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                             June 30, 2021

       R. Lee Phegley, Jr.
       Chief Financial Officer
       Invesco Mortgage Capital Inc.
       1555 Peachtree Street. N.E.,
       Suite 1800
       Atlanta, Georgia 30309

                                                        Re: Invesco Mortgage
Capital Inc.
                                                            Form 10-K for
fiscal year ended December 31, 2020
                                                            Filed February 22,
2021
                                                            File No. 001-34385

       Dear Mr. Phegley:

             We have reviewed your filing 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.

       Form 10-K filed February 22, 2021

       Non-GAAP financial measures, page 43

   1.                                                   Reference is made to
your use of core earnings in the past and resumption within the first
                                                        quarter of 2021.
Included in your calculation of core earnings are adjustments for certain
                                                        realized and unrealized
gains and losses. In light of these adjustments, please tell us how
                                                        you determined it was
appropriate to title this measure as core earnings. Further, our
                                                        understanding is that
this measure is commonly used by mortgage REITs as an indicator
                                                        of dividend paying
ability. Please tell us if this measure is used by your management as
                                                        an indicator of your
dividend paying ability. If so, please revise your filing to disclose
                                                        that purpose.
               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.
 R. Lee Phegley, Jr.
Invesco Mortgage Capital Inc.
June 30, 2021
Page 2

       You may contact Peter McPhun at 202-551-3581 or Wilson Lee at
202-551-3468 if you
have any questions.



FirstName LastNameR. Lee Phegley, Jr.                  Sincerely,
Comapany NameInvesco Mortgage Capital Inc.
                                                       Division of Corporation
Finance
June 30, 2021 Page 2                                   Office of Real Estate &
Construction
FirstName LastName