date. Therefore, we

 3

 Ms. Cicely LaMothe

September 27, 2013

 Page 4
of 4

 presently expect that we will receive cash on modified mortgage loans through monthly borrower payments, HAMP incentive payments, payoffs or
acquisition of the property securing the loans and liquidation of the property in the event the borrower subsequently defaults.

 You
may call me at (818) 224-7434 if you require clarification or have additional questions. I can also be reached by U.S. mail or by e-mail at anne.mccallion@pnmac.com.

Sincerely,

/s/ Anne D. McCallion

Anne D. McCallion

Chief Financial Officer

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