Mail Stop 4561

      August 18, 2008

Gerald J. Reihsen, III
Executive Vice President and Assistant Secretary
Behringer Harvard Multifamily REIT I, Inc.
15601 Dallas Parkway, Suite 600
Addison, Texas  75001

	Re:	Behringer Harvard Multifamily REIT I, Inc.
		Amendment No. 3 to Registration Statement on Form S-11
		Filed May 9, 2008
		File No. 333-148414

Dear Mr. Reihsen:

      We have reviewed your filing and have the following
comments.
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
additional
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      Please understand that 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.  We 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 Cover Page

1. We have read your responses dated August 4, 2008 and August 8,
2008.   Please expand your risk factor disclosures to discuss your
exposure to Fairfield Residential similar to the information
provided
in your responses.   The disclosure should address the nature of
the
risk and briefly describe the terms and conditions of the
guarantees
provided by Fairfield Residential.   In addition, please quantify
the
amount of the loans related to Fairfield Residential and the
percentage of total assets as of each period end presented within
your filing.

* 	*	 *

      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 supplemental 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 filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy 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 Rules 460 and 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.

      You may contact Wilson Lee at (202) 551-3468 or Linda van
Doorn, at (202) 551-3498 if you have questions regarding comments
on
the financial statements and related matters.  Please contact
Angela
McHale at (202) 551-3402 with any other questions.  If you require
further assistance you may contact me at (202) 551-3852.

      					Sincerely,


      					Michael McTiernan
      					Special Counsel

cc:	Neil Miller, Esq. (via facsimile)
Gerald J. Reihsen, III
Behringer Harvard Multifamily REIT I, Inc.
August 18, 2008
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