SecProbe.io

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      March 25, 2005

Mail Stop 0408

By U.S. Mail and facsimile to (305) 231-6660.

Humberto L. Lopez
Chief Financial Officer
BankUnited Financial Corporation
255 Alhambra Circle
Coral Gables, FL 33314

Re: BankUnited Financial Corporation
Form 10-K for the Year Ended September 30, 2004
Forms 10-Q for the fiscal year 2005
File Number 001-13921

Dear Mr. Lopez,

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
document
in future filings 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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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.

Form 10-K

Management`s Discussion and Analysis

General

1. Please revise throughout the document to clarify the nature of
the
activity that you currently refer to as securitizations.  It
appears
that you merely sell whole loans and that the purchaser sells the
loans into securitization trusts.  If that is the case, than the
purchaser of your loans is the transferor under SFAS 140 and is
the
party that securitizes the loans.  It appears that you choose to
receive MBS`s in exchange for the loans instead of cash.  Also, if
you are not the transferor to the securitization trusts under SFAS
140, the MBS`s are merely SFAS 115 securities and not retained
interests as your currently refer to them.

2. Please revise your discussion of non-interest income to clarify
how the recognition of mortgage servicing rights resulted in gains
in
each of the periods presented.

Liquidity and Capital Resources - page 21

3. Please revise your liquidity discussion to include the
following:
* Disclose the amount of FHLB borrowings obtained through the
convertible advances program and the "knockout" advance program so
investors will know how much of your debt is potentially callable.
* Disclose the agreed upon threshold rate at which the "knockout"
advances become callable.

Comparison of Operating Results for the Fiscal Years Ended
September
30, 2004 and 2003

Net Interest Income - page 31

4. Please exclude loans held for sale in all Industry Guide 3
disclosures, which are intended to reflect portfolio loans.  Also,
please include the fixed and variable interest rate information
required by Item III.B of Industry Guide 3.

Consolidated Financial Statements

General

5. Please revise to include the disclosure requirements of
paragraph
17(e) for your servicing assets.  Supplementally provide us drafts
of
your proposed changes.

Form 10-Q

6. Please supplementally tell us, and revise to provide similar
disclosures, how the acceleration of the vesting period for the
options granted to the CEO and COO did not meet the criteria for
variable accounting under FIN 44.

*	*	*

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments, indicates your
intent to include the requested disclosure in future filings, and
provides any requested supplemental information.  Detailed letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Rebekah Moore at (202) 824-5482 or myself at
(202) 942-1782 if you have questions regarding our comments and
related matters.

                                   Sincerely,

                                   Paul Cline
                                   Senior Accountant

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Mr. Humberto L. Lopez
Page 3 of 3

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