TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo February 28, 2022 Ole Jensen Vice President - Finance and Chief Financial Officer BMW FS Securities LLC 300 Chestnut Ridge Road Woodcliff Lake, New Jersey 07677 Re: BMW FS Securities LLC Registration Statement on Form SF-3 Filed February 2, 2022 File No. 333-262471 Dear Mr. Jensen: We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, 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 comments apply 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 these comments, we may have additional comments. Registration Statement on Form SF-3 Form of Prospectus Risk Factors, page 28 1. To the extent that you believe investors in these asset-backed securities may be impacted by climate-related events, including, but not limited to, existing or pending legislation or regulation that relates to climate change, please consider revising your disclosure to describe these risks. See the Commission s Guidance Regarding Disclosure Related to Climate Change, Interpretive Release No. 33-9106 (Feb. 8, 2010). We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Ole Jensen BMW FS Securities LLC February 28, 2022 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Arthur Sandel at 202-551-3262 or Rolaine Bancroft at 202-551- 3313 with any questions. FirstName LastNameOle Jensen Sincerely, Comapany NameBMW FS Securities LLC Division of Corporation Finance February 28, 2022 Page 2 Office of Structured Finance FirstName LastName