SecProbe.io

May 20, 2009

Mr. Hiroshi Saito
Chief Financial Officer Mitsubishi UFJ Financial Group Inc. 4-1, Marunouchi 2- chome Chiyoda-ku, Tokyo 100-8330 Japan
Re: Mitsubishi UFJ Financial Group Inc.
  Form 20-F for Fiscal Year Ended March 31, 2008   File No. 333-98061-99

Dear Mr. Saito:

We have reviewed your response lett er dated April 6, 2009.  We have the
following additional comments.  Form 20-F for Fiscal Year Ended March 31, 2008

 Notes to Consolidated Financial Statements

 Note 31 – Estimated Fair Value of Financial Instruments, page F-107

 1. We have reviewed your response to prior comment two from our letter dated
March 24, 2009.  Please provide us with the following additional information
regarding your other debt securities.  Consider providing this information in a
tabular format, segregated by the different types of assets backing your other debt
securities:

• The unadjusted non-binding prices recei ved from the pricing vendors/broker-
dealers and ultimately recorded in your financial statements; and
• The quoted prices of securi ties with similar characte ristics as used in your
internal price verification procedures.

2. In addition to our comment above, we note you use quoted market prices of
securities with similar char acteristics to determine fa ir value of your mortgage
backed securities when quoted market prices  are not available.  Please tell us why
you do not also use quoted market prices of securities with sim ilar characteristics
to determine the fair value of your other debt securities.  Explain why you believe
non-binding quotes from pricing vendors/br oker-dealers are more representative
of the fair values of these securities.

Mr. Hiroshi Saito
Mitsubishi UFJ Financial Group, Inc. May 20, 2009 Page 2

3. Please tell us whether your valuation methodology for other debt securities changed upon adoption of FSP FAS 157-3, Determining the Fair Value of a
Financial Asset When the Market For That Asset Is Not Active.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a response letter that keys
your responses to our comments and provides an y requested information.  Detailed letters
greatly facilitate our review.  Please file  your response letter on  EDGAR.  Please
understand that we may have additional comments after reviewing your responses to our comments.
You may contact Sharon M. Blume, A ssistant Chief Accountant, at (202) 551-
3474 or me at (202) 551-3872 if you have questions.

Sincerely,

 Hugh West
        A c c o u n t i n g  B r a n c h  C h i e f