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Mr. George Ohsiek, Jr., Branch Chief                             April 15, 2005
Division of Corporation Finance
Securities Exchange Commission
Washington, D.C. 20549

                    Re: Bernard Chaus, Inc. (the "Company")
                        Form 10-K for the year ended June 30, 2004
                        Filed September 28, 2004

Dear Mr. Ohsiek:

We are in receipt of your letter dated March 22, 2005 with regard to the
Company's Form 10-K for the fiscal year ended June 30, 2004. The following are
our responses to the comments:

Notes To Consolidated Financial Statements

Note 2. Summary of Significant Accounting Policies

Credit Terms, page F-7

1.       We read your response to comment 5. Please tell us how the transferee
         has assumed the full risk of collection, since you do not receive
         payments from the transferee until they receive payments from your
         customers. It appears that you have received a beneficial interest in
         the factored receivables. Also, tell us the timing of when you record
         the sale of the receivables and when you consider the transaction for
         the transfer of the receivables to be complete. See paragraphs 9-12 of
         SFAS 140.

         We believe that the transferee (CIT) has assumed the full risk of
         collection. The factoring agreement with CIT specifically states, "You
         sell and assign to us, and we purchase as absolute owner, all accounts
         arising from your sales of inventory or rendition of services,
         including those under any trade names, through any divisions and
         through any selling agent." The terms of the factoring agreement
         specify payment terms from CIT and we do receive payment from CIT if
         our customers do not pay timely. As defined in the factoring agreement,
         we receive payment from the factor as of the earlier of: a) the date
         that CIT has been paid by the Company's customers; b) the date of the
         customer's longest maturity of the customer's invoices then outstanding
         if the customer is in a bankruptcy or insolvency proceeding; or c) the
         last day of the third month following the customer's longest maturity
         date of the customer's invoices then outstanding if the receivable
         remains unpaid. Therefore, the transferee has assumed the full risk of
         collection and we have not received a beneficial interest in the
         factored receivables.

- 2 -

         We believe that we meet the criteria in paragraph 9 of SFAS 140 to
         treat the factoring arrangement as a sale of receivables: 9a) The
         factored receivables are isolated from the Company. Customers make
         payments on the receivables directly to CIT; 9b) CIT, as transferee,
         has the right to pledge or exchange the assets it received, and no
         condition both constrains the transferee from taking advantage of its
         right to pledge or exchange and provides more than a trivial benefit to
         the Company; and 9c) The Company does not maintain effective control
         over the transferred assets. CIT assumes the credit risk on the
         receivables and CIT is not able to return the receivables to the
         Company.

         In accordance with SFAS 140 paragraphs 9-11, we record the sale of
         receivables upon completion of the transfer of the financial assets
         (receivables), which is subsequent to recording revenue on the sale of
         inventory to customers. At that time, we derecognize the receivables
         sold, recognize all assets obtained and liabilities incurred (if any)
         in consideration as proceeds of the sale, measure at fair value assets
         obtained and liabilities incurred in the sale, and recognize in
         earnings any gain or loss on the sale, including factoring fees or
         charges.

         On a prospective basis, in future periodic filings, we will expand our
         existing disclosures in Note 2 as drafted below.

         Draft Note 2. - Credit Terms:

         Through March 31, 2004, the Company extended credit to the majority of
         its customers through a factoring agreement with The CIT
         Group/Commercial Services, Inc. ("CIT"). Under the factoring
         arrangement, the Company receives payment from CIT as of the earlier
         of: a) the date that CIT has been paid by the Company's customers; b)
         the date of the customer's longest maturity of the customer's invoices
         then outstanding if the customer is in a bankruptcy or insolvency
         proceeding; or c) the last day of the third month following the
         customer's longest maturity date of the customer's invoices then
         outstanding if the receivable remains unpaid. CIT assumes only the risk
         of the Company's customers' insolvency or non-payment. All other
         receivable risks for customer deductions that reduce the customer
         receivable balances are retained by the Company, including, but not
         limited to, allowable customer markdowns, operational chargebacks,
         disputes, discounts, and returns. Effective March 31, 2004, the
         Company, the Company's SL Danielle subsidiary and CIT agreed to
         terminate the Factoring Agreements between them. In connection with the
         termination of those Factoring Agreements, the Company's Cynthia Steffe
         Acquisition subsidiary and CIT entered into an amendment of their
         Factoring Agreement revising only the factoring commission. Receivables
         related to sales of Cynthia Steffe product lines continue to be
         factored. At March 31, 2004, approximately 98% of the Company's
         accounts receivable were being serviced by CIT under the factoring
         arrangement. Effective April 1, 2004 the Company extends credit to its
         customers, other than customers of CS Acquisition based upon an
         evaluation of the customer's financial condition and credit history. At
         June 30, 2004, approximately 95% of the Company's accounts receivable
         was non factored.

                                    * * * * *

                                                 Very truly yours,

                                                 /s/ Barton Heminover

                                                 Barton Heminover
                                                 Chief Financial Officer