EX-99.77B ACCT LTTR 2 r77b.htm

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 audits of the financial statements of the
PIMCO Commercial Mortgage Securities, Inc.  (the "Fund") as of and for
the year ended December 31, 2005, in accordance with the standards of the
Public Company Accounting Oversight Board (United States), we considered the
Fund's internal control over financial reporting, including control
activities for safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the financial
statements and to comply with the requirements of Form N-SAR, but not for the
purpose of expressing an opinion on the effectiveness of the Fund's internal
control over financial reporting. Accordingly, we express no such opinion.

The management of the Fund is responsible for establishing and maintaining
internal control over financial reporting. In fulfilling this responsibility,
estimates and judgments by management are required to assess the expected
benefits and related costs of controls. A company's internal control over
financial reporting is a process designed to provide reasonable assurance
regarding the reliability of financial reporting and the preparation of
financial statements for external purposes in accordance with generally
accepted accounting principles. Such internal control over financial reporting
includes policies and procedures that provide reasonable assurance regarding
prevention or timely detection of unauthorized acquisition, use or
disposition of a company's assets that could have a material effect on the
financial statements.

Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also, projections of any
evaluation of effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in conditions, or that the
degree of compliance with the policies or procedures may deteriorate.

A control deficiency exists when the design or operation of a control does
not allow management or employees, in the normal course of performing their
assigned functions, to prevent or detect misstatements on a timely basis. A
significant deficiency is a control deficiency, or combination of control
deficiencies, that adversely affects the company's ability to initiate,
authorize, record, process or report external financial data reliably in
accordance with generally accepted accounting principles such that there
is more than a remote likelihood that a misstatement of the company's annual
or interim financial statements that is more than inconsequential will not be
prevented or detected. A material weakness is a control deficiency, or
combination of control deficiencies, that results in more than a remote
likelihood that a material misstatement of the annual or interim financial
statements will not be prevented or detected.

Our consideration of the Fund's internal control over financial reporting
was for the limited purpose described in the first paragraph and would not
necessarily disclose all deficiencies in internal control over financial
reporting that might be significant deficiencies or material weaknesses
under standards established by the Public Company Accounting Oversight Board
(United States).  However, we noted no deficiencies in the Fund's internal
control over financial reporting and its operation, including controls for
safeguarding securities, that we consider to be material weaknesses as
defined above as of December 31, 2005.

This report is intended solely for the information and use of management
and the Directors of the PIMCO Commercial Mortgage Securities Trust, Inc.
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 17, 2006