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                             December 16, 2020

       Apostolos Zafolias
       Chief Financial Officer
       Genco Shipping & Trading Ltd.
       299 Park Avenue
       New York , NY 10171

                                                        Re: Genco Shipping &
Trading Ltd.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2019
                                                            Filed February 27,
2020
                                                            File No. 001-33393

       Dear Mr. Zafolias:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year ended December 31, 2019

       Item 7. Management   s Discussion and Analysis of Financial Condition
and Results of
       Operations , page 50

   1.                                                   We note that you have
various disclosures differentiating between major and minor bulk
                                                        commodities and major
and minor bulk vessels. For example, your disclosure on page 31
                                                        indicates that your
minor bulk fleet requires the use of low sulfur fuel, which you explain
                                                        is more expensive than
the fuel utilized by your Capesize vessels; and on page 9 you state
                                                        that your business
"fluctuates in line with the main patterns of trade of the major drybulk
                                                        cargoes and varies
according to changes in the supply and demand for these items."

                                                        We also note disclosure
in your interim report for the quarter ended September 30, 2020,
                                                        explaining that a
primary reason for the overall decrease in revenues for the cumulative
                                                        period, in addition to
having fewer vessels operating, relates to a decrease in revenues
                                                        earned by your minor
bulk vessels, partially offset by an increase in revenue earned by
 Apostolos Zafolias
Genco Shipping & Trading Ltd.
December 16, 2020
Page 2
      your Capesize vessels.

      We see various presentations on your website which include listings of
vessels in each of
      the major and minor vessel categories and a percentage breakdown of
commodities
      carried during 2019. We understand from these presentations, and we
surmise from your
      disclosures, that the Capesize vessels represent your major bulk vessel
category and all of
      the other ships comprise your minor bulk vessel category.

      Please expand the disclosures in your periodic filings to include
comparable details, as
      referenced from your presentations, reflecting your definitions of minor
and major bulk
      vessels, and minor and major bulk products, along with details of revenue
earned from i)
      minor bulk vessels and ii)major bulk vessels for each of the periods
presented, so that a
      reader can better understand the trends from these revenue streams.

      Please also include a description of the twelve groups of sister ships
mentioned on your
      website and clarify whether the major and minor vessel types are limited
to carrying the
      major and minor categories of commodities, respectively, that are
shipped, or if this is not
      the case, describe the extent to which your major vessels carry minor
commodities and
      your minor vessels carry major commodities.
       In closing, 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.

      You may contact John Cannarella, Staff Accountant, at 202-551-3337 or
Karl Hiller,
Branch Chief, at 202-551-3686 with any questions.



                                                            Sincerely,
FirstName LastNameApostolos Zafolias
                                                            Division of
Corporation Finance
Comapany NameGenco Shipping & Trading Ltd.
                                                            Office of Energy &
Transportation
December 16, 2020 Page 2
cc:       Kathy Luther
FirstName LastName