April 14, 2020

David Lee
Chief Financial Officer
Motorcar Parts of America, Inc.
2929 California Street
Torrance, CA 90503

       Re: Motorcar Parts of America, Inc.
           Form 10-K for the Fiscal Year Ended March 31, 2019
           Form 8-K filed November 12, 2019
           Response dated March 2, 2020
           File No. 001-33861

Dear Mr. Lee:

        We have reviewed your March 2, 2020 response to our comment letter and
have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
February 5, 2020 letter.

Form 8-K filed November 12, 2019

Exhibit 99.1, page 1

1.    We note your response to prior comment 4 and the information provided to
us in our call
      held on March 13, 2020. To help us fully understand why you believe
certain of the non-
      GAAP adjustments made to arrive at your non-GAAP financial measures are
important to
      an understanding of your results of operations and how they comply with
Item 10(e) of
      Regulation S-K and Regulation G, please address the following:

           Describe to us the nature of cores in your business and provide us
with an example
           depicting the accounting for cores throughout their lifecycle.
           Customer allowances related to new business   please explain to us
how you account
 David Lee
Motorcar Parts of America, Inc.
April 14, 2020
Page 2
              for customer allowances when new business is acquired and why you
believe that
              reversing these allowances recorded at acquisition is useful to
your investors and
              reflective of your ongoing product pricing. Please provide us
with an indication of
              the amount of new business you acquire in a given year. If you
acquire new business
              regularly, tell us why you believe it is appropriate to exclude
the allowances from
              your performance measures.
              Revaluation   cores on customers' shelves   Excluding the
inventory revaluation
              required by GAAP appears to result in tailored accounting. In
detail, please explain
              to us why you believe it is appropriate to exclude the inventory
revaluation included
              in cost of sales.
              New product line start-up and ramp-up costs and transition
expenses   please provide
              us with a list of the amounts included in this adjustment for
each category. Tell us if
              all of these adjustments relate to the expansion of your
operations into Mexico; how
              often you incur these types of costs; and why you do not consider
these to be normal,
              recurring cash operating expenses. We understand that some of the
transition costs
              incurred relate to lease expense, employee training and redundant
costs. Please tell
              us in more detail about the nature of each of these items.


       You may contact Melissa Gilmore at (202) 551-3777 or Martin James,
Senior Advisor, at
(202) 551-3671 with any questions.



FirstName LastNameDavid Lee                                    Sincerely,
Comapany NameMotorcar Parts of America, Inc.
                                                               Division of
Corporation Finance
April 14, 2020 Page 2                                          Office of
Manufacturing
FirstName LastName