March 20, 2019

Glenn A. Votek
Chief Financial Officer
Annaly Capital Management, Inc.
1211 Avenue Of The Americas
New York, New York 10036

       Re: Annaly Capital Management, Inc.
           Form 10-K for the fiscal year ended December 31, 2018
           Filed February 19, 2019
           File No. 001-13447

Dear Mr. Votek:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2018

Item 7. Management's Discussion and Analysis
Non-GAAP Financial Measures, page 55

1.    We note that beginning with the three months ended March 31, 2018 you
revised your
      calculation of economic interest expense and economic net interest income
(excluding
      PAA) to reflect the net interest component of all interest rate swaps. It
appears that this
      change was caused by changes to your hedging portfolio. Please tell us
how your hedging
      portfolio has changed and explain why these changes resulted in the
change to your
      calculation of economic interest expense and economic net interest income
(excluding
      PAA).
Note 10. Derivative Instruments, page F-24

2.    Please tell us whether you have entered into any market agreed coupon
("MAC") interest
      rate swaps. To the extent you have entered into MAC interest rate swaps,
please quantify
 Glenn A. Votek
Annaly Capital Management, Inc.
March 20, 2019
Page 2
         your exposure and clarify how you are accounting for such swaps. Your
response should
         quantify total current notional separated by tiers of maturity,
amounts paid/received to
         compensate for the off-market nature of such interest rate swaps and
your accounting
         treatment should be supported by the GAAP accounting literature relied
upon.
       In closing, 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.

       You may contact Wilson K. Lee, Senior Staff Accountant, at (202) 551 -
3468 or Robert
F. Telewicz, Accounting Branch Chief, at (202) 551 - 3438 with any questions.



                                                             Sincerely,
FirstName LastNameGlenn A. Votek
                                                             Division of
Corporation Finance
Comapany NameAnnaly Capital Management, Inc.
                                                             Office of Real
Estate and
March 20, 2019 Page 2                                        Commodities
FirstName LastName