SecProbe.io

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Mail Stop 4561
								September 13, 2005

By U.S. Mail and Facsimile to (425) 468-8230

Michael A. Tembreull
Vice Chairman
Paccar Financial Corp.
777 106th Avenue N.E.
Bellevue, Washington  98004

Re:	Paccar Financial Corp.
	Form 10-K for Fiscal Year Ended December 31, 2004
      Filed March 4, 2005
	File No. 001-11677

Dear Mr. Tembruell:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review 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.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Results of Operations, page 11
1. Please tell us and revise future filings to fully explain the
reasons for changes in each element of your loan loss allowance so
that a reader can understand how changes in risks in the portfolio
during each period relate to the loan loss allowance established
at
period-end.

* Quantify and explain how changes in your estimation methods and
assumptions affected the allowance;

* Quantify and explain how changes in loan and lease
concentrations,
quality, and terms that occurred during the period are reflected
in
your allowance.

* Quantify your gross charge-offs and recoveries for each period
presented and explain why net charge-offs have decreased so
significantly, whether this trend is expected to continue, and how
this affected the determination of your allowance.

Critical Accounting Policies, page 13
2. Please tell us and in future filings revise to include a
complete
description of your accounting policy for the allowance for credit
losses.  Describe your systematic analysis and procedural
discipline,
required by FRR-28, for determining the amount of your allowance
for
losses.  Specifically explain the following:

* how you determine each element of the allowance;

* which contracts are evaluated individually and which contracts
are
evaluated as a group;

* how you determine both the allocated and unallocated portions of
the allowance for losses;

* how you determine the loss factors you apply to your graded
loans
to develop a general allowance; and

* how you consider dealer recourse provisions in determining each
element of your allowance.

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter with your response indicating your intent to provide
the
requested disclosures in future filings.  Please provide us drafts
of
your proposed revisions, where applicable, and any requested
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Margaret Fitzgerald at (202) 551-3556 or me
at
(202) 551-3426 if you have questions regarding comments on the
financial statements and related matters.

      Sincerely,

      Angela Jackson
      Senior Accountant

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Michael A. Tembreull
Paccar Financial Corp.
September 13, 2005
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