<DOCUMENT>
<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>r77b2.txt
<DESCRIPTION>PUBLIC ACCOUNTING REPORT
<TEXT>
Report of Independent Registered Public Accounting Firm

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


In planning and performing our audit of the financial statements of the
PIMCO Commercial Mortgage Securities Trust, Inc. (the "Fund") as of and
for the year ended December 31, 2006, 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
controls 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 the Fund's internal control over financial reporting as
of December 31, 2006.

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
would not necessarily disclose all deficiencies in internal control over
financial reporting that might be material weaknesses under standards
established by the Public Company Accounting Oversight Board (United
States).  However, during our audits of the financial statement of the Fund as
of and for the year ended December 31, 2006, we noted no deficiencies in
the Fund's internal control over financial reporting, including controls for
safeguarding securities, that we consider to be a material weakness as
defined above as of December 31, 2006.

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.


/s/ PricewaterhouseCoopers LLP
February 22, 2007



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</DOCUMENT>
