September 21, 2022


Division of Corporation Finance

Disclosure Review Program

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549


Re: MSCI Inc.

Definitive Proxy Statement on Schedule 14A Filed April 26, 2022

File No. 001-33812


To Division of Corporation Finance:


We received your comment letter dated September 19, 2022. On behalf of MSCI Inc., I confirm that we will enhance our future proxy disclosures to address the topics discussed in your letter as well as any material developments in our risk oversight structure.




/s/ Robert J. Gutowski


Robert J. Gutowski

General Counsel



Henry A. Fernandez, Chairman and Chief Executive Officer, MSCI Inc.

Cecilia E. Aza, Corporate Secretary, MSCI Inc.

Richard D. Truesdell Jr., Davis Polk & Wardwell LLP