October 11, 2018

George H. Haas, IV
Chief Financial Officer
Orchid Island Capital, Inc.
3305 Flamingo Drive
Vero Beach, Florida 32963

       Re: Orchid Island Capital, Inc.
           Form 10-K for the fiscal year ended December 31, 2017
           Filed February 15, 2018
           File No. 001-35236

Dear Mr. Haas:

       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 fiscal year ended December 31, 2017

Note 1. Organization and Significant Accounting Policies
Derivative Financial Instruments, page 83

1.    Please enhance your disclosure in future filings to provide a more robust
discussion of
      TBA securities and "dollar roll income." Your enhanced disclosure should
include the
      following:
        a discussion of why you believe dollar roll income represents the
economic equivalent
          of net interest income generated from investments in agency RMBS.
        an explanation of how you calculate the portion of the gain/loss from
derivative
          instruments that is reflected as TBA dollar roll income.
Note 12. Fair Value , page 97
 George H. Haas, IV
Orchid Island Capital, Inc.
October 11, 2018
Page 2

2.       We note your disclosure that the Company's investments in RMBS,
interest rate swaptions
         and TBA securities are valued using Level 2 valuations, and such
valuations are
         determined by the Company based on independent pricing sources and/or
third party
         broker quotes, when available. In future filings, please revise your
disclosure to describe
         the valuation techniques used by independent pricing sources and/or
third-party pricing
         services to determine the fair value of these securities categorized
within Level 2 of the
         fair value hierarchy. Reference is made to ASC 820-10-50-2(bbb).
       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 Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or
Wilson K.
Lee, Senior Staff Accountant, at (202) 551-3468 with any questions.



                                                              Sincerely,
FirstName LastNameGeorge H. Haas, IV
                                                              Division of
Corporation Finance
Comapany NameOrchid Island Capital, Inc.
                                                              Office of Real
Estate and
October 11, 2018 Page 2                                       Commodities
FirstName LastName