Mail Stop 3561

      March 30, 2006


Via U.S. Mail

Jerome B. Van Orman, Jr.
Capital Auto Receivables, Inc.
200 Renaissance Center
Detroit, MI  48265

Re: 	Capital Auto Receivables, Inc.
	Amendment No. 1 to Registration Statement on Form S-3
	Filed March 15, 2006
	File Nos. 333-131476 and 01

Dear Mr. Orman:

      We have limited our review of your filing for compliance
with
Regulation AB.  Please note that our limited review covers only
those
issues addressed in the comments below.  Please also note that our
comments to either the base prospectus and/or the supplement
should be
applied universally, if applicable.

      Where indicated, we think you should revise your document in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so that we can better understand your
disclosure.  After reviewing this information, we may raise
additional
comments.

      The purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to
enhance
the overall disclosure in your filing.  We look forward to working
with you in these respects and welcome any questions you may have
about our comments or on any other aspect of our review.  Feel
free to
call us at the telephone numbers listed at the end of this letter.


Registration Statement on Form S-3
General
1. We note your response to prior comment 4; however, we could not
locate a description of interest rate swaps in the base
prospectus,
outside of a few brief references to the interest rate swap.
Please
revise your base prospectus or advise.

*	*	*	*	*

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Act of 1933
and
that they have provided all information investors require for an
informed investment decision.  Since the company and its
management
are in possession of all the facts relating to a company`s
disclosure,
they are responsible for the accuracy and adequately of the
disclosures they have made.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

      We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting
a request for acceleration.  Please provide this request at least
two
business days in advance of the requested effective date.


	If you have any questions regarding these comments, you may
contact Rolaine Bancroft at (202) 551-3313.  If you need further
assistance, you may contact me at (202) 551-3750.

							Regards,


							Sara W. Dunton
							Senior Attorney



cc:	Via Facsimile (312) 706-8192
	Elizabeth A. Raymond, Esq.
	Mayer, Brown, Rowe & Maw LLP


Jerome B. Van Orman, Jr.
Capital Auto Receivables, Inc.
March 30, 2006
Page 1