September 28, 2018 George Kok President Morgan Stanley Capital I Inc. 1585 Broadway New York, NY 10036 Re: Morgan Stanley Capital I Inc. Registration Statement on Form SF-3 Filed September 20, 2018 File No. 333-227446 Dear Mr. Kok: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Lulu Cheng at 202-551-3811 or me at 202-551-3850 with any questions. Sincerely, /s/ Katherine Hsu Katherine Hsu Office Chief Office of Structured Finance cc: Kevin C. Blauch, Sidley Austin LLP Jonathan Nunes, Sidley Austin LLP