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    Cadwalader, Wickersham & Taft LLP

                           227 West Trade Street, Charlotte, NC 28202

                           Tel +1 704 348 5100 Fax +1 704 348 5200

                           www.cadwalader.com

July 14, 2020

Katherine Hsu

Office Chief

Office of Structured Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Re: LMF Commercial Mortgage Securities, LLC

Registration Statement on Form SF-3

  Filed February 21, 2020

  File No.
333-236566

Dear Ms. Hsu:

We are counsel to
LMF Commercial Mortgage Securities, LLC (the “Registrant”). We have reviewed your letter dated March 19, 2020
(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 registration statement
(File No. 333-236566) on Form SF-3 as initially filed on February 21, 2020. 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 our pre-effective amendment to the registration statement (the “Amendment
No. 1”) submitted herewith.

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

Frank
Polverino   Tel +1 212 504 6820  Fax +1 212 504 6666    frank.polverino@cwt.com

Ms. Katherine Hsu

July 14, 2020

General Comments

1. Please confirm that the depositor or any issuing entity previously established, directly or indirectly, by the depositor
or any affiliate of the depositor have been current with Exchange Act reporting during the last twelve months with respect to asset-backed
securities involving the same asset class. See General Instruction I.A.2. of Form SF-3.

   The Registrant confirms that the depositor
or any issuing entity previously established, directly or indirectly, by the depositor or any affiliate of the depositor has been
current with Exchange Act reporting during the last twelve months with respect to asset-backed securities involving the same asset
class. Neither the Registrant nor any of its affiliates have offered any class of asset-backed securities involving the same asset
class contemplated by Amendment No. 1.

2. Please confirm that all revisions made in the prospectus in response to our comments will be applied to the applicable
transaction documents, as necessary. Please file your revised exhibits in an amendment prior to effectiveness.

   The Registrant confirms that all revisions
made in the prospectus in response to the Staff’s comments were applied to the applicable transaction documents as needed.

3. Please insert the signatures from the majority of the depositor's Board of Managers. See Form SF-3 Item 15. Instruction
1.

   The signatures from the depositor’s
Board of Managers has been added to the Form SF-3.

4. Please review the address for LMF Commercial Securities, LLC throughout the disclosure and the exhibits. Specifically,
in certain documents the address is “700 NW 107th” while in other documents it is “790 NW 107th” (e.g.,
cover page, page 25 of the base prospectus, legal opinion.)

   We have revised the
address throughout the disclosure and the exhibits to conform to the address that is indicated on the cover page of Amendment No.
1.

5. Please define the term “Swap-Priced Principal Balance Certificates” in the disclosure.

   We have revised the prospectus to define
the term “Swap-Priced Principal Balance Certificates” under the section heading “Credit Risk Retention—Material
Terms of the Yield-Priced Certificates”.

Page 2

Ms. Katherine Hsu
 July 14, 2020

6. Please disclose the implications of COVID-19 to the offer and sale of securities you are registering, or advise us why
you concluded that such information is not necessary. For example, consider discussing whether certain commercial property tenants
have been impacted by COVID-19 and the collateral effect that it would have on the ability of property owners to make their mortgage
payments on CMBS assets. As another example, we note that Section 8.02 of the Pooling and Servicing Agreement provides that in
no event shall the Trustee or the Certificate Administrator be liable for any failure or delay in the performance of its obligations
due to force majeure or acts of God, provided that such failure or delay is not also a result of its own negligence, bad faith
or willful misconduct. Please clarify here what you mean by “force majeure” and tell us what consideration you have
given as to whether events relating to COVID-19 would constitute a “force majeure” for purposes of this section and
how that could impact payments to investors. Please also confirm you will provide updated disclosure at the time of any takedown.

   We have revised the prospectus to add
the risk factor “Current Coronavirus Pandemic Has Adversely Affected the Global Economy and Will Likely Adversely Affect
the Performance of the Mortgage Loans” under the section heading “Risk Factors—Risks Related to Market
Conditions and Other External Factors”. This risk factor, as well as any other COVID-19 related disclosures, will be
updated at the time of any takedown.

                                        With respect to the reference to “force
majeure” in Section 8.02 of the Pooling and Servicing Agreement, we believe its meaning is that certain circumstances may
arise beyond the control of the Trustee or the Certificate Administrator, making performance of their obligations commercially
impracticable, illegal or impossible. Stay at home orders due to COVID-19 have been in effect around the country for almost three
months, and we are not aware of any trustee or administrator in asset backed securities transactions that has invoked the force
majeure clause to excuse its performance under such transactions. As a result, we do not believe that COVID-19 would constitute
a “force majeure” for purposes of this section of the Pooling and Servicing Agreement and therefore should not affect
the ability of the Trustee or Certificate Administrator to make required payments to the investors.

7. The disclosure contains several references to LIBOR (e.g., pages 60 and 153). Please consider whether the expected discontinuation
of LIBOR is a principal risk to any security, swap or other financial instrument used in the offering. If you believe it is not,
please explain to us why. Otherwise, please describe how the expected discontinuation of LIBOR could affect the offering including
with respect to certain credit enhancements and Floating Rate Certificates. Additionally, please explain what alternative methods
are contemplated and how the transition to any successor rate could affect the market value and/or liquidity of the financial instruments
that reference LIBOR.

Page 3

Ms. Katherine Hsu
 July 14, 2020

 We have revised the prospectus to add the
risk factor “Changes to, or Elimination of, LIBOR Could Adversely Affect Your Investment in the Certificates”
under the section heading “Risk Factors—Condemnation of a Mortgaged Property May Adversely Affect Distributions
on Certificates”.

Description of the Mortgage Pool –
Whole Loans, page 208

8. Please define the term “Control Notes” and “Non-Control Notes” in the disclosure.

   We have revised the prospectus to define
the terms “Control Notes” and “Non-Control Notes” under the section heading “The Whole Loans—General—
Whole Loan Control Notes and Non-Control Notes”.

Transaction Parties—Depositor,
page 230

9. The disclosure states that this section is: “[TO BE UPDATED].” Please identify which updates would be made
under this section.

   We have revised the prospectus to delete
the reference “[TO BE UPDATED]” under the section heading “Transaction Parties—The Sponsors and the
Mortgage Loan Sellers—The Depositor”.

Book Entry Registration, page 293

10. At the end of the first full paragraph, we note that counsel deleted the sentence that made clear that the limitations
of the paragraph did not apply in particular to rights relating to the asset representations reviewer and the dispute resolutions
provisions. Please revise the disclosure to clarify that all Certificateholders and Certificate Owners will be able to directly
participate in a vote for an asset representations review and dispute resolution.

   We have revised the prospectus to restore
the deleted sentence that made clear that the limitations of the paragraph did not apply in particular to rights relating to the
asset representations reviewer and the dispute resolutions provisions.

Certificateholder Communication—Requests
to Communicate, pages 295-296

11. We note that the disclosure states: “Requesting Investors will be responsible for their own expenses in making
any Communication Request, but will not be required to bear any expenses of the certificate administrator.” Please clarify
that “any expenses the Certificate

Page 4

Ms. Katherine Hsu
 July 14, 2020

 Administrator
                                         incurs in connection with any request to communicate shall be paid by the Trust.”
                                         See Section 5.06(b)(ii) of the Form of Pooling and Servicing Agreement (“PSA”).

   We have revised the prospectus to add clarifying
language from Section 5.06(b)(ii) of the PSA.

Asset Representations Reviewer Compensation,
page 332

12. Please update the section to account for changes made on page 433 of the PSA under section 12.02.

   We have revised the prospectus to account
for changes made on page 433 of the PSA under Section 12.02.

The Asset Representations Reviewer—Asset
Review Trigger, page 383

13. Please supplementally explain the circumstances where the bracketed language beginning with “or (2)(A) prior to
and including the second anniversary” would be used in the disclosure.

   We have revised the prospectus to restore
the language that was included in the Registrant’s SF-3 registration statement from 2017.

The Asset Representations Reviewer—Asset
Review Vote, page 384

14. In the last sentence, the disclosure states: “[Any reasonable out-of-pocket expenses incurred by the certificate
administrator in connection with administering such vote will be paid as an expense of the issuing entity from the Collection Account.]”
We note that the Collection Account is established for the benefit of the Certificateholders (as defined on page 312). We believe
that this sentence would not satisfy the shelf eligibility requirements because it would unduly discourage Certificateholders from
requesting an asset review and make it more onerous for them to utilize the provision. Accordingly, please remove or revise.

   We have revised the prospectus to remove
this bracketed sentence from the disclosure.

The Asset Representations Reviewer—Review
Materials, page 385

15. We note that there is no provision for the delivery of a copy of the Diligence File for each Mortgage Loan that is a
Delinquent Loan in romanette (i). We further note the inclusion of “Diligence Files” in the parenthetical beginning
with “collectively” in the first paragraph.

Page 5

Ms. Katherine Hsu
 July 14, 2020

 Please clarify
                                         whether the asset representations reviewer will have access to the Diligence File(s)
                                         for each mortgage that is delinquent. We also note the first sentence of the second paragraph
                                         on page 387, which states that a Diligence File will be provided to the asset representations
                                         reviewer. Please ensure that your disclosure is consistent throughout.

   Additionally, in romanette (vii)
under the first paragraph, please revise or clarify whether the master servicer or the special servicer will also have access to
and must deliver documents that are in the possession of the custodian or other parties in the event that the asset representations
reviewer requests such documents during its review.

   We have revised the prospectus under the
section headings “Description of the Mortgage Loan Purchase Agreements—General” and “The Asset
Representations Reviewer—Asset Review—Review Materials” to make clear that the Diligence File for each Mortgage
Loan is delivered by posting such Diligence File to the secure data room along with the other Review Materials.

   Additionally, the revisions we have made
under section headings “Description of the Mortgage Loan Purchase Agreements—General” and “The
Asset Representations Reviewer—Asset Review—Review Materials” in the prospectus clarify that the master servicer
or the special servicer will also have access to and must deliver documents that are in the possession of the custodian or other
parties in the event that the asset representations reviewer requests such documents during its review. As such, the asset representations
reviewer will have access to the Diligence File for each Mortgage Loan that is delinquent.

The Asset Representations Reviewer—Review
Materials, page 386

16. In the last sentence of the first paragraph, the disclosure states that the mortgage loan seller is not required to provide
any documents with information “that is proprietary to the related originator or mortgage loan seller.” Additionally,
in the second to last paragraph, it states “the asset representations reviewer will not be permitted to review any information
other than (i) the Review Materials posted in the secure data room, or (ii) Unsolicited Information.” Please discuss both
of these limitations in terms of an asset representations reviewer’s ability to perform its duties in determining noncompliance.
See Instruction I.B.1.(b)(B) of Form SF-3.

   We have revised the prospectus to clarify
the scope of materials the asset representations reviewer may review in the third paragraph under The Asset Representations
Reviewer—Asset Review—Asset Review”.

Page 6

Ms. Katherine Hsu
 July 14, 2020

The Asset Representations Reviewer—Review
Materials, page 386

17. Please reconcile the last paragraph of the disclosure that states “the asset representations reviewer will not
be permitted to review any information other than (i) the Review Materials posted in the secure data room, or (ii) Unsolicited
Information” with the following from the PSA under section 12.01: “The Asset Representations Reviewer shall not
be required to review any information other than (x) the Review Materials or (y) if applicable, Unsolicited Information.”

   We have revised the prospectus so that
the disclosure is consistent with the applicable language in Section 12.01 of the PSA.

The Asset Representations Reviewer—Asset
Review, page 386

18. In the first paragraph, we note that once a Delinquent Loan has been reviewed by the asset reviewer for compliance with
the representations and warranties it will not be reviewed again, even were it to become a Delinquent Loan again. To the extent
that an asset representations review was conducted previously with respect to a Delinquent Loan, we do not object if such loan
is not included in any further asset representations reviews, unless either such loan is the subject of a representation or warranty
as of a date after the completion of the prior asset representations review or the asset representations reviewer has reason to
believe that a prior asset representations review was conducted in a manner that would not have ascertained compliance with a specific
representation or warranty. In the absence of such limitations, we believe this is not a permissible limit on the scope of the
asset representations review under General Instruction I.B.1(b) of Form SF-3. Please revise. Also, refer to Section V.B.3(a)(2)(c)(i)(b)
of the Regulation AB II Adopting Release. Please also revise your transactio