SecProbe.io

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                                   May 2, 2005

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W., Mail Stop 0409
Washington, D.C. 20549
Attention:  Gregory Dundas

     Re:  CONSUMER PORTFOLIO SERVICES, INC.
          FORM S-2 FILED APRIL 13, 2005
          FILE NO. 333-121913

          FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004 AND RELATED DOCUMENTS
          FILE NO. 1-14116

Dear Mr. Dundas:

On behalf of Consumer Portfolio Services, Inc. we submit this response letter to
the staff's comment letter dated April 26, 2005 addressed to the registrant.

Our responses to the staff's comments in the April 26, 2005 comment letter are
set forth below. To facilitate your review, each comment of the staff has been
set forth below in italics and is followed by our response.

                                    FORM S-2
                                    --------

Forward-looking statements - page 18
------------------------------------

1.   WE NOTE THE REFERENCE TO "ADDITIONAL RISKS" IN THE LAST SENTENCE IN THIS
     SECTION. THIS MAY BE CONFUSING IN LIGHT OF THE STATEMENT IN THE
     INTRODUCTORY PARAGRAPH TO THE RISK FACTOR SECTION THAT THE RISK FACTOR
     SECTION SETS FORTH THE MATERIAL RISKS OF THE COMPANY AND INVESTMENT IN THE
     NOTES. PLEASE REVISE.

     We have removed the reference to "additional risks" in the last sentence of
     this section.

Marketing materials
-------------------

2.   WE NOTE THE DESCRIPTION OF THE COMPANY AS "ONE OF THE NATION'S LEADING
     INDEPENDENT AUTOMOBILE FINANCE COMPANIES." PLEASE TELL US SUPPLEMENTALLY
     THE BASIS FOR THIS STATEMENT OR DELETE IT FROM THE MATERIALS.

<PAGE>

Mr. Gregory Dundas
May 2, 2005
Page 2

     The marketing materials will be revised to describe the Company as "an
     independent automobile finance company" instead of "one of the nation's
     leading independent automobile finance companies."

                 FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004
                 ----------------------------------------------

Note 1- Summary of Significant Accounting Policies
--------------------------------------------------

Finance Receivables, Net of Unearned Income - page F-11
-------------------------------------------------------

3.   WE NOTE YOUR REVISED DISCLOSURES IN RESPONSE TO OUR PRIOR COMMENT 29 WHERE
     YOU STATE THAT THE COMPANY'S PORTFOLIO OF RECEIVABLES IS COMPRISED OF
     SMALLER-BALANCE HOMOGENOUS CONTRACTS THAT ARE COLLECTIVELY EVALUATED FOR
     IMPAIRMENT ON A PORTFOLIO BASIS. SUPPLEMENTALLY TELL US THE CRITERIA YOU
     USE TO DETERMINE WHETHER A RECEIVABLE IS IMPAIRED. FOR EXAMPLE, STATE
     WHETHER YOU USE HISTORICAL STATISTICS, SUCH AS AVERAGE RECOVERY PERIOD AND
     AVERAGE AMOUNT RECOVERED AS A MEANS OF MEASURING IMPAIRMENT OF THOSE LOANS.

     Receivables are deemed impaired upon the earlier of becoming greater than
     90 days contractually delinquent or upon the liquidation of the related
     vehicle. In establishing the adequacy of the loan loss allowance a
     portfolio approach is utilized, which stratifies the finance receivables
     into separately identified pools (commonly referred to as static pools).
     Management examines historical performance and repayment statistics, the
     composition of each static pool, current delinquencies and the value of the
     underlying collateral when evaluating probable credit losses that can be
     reasonably estimated.

4.   WE NOTE YOUR REVISED DISCLOSURE IN RESPONSE TO OUR PRIOR COMMENT 29 WHERE
     YOU STATE THAT FINANCE RECEIVABLES ARE EVALUATED FOR IMPAIRMENT ON A
     PORTFOLIO BASIS. WE ALSO NOTE YOUR DISCLOSURE ON PAGE F-10 OF YOUR 2003
     10-K WHERE YOU STATE THAT FINANCE RECEIVABLES ARE EVALUATED FOR IMPAIRMENT
     ON A LOAN-BY-LOAN BASIS. SUPPLEMENTALLY TELL US WHETHER YOU HAVE CHANGED
     YOUR METHOD OF EVALUATING THESE RECEIVABLES FOR IMPAIRMENT.

     Management's methodology for evaluating receivables for impairment and
     establishing the adequacy of the loan loss allowance has not changed. The
     disclosure was changed in the 2004 10-K to more accurately reflect the
     methodology related to establishing the loan loss allowance.

Contract Acquisition Fees - page F-12
-------------------------------------

5.   WE NOTE YOUR REVISED DISCLOSURES IN RESPONSE TO OUR PRIOR COMMENT 32. AS
     PREVIOUSLY REQUESTED, SUPPLEMENTALLY TELL US HOW YOU CONSIDERED THE
     GUIDANCE IN PARAGRAPHS .13-.18 OF AICPA PRACTICE BULLETIN 6 IN ACCOUNTING
     FOR THESE FEES AT AND SUBSEQUENT TO THE DATE OF ACQUISITION AS THEY RELATE
     TO YOUR LOANS HELD-FOR-INVESTMENT. PARAGRAPHS .13-.18 STATE THE CRITERION
     COMPANIES MUST CONSIDER WHEN DETERMINING WHETHER THE ACCRUAL METHOD (LEVEL
     YIELD) OR THE COST RECOVERY METHOD SHOULD BE USED FOR RECOGNIZING THESE
     FEES INTO INCOME.

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Mr. Gregory Dundas
May 2, 2005
Page 3

     In accordance with AICPA Practice Bulletin 6 ("PB 6") paragraph 13, at the
     time of acquisition, the Company estimates the future undiscounted cash
     collections of the receivables. If this estimate is greater than the
     acquisition amount, the Company amortizes the receivables on a level yield
     basis because the payments of principal and interest are reasonably
     estimable and the ultimate receipt of the acquisition amount of the
     receivables is probable. It should be noted that the majority of the
     Company's receivables are purchased at a discount that ranges from 1-2% of
     the acquisition amount. During the year ended December 31, 2004 the Company
     purchased a portfolio of receivables from SeaWest Financial Corporation at
     a discount of approximately 22%. This entire discount was treated as an
     unaccretable discount at the date of acquisition based on the guidance in
     paragraph 13 of PB 6. In accordance with paragraph 15 of PB 6, the Company
     makes adjustments to the yield on a prospective basis as changes in the
     original cash flow estimates change. These yield adjustments are calculated
     on a quarterly basis.

6.   WE NOTE YOUR RESPONSES TO OUR PRIOR COMMENTS 33 AND 43 WHERE YOU STATE THAT
     THE METHODS YOU USED TO AMORTIZE DEFERRED ACQUISITION FEES AND DEBT
     ISSUANCE COSTS INTO INCOME APPROXIMATED THE LEVEL YIELD METHOD. WE ALSO
     NOTE THAT YOU HAVE QUANTIFIED THE DIFFERENCE BETWEEN THE METHOD USED DURING
     2003 AND THE MORE COMPREHENSIVE LEVEL YIELD METHODOLOGY ADOPTED DURING
     2004. SUPPLEMENTALLY PROVIDE US WITH THE FOLLOWING INFORMATION REGARDING
     THESE FEES:

          o    CLARIFY THE DIFFERENCE BETWEEN THE LEVEL YIELD METHOD THAT
               "APPROXIMATED" THE METHOD USED DURING 2003 AND THE MORE
               COMPREHENSIVE METHODOLOGY ADOPTED DURING 2004.

               The method used in 2003 that "approximated" the level yield
               method was a method management refers to as the depletion method,
               where the acquisition fees were recognized as interest income at
               the same rate as the receivables amortized, including
               prepayments. Similarly for the deferred financing costs, deferred
               financing costs were recognized as interest expense at the same
               rate as the securitization trust debt amortized, including
               prepayments. The "more comprehensive method" adopted in 2004 is
               the level yield method.

          o    AS PREVIOUSLY REQUESTED, QUANTIFY THE DIFFERENCE BETWEEN THE
               LEVEL YIELD METHOD THAT "APPROXIMATED" THE METHOD USED DURING
               2003 AND THE METHOD USED DURING 2003.

               As discussed above, the method used during 2003 was a method
               management refers to as the depletion method, which
               "approximated" the level yield method. As stated in management's
               response letter dated April 13, 2005 to your prior comment 33,
               interest income under the level yield method would have been
               $107,000 higher than under the depletion method. Similarly, with
               respect to your prior comment 43 interest expense under the level
               yield method would have been $96,000 higher than under the
               depletion method. The combined impact on pre-tax income of using
               the level yield method vs. the depletion method would have been
               an increase of $11,000.

<PAGE>

Mr. Gregory Dundas
May 2, 2005
Page 4

          o    CLARIFY HOW YOU CONSIDERED THE GUIDANCE IN PARAGRAPHS 13 OF APB
               20 AS IT RELATES TO THE ADOPTION OF A MORE COMPREHENSIVE LEVEL
               YIELD METHODOLOGY DURING 2004. SINCE YOUR PRIOR METHODOLOGY DID
               NOT COMPLY WITH GAAP, IT WOULD NOT BE APPROPRIATE TO CHARACTERIZE
               THIS CHANGE AS A CHANGE IN ACCOUNTING POLICY BASED ON THE
               GUIDANCE OF APB 20. IF THE AMOUNTS INVOLVED WERE MATERIAL, THEIR
               IMPACT WOULD NEED TO BE REPORTED AS A CORRECTION OF AN ERROR
               BASED ON THE GUIDANCE OF PARAGRAPHS 36-37 OF APB 20.

               Management reviewed the differences for interest income, interest
               expense and pre-tax income as quantified above and concluded that
               for each item such differences were immaterial and that
               accounting for such differences as a correction of an error was
               not deemed necessary under APB 20.

Treatment of Securitizations page F-12
--------------------------------------

7.   WE NOTE YOUR RESPONSE TO OUR PRIOR COMMENT 34. WE ARE UNABLE TO UNDERSTAND
     WHETHER THE MODIFICATIONS APPLIED TO TRUSTS AND AGREEMENTS IN FORCE AT JUNE
     30, 2003, OR WHETHER YOU ONLY CHANGED THE FORM OF NEW TRUSTS AND AGREEMENTS
     AFTER THAT DATE. SUPPLEMENTALLY PROVIDE US WITH THE FOLLOWING INFORMATION
     REGARDING YOUR TERM SECURITIZATIONS:

          o    TELL US HOW THE SECURITIZATION AGREEMENTS RELATED TO TERM
               SECURITIZATION TRANSACTIONS AFTER JUNE 2003 WERE MODIFIED FROM
               THE PREVIOUS FORM USED SO THAT THE RELATED TRUSTS WOULD NO LONGER
               MEET THE DEFINITION OF QSPES.

          o    CLARIFY WHETHER THE TRUSTS RELATED TO TERM SECURITIZATION
               TRANSACTIONS AFTER JUNE 2003 ALSO RELATE TO TERM SECURITIZATION
               TRANSACTIONS PRIOR TO JUNE 2003. IF THESE ARE THE SAME TRUSTS,
               EXPLAIN WHY YOUR ABILITY TO MODIFY YOUR TRUSTS VIA MODIFICATION
               OF THE SECURITIZATION AGREEMENT DID NOT PROHIBIT THEM FROM BEING
               QSPES.

     No changes were made to Trusts in force at June 30, 2003 and none of the
     Trusts created after June 30, 2003 relate to any term securitization
     transaction prior to June 30, 2003. One change made to certain new Trusts
     created after June 30, 2003 so that they would not qualify as QSPEs was to
     give such Trusts the ability to purchase derivative contracts which are
     outside of the scope permitted by paragraph 35c(2) of FAS 140. In addition,
     new provisions were added to the related securitization documents which
     disqualify sale treatment under FAS 140, including giving the servicer of
     the related Trust assets (the Company) the ability to repurchase up to 1%
     of the original principal balance of any receivable sold in the
     transaction. Each of the Trusts created after June 30, 2003 contains the
     repurchase provision described above.

<PAGE>

Mr. Gregory Dundas
May 2, 2005
Page 5

8.   YOUR RESPONSE TO OUR PRIOR COMMENT 36 APPEARS TO ADDRESS YOUR WAREHOUSE
     SECURITIZATION STRUCTURES ONLY. FOR YOUR TERM SECURITIZATION STRUCTURES, AS
     DESCRIBED ON PAGE 24, SUPPLEMENTALLY PROVIDE US WITH THE FOLLOWING
     INFORMATION:

          o    CLARIFY WHETHER YOU RECORDED A GAIN ON SALE OF CONTRACTS WHEN THE
               CONTRACTS WERE TRANSFERRED TO THE SPECIAL PURPOSE SUBSIDIARY OR
               WHEN THE CONTRACTS WERE TRANSFERRED TO THE TRUST.

               Gain on sale was recorded only upon the contracts being
               transferred to the Trust.

          o    IF YOU RECORDED A GAIN ON SALE OF CONTRACTS WHEN THE CONTRACTS
               WERE TRANSFERRED TO THE SPECIAL PURPOSE SUBSIDIARY, EXPLAIN HOW
               YOU CEDED EFFECTIVE CONTROL OVER ASSETS TRANSFERRED TO THE
               SPECIAL PURPOSE SUBSIDIARY.

               As described above, gain on sale was recorded only upon the
               contracts being transferred to the Trust.

          o    CLARIFY WHETHER THE SPECIAL PURPOSE SUBSIDIARY WAS CONSOLIDATED
               UNDER TERM SECURITIZATIONS THAT WERE PREVIOUSLY ACCOUNTED FOR AS
               SALES.

               The special purpose subsidiary has always been consolidated.
               Under the term securitizations that were previously accounted for
               as sales, the assets and liabilities of the Trust held by the
               special purpose subsidiary were not consolidated because, under
               paragraph 46 of FAS 140, the Trusts qualified as QSPEs.

9.   WE NOTE YOUR DISCLOSURE ON PAGE F-12, WHERE YOU STATE THAT FOR
     SECURITIZATION TRANSACTIONS THAT WERE TREATED AS SALES FOR FINANCIAL
     ACCOUNTING PURPOSES, THE COMPANY, OR A WHOLLY-OWNED SUBSIDIARY OF THE
     COMPANY, RETAINS A RESIDUAL INTEREST IN THE CONTRACTS THAT WERE SOLD TO A
     WHOLLY-OWNED, UNCONSOLIDATED SPECIAL PURPOSE SUBSIDIARY. SUPPLEMENTALLY
     TELL US HOW YOU DETERMINED THAT IT WAS NOT APPROPRIATE TO CONSOLIDATE THESE
     WHOLLY-OWNED SPECIAL PURPOSE SUBSIDIARIES, INCLUDING THE ACCOUNTING
     GUIDANCE UPON WHICH YOU RELIED.

     Under paragraph 46 of FAS 140, the assets and liabilities of a Trust that
     is a QSPE are not consolidated.

10.  WE NOTE YOUR RESPONSE TO OUR PRIOR COMMENT 39. SUPPLEMENTALLY TELL US HOW
     THE TRANSFER OF EXCESS CASH FROM ONE SPREAD ACCOUNT TO ANOTHER AFFECTS THE
     CALCULATION OF CASH OUT FOR EACH OF THE SPREAD ACCOUNTS.

<PAGE>

Mr. Gregory Dundas
May 2, 2005
Page 6

     The only term securitization transactions that have these provisions relate
     to non-consolidated Trusts. If excess cash flow from one spread account is
     transferred to another spread account, therefore, the cash out for the two
     individual transactions would change but the aggregate cash out would
     remain unchanged. In addition, such transfer of excess cash flow would
     occur only upon certain triggering events, which are not probable.

                                     * * * *

     We respectfully submit the foregoing for your consideration in response to
your comment letter dated April 26, 2005. If you have any further questions
concerning this filing, please contact me at (214) 659-4425 or Patrick Sargent
at (214) 659-4430.

                                                     Very truly yours,

                                                     /s/ Mark W. Harris

                                                     Mark W. Harris

cc  Sharon Johnson (via EDGAR)

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