November 26, 2018

Daniel Draper
Chief Executive Officer and Manager
Invesco DB Multi-Sector Commodity Trust
3500 Lacey Road, Suite 700
Downers Grove, Illinois 60515

       Re: Invesco DB Multi-Sector Commodity Trust
           Registration Statement on Form S-1
           Filed November 15, 2018
           File No. 333-228404

Dear Mr. Draper:

       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 Joshua Lobert, Staff Attorney, at 202-551-7150 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate and
                                                            Commodities