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
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