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<TYPE>EX-99.77D
<SEQUENCE>3
<FILENAME>r77d.txt
<TEXT>
77D     Policies with respect to security investment

                     Change of Investment Policies

The Fund's Board of Directors approved modifications to the PIMCO Commercial
Mortgage Securities Trust, Inc.'s (the "Fund") investment policies as a
result of a new rule promulgated by the Securities and Exchange Commission
("Commission").  The Commission adopted new Rule 35d-1 under the Investment
Company Act of 1940, as amended (the "Names Rule"), generally requiring a
fund with a name suggesting a focus in a particular type of investment to
invest under normal circumstances, at least 80% of its net assets (plus the
amount of any borrowings for investment purposes), in the type of investment
suggested by its name.  As a result, effective July 31, 2002, the Board of
Directors of the Fund adopted a non-fundamental policy to invest, under
normal circumstances, at least 80% of its net assets, plus the amounts of
any borrowings for investment purposes, in commercial mortgage-backed
securities.  Prior to the change, the Fund was subject to a similar
requirement with regard to 65% of its total assets.  Pacific Investment
Management Company LLC, the Fund's investment adviser, does not believe
that the new policy will result in any changes in the way the Fund is
currently managed.

This investment policy may be changed in the future by the Fund's Board of
Directors without shareholder approval.  The Fund will provide shareholders
with at least 60 days' prior notice of any change to this investment policy.

In addition, the Fund changed its investment policies:  (i) to eliminate
the requirement that liquid assets segregated to meet asset coverage
requirements be "high grade debt obligations rated A or better"; and (ii)
to permit the Fund to invest in futures and related options for other than
bona-fide hedging purposes, provided that, immediately after such an
investment, the aggregate initial margin deposits plus premiums paid for
open futures options positions, less the amount by which any such options
are "in the money," does not exceed 5% of the Fund's net assets.  These
changes were designed to reflect, among other things, changes in regulatory
requirements since the Fund's launch in 1993.

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</DOCUMENT>
