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Office of Beverages, Apparel and Mining Division of Corporate Finance Securities and Exchange Commission Ref: Brazil Minerals, Inc. Form 10-K for the Fiscal Year Ended December 31, 2015 Filed April 14, 2016 File No. 000-55191

Dear Mr. Reynolds:

Reference is made to your comment letter, dated October 19, 2016, to Brazil Minerals, Inc. (the "Company") relating to the subject filing (the "Comment Letter"). Set forth below is each comment contained in the Comment Letter, followed by the Company's response thereto:

Form 10-K for the Fiscal Year Ended December 31, 2015

Item 2. Properties, page 16

1.

Please include a map showing the location and access to each material property pursuant to paragraph (b) (2) of Industry Guide 7.

The two sets of maps below will be added to Item 2 - Properties in future 10-K filings indicating the two material properties as of today. Additional maps will be added if the Company obtains any additional material properties.

a)

With respect to Mineração Duas Barras Ltda. ("MDB"):

Mr. John Reynolds

November 2, 2016

Page 2

a.

Map showing location of MDB

Mr. John Reynolds

November 2, 2016

Page 3

b

Map showing details of the gold, diamond, and sand mining concession owned by MDB (mineral right DNPM 806.569/1977):

Mr. John Reynolds

November 2, 2016

Page 4

b)

With respect to RST Recursos Minerais Ltda. ("RST"):

a.

Map showing location of RST

Mr. John Reynolds

November 2, 2016

Page 5

b.

Map showing details of the mineral right owned by RST which has started to be mined for gold and diamonds (mineral right DNPM 802.267/1977)

Mr. John Reynolds

November 2, 2016

Page 6

2.

Please include the expiration date associated with each of your mineral rights.

The table below is updated with the addition of an "Expiration Date" column. The table (updated as necessary) will be included in future 10-K filings.

DNPM Mineral Right Number

Mineral Right Status

Location

Subsidiary

Area of Mineral Right (in acres)

Minerals Currently Requested in Mineral Right Document

Expiration Date of Mineral Right (when applicable)

806.569/1977

MC

JRV

M DB

diamond, gold, sand

n/a (1)

830.797/1982

MC

JRV

RST

diamond, gold

n/a (1)

830.062/1980

MC

JRV

RST

1,177

diamond, gold

n/a (1)

817.734/1968

MC

JRV

RST

5,202

diamond, gold

n/a (1)

807.497/1968

MC

JRV

RST

1,178

diamond, gold

n/a (1)

003.048/1956

MC

JRV

RST

diamond, gold

n/a (1)

003.047/1956

MC

JRV

RST

1,343

diamond, gold

n/a (1)

003.046/1956

MC

JRV

RST

1,039

diamond, gold

n/a (1)

003.045/1956

MC

JRV

RST

1,295

diamond, gold

n/a (1)

003.044/1956

MC

JRV

RST

diamond, gold

n/a (1)

830.749/1981

AMC

JRV

RST

diamond, gold

n/a (2)

830.746/1981

AMC

JRV

RST

diamond, gold

n/a (2)

830.921/1980

AMC

JRV

RST

diamond, gold

n/a (2)

830.919/1980

AMC

JRV

RST

diamond

n/a (2)

804.492/1977

AMC

JRV

RST

diamond, gold

n/a (2)

802.267/1977

AMC

JRV

RST

1,310

diamond, gold

n/a (2)

831.742/1987

AMC

JRV

RST

diamond

n/a (2)

830.998/1984

AMC

JRV

RST

diamond

n/a (2)

880.239/2009

RP

Apui

BMIXP

24,708

gold

n/a (2)

831.380/2014

RP

JRV

BMIXP

1,375

diamond, gold, gravel, sand

10/29/2018

831.398/2014

RP

JRV

BMIXP

diamond, gold, gravel, sand

11/13/2018

832.052/2006

RP

JRV

MDB

diamond, gold

n/a (2)

830.899/2013

RP

JRV

RST

1,443

diamond, gold

10/08/2018

830.898/2013

RP

JRV

RST

diamond, gold

06/10/2018

833.685/2006

RP

JRV

RST

diamond, gold

n/a (2)

832.108/2005

RP

JRV

RST

diamond, gold

n/a (3)

832.059/2014

ARP

JRV

BMIXP

1,152

diamond, gold, gravel, sand

n/a (4)

832.060/2014

ARP

JRV

BMIXP

1,052

diamond, gold, gravel, sand

n/a (4)

832.043/2007

ARP

JRV

BMIXP

diamond

n/a (4)

833.938/2006

ARP

JRV

BMIXP

1,236

diamond, gold

n/a (4)

Mr. John Reynolds

November 2, 2016

Page 7

Table Legend:

Ref: Mineral Right Status

MC: Mining Concession

AMC: Application for Mining Concession

RP: Research Permit

ARP: Application for Research Permit

Ref: Location

JRV: Jequitinhonha River valley, State of Minas Gerais, Brazil

Apui: Apui region, State of Amazonas, Brazil

Ref: Subsidiary

MDB: Mineração Duas Barras Ltda.

RST: RST Recursos Minerais Ltda.

BMIXP: BMIX Participações Ltda.

Ref: Expiration Date of Mineral Right

n/a (1): not applicable; mining concessions are in perpetuity under current law

n/a (2): not applicable; final research report approved by or being reviewed by the mining department

n/a (3): not applicable; in analysis at the mining department

n/a (4): not applicable; awaiting research permit to begin timeline

3.

We note your disclosure on page 16 regarding 4 million ounces of gold and your disclosure on page 25 regarding your forward looking estimates. Only proven and probable reserves and estimates thereof may be disclosed in filings with the United States Securities and Exchange Commission pursuant to paragraph (b) (5) of Industry Guide 7. Please revise to remove these estimates.

We will revise the last paragraph on page 16 to read as follows:

BMIXP holds title to a mineral rights claim for gold covering an area of 9,999.11 hectares, or approximately 24,708 acres, in region of Apui, State of Amazonas in Brazil. This area has had its final report submitted to us in November 2015 to the local mining department, and it was approved. Under Industry Guide 7, there are no proven or probable reserves in said property.

Mr. John Reynolds

November 2, 2016

Page 8

We will revise the first two paragraphs on page 25, and combine them to read as follows:

Our technical team performed calculations as to what can be expected from this new mining area with "white gravel". This area contains "white gravel", well formed, and known from our research drilling to contain diamonds and gold. Lacking for now a precise measure of density of recoverable diamonds and gold per unit of weight of such gravel, our team used the "best" and "worst" known densities from "white gravel" obtained at other areas which we mined within the same geological environment. These density measurements had been obtained from running volumes of such gravel through our diamond and gold recovery plant. Our recovery plant can process 45 cubic meters of gravel per hour, and therefore over a shift of eight hours in one working day it is capable of washing and filtering 360 cubic meters of gravel. Under Industry Guide 7, there are no publishable estimates.

After reviewing these responses, please advise us if you have any further questions or comments on the subject filing.

Very truly yours,
/s/ Marc Fogassa