TEXT-EXTRACT 2 filename2.txt Mailstop 3628 October 3, 2018 Helaine Kaplan President and Managing Director Deutsche Mortgage & Asset Receiving Corporation 60 Wall Street New York, New York 10005 Re: Deutsche Mortgage & Asset Receiving Corporation Amendment No. 1 to Registration Statement on Form SF-3 Filed September 20, 2018 File No. 333-226943 Dear Ms. Kaplan: We have reviewed your amended registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Form of Prospectus Pooling and Servicing Agreement--The Asset Representations Reviewer--Asset Review--Asset Review Trigger, page 322 1. In discussing the appropriateness of your asset review trigger, you refer to prior pools of commercial mortgage loans for which GACC (or its predecessors) was a sponsor in a public offering of CMBS, and you include a placeholder on page 323 for "the highest percentage of loans that were delinquent at least 60 days at the end of any [reporting period] between January 1, 2010 and [INSERT A DATE NO LATER THAN 135 DAYS OF THE DATE OF FIRST USE OF THE PROSPECTUS]." However, your recent Rule 424 prospectuses (e.g., CD 2018-CD7 Mortgage Trust) instead disclose the highest delinquency rate for reporting periods occurring during the most recent five calendar years. Please confirm that you intend Helaine Kaplan Deutsche Mortgage & Asset Receiving Corporation October 3, 2018 Page 2 to use a fixed start date of January 1, 2010 in your Rule 424 prospectuses going forward, or revise your form of prospectus to reflect the reporting periods for which you intend to disclose the highest delinquency rate. Please contact Michelle Stasny at (202) 551-3674 or me at (202) 551-3313 with any questions. Sincerely, /s/ Rolaine S. Bancroft Rolaine S. Bancroft Senior Special Counsel Office of Structured Finance