<DOCUMENT>
<TYPE>EX-99.77B
<SEQUENCE>3
<FILENAME>r77b.txt
<TEXT>
77B     Accountant's Report on Internal Control

Report of Independent Registered Public Accounting Firm

To the Shareholders and Directors of the
PIMCO Commercial Mortgage Securities Trust, Inc.

In planning and performing our audit of the financial statements
of PIMCO Commercial Mortgage Trust, Inc. (the "Trust") for the
year ended December 31, 2004, we considered its internal control,
including control activities for safeguarding securities, in
order to determine our auditing procedures for the purpose of
expressing our opinion on the financial statements and to comply
with the requirements of Form N-SAR, not to provide assurance on
internal control.

The management of the Trust is responsible for establishing and
maintaining internal control.  In fulfilling this responsibility,
estimates and judgments by management are required to assess the
expected benefits and related costs of controls.  Generally,
controls that are relevant to an audit pertain to the entity's
objective of preparing financial statements for external purposes
that are fairly presented in conformity with generally accepted
accounting principles.  Those controls include the safeguarding
of assets against unauthorized acquisition, use or disposition.

Because of inherent limitations in internal control, errors or
fraud may occur and not be detected.  Also, projection of any
evaluation of internal control to future periods is subject to
the risk that controls may become inadequate because of changes
in conditions or that the effectiveness of their design and
operation may deteriorate.

Our consideration of internal control would not necessarily disclose
all matters in internal control that might be material weaknesses
under standards established by the Public Company Accounting Oversight
Board (United States).  A material weakness, for purposes of this
report, is a condition in which the design or operation of one or
more of the internal control components does not reduce to a
relatively low level the risk that misstatements caused by error
or fraud in amounts that would be material in relation to the
financial statements being audited may occur and not be detected
within a timely period by employees in the normal course of performing
their assigned functions.  However, we noted no matters involving
internal control and its operation, including controls for
safeguarding securities, that we consider to be material weaknesses
as defined above as of December 31, 2004.

This report is intended solely for the information and use of the
Board of Directors, management and the Securities and Exchange
Commission and is not intended to be and should not be used by anyone
other than these specified parties.



February 18, 2005
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