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    Cadwalader, Wickersham & Taft LLP

                           200 Liberty Street, New York, NY 10281

                           Tel +1 212 504 6000 Fax +1 212 504 6666

                           www.cadwalader.com

March 7, 2024

Rolaine Bancroft

Office Chief

Office of Structured Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

 Re: Barclays
                                            Commercial Mortgage Securities LLC

                                            Amendment No. 1 to Registration Statement on Form SF-3

                                            Filed February 2, 2024

                                            File No. 333-276033

Dear Ms. Bancroft:

We are counsel to Barclays
Commercial Mortgage Securities LLC (the “Registrant”). We have reviewed your letter dated February 16, 2024 (the “Comment
Letter”) transmitting comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities
and Exchange Commission (the “Commission”) to the Registrant’s amendment to the registration statement (File
No. 333-276033) on Form SF-3 as filed on February 2, 2024 (the “Registration Statement”). We have also discussed the
comments contained in the Comment Letter with various representatives of the Registrant. Capitalized terms used herein without definition
have the meanings given them in the form of prospectus contained in the Registration Statement.

For your convenience, the
Staff’s comments are repeated in italics below, followed by the Registrant’s responses.

Amendment No. 1 to Registration Statement on Form SF-3 filed
February 2, 2024

General

 1. We note your response to prior comment 1 and reissue in part. Specifically, we note your statement that "[n]o affiliate
of the Registrant has offered a class of asset-backed securities involving the same asset class as this offering." Records indicate,
however, that Barclays Commercial Mortgage Securities LLC, as depositor, has conducted numerous offerings of asset-backed securities involving
commercial mortgage loans through affiliated issuing entities including, as examples only, recent registered offerings issued through
the following issuing entities: BBCMS Mortgage Trust 2024-C24, BBCMS Mortgage Trust 2023-5C23,

  Robert
                               Kim   Tel +1 212 504 6258   Fax +1 212 504 6666   robert.kim@cwt.com

Rolaine Bancroft, Esq.

March 7, 2024

  and BBCMS Mortgage Trust 2023-C22. Accordingly,
                                            please provide us with the CIK for these and any other affiliate of the depositor, including
                                            issuing entities, that have offered a class of asset-backed securities involving the same
                                            asset class as this offering.

The names and CIKs for each of the issuing entities
formed by the Registrant in connection with an offering of the same asset class made pursuant to a registration statement filed by the
Registrant (the “Issuing Entities”) are listed in the table below.

To clarify its response in its previous letter
dated February 2, 2024, the Registrant did not identify these Issuing Entities as “affiliates” of the Registrant because the
Registrant does not view them as falling within the definition of “affiliates” under Rule 4051
as the Issuing Entities do not control, or not are controlled by, and are not under common with the Registrant. Although each of the Issuing
Entities is a New York common law trust (a “Trust”) formed pursuant to a pooling and servicing agreement (“Pooling
and Servicing Agreement”) entered into by the Registrant and other parties thereto in connection with a securitization transaction,
once the Issuing Entity is formed and closing of the securitization transaction occurs, the servicing of the Trust assets is performed
by servicers appointed pursuant to the Pooling and Servicing Agreement, and it is the requisite percentages of the holders of the pass-through
trust certificates issued in connection with the securitization transaction (the “Certificates”), rather than the Registrant,
that have the power to direct various actions of the Trust. Typically, neither the Registrant nor its affiliates hold more than 5% of
the certificate balance of the Certificates (for purposes of complying with the credit risk retention rules), which ownership percentage
is insufficient to bestow upon the Registrant control rights over the Trust2.

Notwithstanding the foregoing, Form SF-3 conditions
shelf eligibility on the satisfaction of the Exchange Act reporting requirements by “the depositor or any issuing entity previously
established, directly or indirectly, by the depositor [emphasis added] or any affiliate of the depositor”, regardless of affiliation
status of the individual issuing entities, and the Registrant’s response in the previous letter with respect to “each relevant
entity” being in compliance with Exchange Act reporting referred to the reporting status both of itself and each Issuing Entity
formed by the depositor in connection with an offering made pursuant to a registration statement filed by the Registrant. Outside of the
Issuing Entities, the Registrant confirms that no affiliate of the Registrant has offered a class of asset-backed securities involving
the same class covered by the Registration Statement.

1
Under Rule 405, “an affiliate of, or person affiliated with, a specified person, is a person that directly, or indirectly
through one or more intermediaries, controls or is controlled by, or is under common control with, the person specified.”

2
A registered broker-dealer affiliate of the Registrant may also temporarily hold additional Certificates from time to time in connection
with secondary market-making activity.

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Rolaine Bancroft, Esq.

March 7, 2024

no affiliate of the Registrant has offered a class
of asset-backed securities involving the same class covered by the Registration Statement.

Names and CIKs of Issuing
Entities

    Issuing
    Entity Name3

    CIK

    BBCMS Mortgage Trust 2017-C1

    0001696707

    BBCMS Mortgage Trust 2018-C2

    0001754913

    BBCMS Mortgage Trust 2019-C3

    0001772527

    BBCMS Mortgage Trust 2019-C4

    0001780131

    BBCMS Mortgage Trust 2019-C5

    0001790441

    BBCMS Mortgage Trust 2020-C6

    0001797679

    BBCMS Mortgage Trust 2020-C7

    0001812604

    BBCMS Mortgage Trust 2020-C8

    0001823722

    BBCMS Mortgage Trust 2021-C9

    0001843823

    BBCMS Mortgage Trust 2021-C10

    0001864196

    BBCMS Mortgage Trust 2021-C11

    0001881326

    BBCMS Mortgage Trust 2021-C12

    0001891818

    BBCMS Mortgage Trust 2022-C14

    0001901814

    BBCMS Mortgage Trust 2022-C15

    0001913593

    BBCMS Mortgage Trust 2022-C16

    0001924780

    BBCMS Mortgage Trust 2022-C17

    0001937985

    BBCMS Mortgage Trust 2022-C18

    0001950140

    BBCMS Mortgage Trust 2023-C19

    0001966434

    BBCMS Mortgage Trust 2023-C20

    00019817694

    BBCMS Mortgage Trust 2023-C21

    0001985684

    BBCMS Mortgage Trust 2023-C22

    0001994342

    BBCMS Mortgage Trust 2023-5C23

    0001998392

    BBCMS Mortgage Trust 2024-C24

    0002006370

Part II - Information Not Required in Prospectus

Item 14. Exhibits, page II-2

      2. We note counsel's legal opinion, filed as Exhibit 5.1, is limited to the laws of the State of New York and to the federal laws
of the United States. Please have counsel revise

3
Securitization trusts for which all public securities have been repaid and reporting obligations have been suspended are excluded.

4
A non-ABS CIK (0001979849) was inadvertently obtained and a report on Form ABS-15G was filed under that CIK. The CIK listed above (0001981769)
is the ABS CIK used for all other filings for the BBCMS Mortgage Trust 2023-C20 transaction, and the Registrant has been in contact with
EDGAR Filer Support requesting the consolidation of the filings under the ABS CIK.

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Rolaine Bancroft, Esq.

March 7, 2024

       the legal opinion or provide a
                                            separate legal opinion with respect to the laws of the State of Delaware, as counsel must
                                            consider the law of the jurisdiction under which each registrant is organized, including
                                            the depositor, which is a Delaware corporation, in order to provide the opinions with respect
                                            to the certificates. Refer to Sections II.B.1.b., II.B.1.e., and II.B.3.b. of the Division
                                            of Corporation Finance Staff Legal Bulletin No. 19 ("Legality and Tax Opinions in Registered
                                            Offerings").

Item 601(b)(5) of Regulation S-K describes the applicable opinion
required as follows: “An opinion of counsel as to the legality of the securities being registered, indicating whether they will,
when sold, be legally issued, fully paid and non-assessable, and, if debt securities, whether they will be binding obligations of the
registrant.”

The securities to be issued under the Registration Statement are
pass-through trust certificates (“Certificates”) that will be issued by a Trust created under a Pooling and Servicing
Agreement to be entered into, at the time a particular series of Certificates is issued, by the Registrant, as depositor, one or more
servicers, a trustee and certain other parties. The Trust will be the “issuing entity” within the meaning of Regulation AB
for that particular series of Certificates, and the trustee for that particular series of Certificates will execute, authenticate and
deliver the Certificates on behalf of the Trust. The authorization for the issuance of the Certificates, the terms and conditions applicable
to the Certificates, and the benefits afforded to the holders of the Certificates will all be governed by the terms of the Pooling and
Servicing Agreement, which is a New York law governed agreement.

In light of the foregoing, we believe the questions that are required
to be addressed by the opinion of counsel required by Item 601(b)(5) of Regulation S-K are (1) whether the Certificates will be legally
issued by the Trust, and (2) whether the terms and conditions provided in the Pooling and Servicing Agreement provide that the
Certificates will be fully paid and non-assessable, both of which are questions of New York law, notwithstanding that the Registrant,
who will be a party to the Pooling and Servicing Agreement as the depositor, is organized in the State of Delaware. Since the Certificates
are not issued by the Registrant and are not “obligations of the Registrant”, the law of the jurisdiction of the Registrant’s
organization is not implicated by Item 601(b)(5) of Regulation S-K5.
Accordingly, we do not believe that an opinion as to Delaware law is applicable in this context, and it is unclear to us what such an
opinion would address.

5
We note the Staff’s reference to Sections II.B.1.b., II.B.1.e., and II.B.3.b. of the Division of Corporation Finance Staff Legal
Bulletin No. 19. The Registrant believes, however, in the particular context of the Certificates to be issued pursuant to the Registration
Statement, references to the “registrant” made in such sections should be read to refer instead to the Trust.

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Rolaine Bancroft, Esq.

March 7, 2024

If you have any questions concerning the foregoing, please contact the
undersigned.

    Very truly yours,

    /s/ Robert Kim

    Robert Kim

cc: Daniel Vinson

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