United States securities and exchange commission logo





                            May 26, 2021

       Anna Paglia
       Chief Executive Officer
       Invesco DB Multi-Sector Commodity Trust
       Invesco DB Base Metals Fund
       3500 Lacey Road, Suite 700
       Downers Grove, Illinois 60515

                                                        Re: Invesco DB
Multi-Sector Commodity Trust
                                                            Invesco DB Base
Metals Fund
                                                            Registration
Statement on Form S-3
                                                            Filed May 21, 2021
                                                            File No. 333-256371

       Dear Ms. Paglia:

              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 Julia
Griffith at 202-551-3267 with any questions.




                            Sincerely,


                            Division of Corporation Finance

                            Office of Finance