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                             March 11, 2022

       Richard Simpson
       President
       Citigroup Commercial Mortgage Securities Inc.
       390 Greenwich Street
       New York, New York 10013

                                                        Re: Citigroup
Commercial Mortgage Securities Inc.
                                                            Registration
Statement on Form SF-3
                                                            Filed February 14,
2022
                                                            File No. 333-262701

       Dear Mr. Simpson:

              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

       General

   1.                                                   We note your use of
LIBOR-based disclosure throughout the form of prospectus when
                                                        discussing interest
rates for floating-rate notes and swap contracts. In light of the
                                                        forthcoming cessation
of all remaining LIBOR indices, please explain to us whether you
                                                        intend to use LIBOR as
a basis for any floating-rate notes or swap contracts and why this
                                                        is appropriate. If you
do not to intend to use LIBOR as a benchmark, please revise your
                                                        disclosure throughout
the prospectus either to identify the benchmark index you plan to
                                                        use, if known, or to
provide appropriate placeholders for a generic benchmark other than
                                                        LIBOR. Please also
include any appropriate risk factors regarding the use of a new
                                                        benchmark and any other
relevant risk factors related to LIBOR transition efforts. See,
                                                        generally, Staff
Statement on LIBOR Transition   Key Considerations for Market
 Richard Simpson
Citigroup Commercial Mortgage Securities Inc.
March 11, 2022
Page 2
      Participants (Dec. 7, 2021).
Form of Prospectus
Risk Factors, page 58

2.    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 specific risks. See the Commission   s Guidance Regarding
Disclosure
      Related to Climate Change, Interpretive Release No. 33-9106 (Feb. 8,
2010).
U.S. Credit Risk Retention
Qualifying CRE Loans, page 257

3.    Your disclosure refers to certain credit risk retention requirements
under "Regulation RR
      of the Securities Act." Please revise your disclosure here and elsewhere
in the form of
      prospectus to reflect that Regulation RR is promulgated under the
Securities Exchange
      Act.
4.    The disclosure in this section appears duplicative of the section also
entitled "Qualifying
      CRE Loans" beginning on page 269. Please revise to delete one of the
sections, as
      applicable.
Part II - Information Not Required in Prospectus
Item 14. Exhibits, page II-4

5.    Please file your remaining exhibits with your next amendment. Refer to
Item 1100(f) of
      Regulation AB and Instruction 1 to Item 601 of Regulation S-K.
        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.

       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 if
you have any questions.



FirstName LastNameRichard Simpson                   Sincerely,
Comapany NameCitigroup Commercial Mortgage Securities Inc.
                                                    Division of Corporation
Finance
March 11, 2022 Page 2
FirstName LastName
                                                    Office of Structured
Finance