SecProbe.io

November 5, 2010
   Mr. Thomas R. Cangemi Senior Executive Vice Presiden t and Chief Financial Officer
New York Community Bancorp, Inc. 615 Merrick Avenue Westbury, New York 11590
Re: New York Community Bancorp, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2009
  Form 10-Q for Fiscal Quarter Ended March 31, 2010    Form 10-Q for Fiscal Quarter Ended June 30, 2010
 File No. 001-31565

Dear Mr. Cangemi:
 We have reviewed your supplemental response and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested  response.  If you do not believe our comments
apply to your facts and circumstances or do not be lieve future revisions are appropriate, please
tell us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.

Mr. Thomas R. Cangemi
New York Community Bancorp, Inc. November 5, 2010 Page 2

Form 10-Q for the Quarter Ended June 30, 2010

 Consolidated Statements of Condition, page 1

1. We note in your balance sheet on page 1 that  you present your covered loans below your
allowance for loan losses.  In addition, we  note your disclosure on page 25 that for
decreases in expected cash flows an allo wance for the covered loan loss will be
established.  Please revise your future interi m and annual filings to clearly present the
allowance for loan loss related to “Covered lo ans” and the allowance for loan loss related
to “non-covered loans”.  If your current allowance of $140.58 million was established to
cover both sub-categories of loans then pl ease present the “Covered loans” line item
before the allowance for loan losses line  item and subtotal for “Total loans”.

Notes to the Unaudited Consolidated Financial Statements
 Note 2. Business Combinations

 Loans, page 9

2. We note your disclosure on page 10 that you aggregated the acquire d loans for both the
AmTrust and Desert Hills transactions into one or more pools and the pools were based
on loans with common risk characteristics.  In addition, we note your response to prior
comment six of our letter dated May 21, 2010 that you applied ASC 310-30 to all acquired loans because at least part of the discount recorded on the acquired loans was
attributable to credit quality.  Please tell us and revise to disclose in future filings the
following regarding your appl ication of ASC 310-30:

 How you segregated the acquired loans in to pools for accretion and impairment
testing purposes. Identify the specific lo an characteristics that were used for
segregation and whether performing a nd nonperforming loans were separately
segregated.
 How you determined that at least part of the discount applied was attributable to
credit quality for loans that were performing under the terms of the loan agreement;
and
 The loans at the acquisition date that met the criteria of ASC 310-30 and those loans
that you analogized to ASC 310-30.  In additi on, in an effort to provide clear and
transparent disclosures pleas e provide separate ASC 310- 30-50 disclosures for both
groups of loans.

Mr. Thomas R. Cangemi
New York Community Bancorp, Inc. November 5, 2010 Page 3

Note 5. Loans, net, page 21

3. We note your response to prior comment ni ne of our letter dated May 21, 2010.  In
addition, we note from your disclosures on page 5 that you have loans with the
underlying collateral located in New York, Ne w Jersey, Ohio, Flor ida, and Arizona.
Given your expansion in your  geographic operations during 2009 and 2010 from your
primary lending area of New York and Ne w Jersey and the continued decline from
December 31, 2008 to June 30, 2010 of your asset quality please provide in future filings a breakdown of your loan portfolio and re lated non-performing loans by geographic
location.

4. We note your response to prior comment 17 of our letter dated May 21, 2010.  Based on
our review of your allowance rollforward di sclosure on pages 24 and 58 we were unable
to locate your revisions to the rollforward that clearly s how the effect the loss sharing
agreements have on your provision for loan losses.   Please tell us where this is located in
your June 30, 2010 Form 10-Q.  If the separate  line item quantifyi ng the provision before
expected reimbursements from the FDIC was not included please revise to include in
future filings.
Item 2. Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Summary of Financial Condition at June 30, 2010
 Acquisition, Development, and Cons truction (“ADC”) Loans, page 51

5. We note your disclosure on page 52 that due to the higher degree of  credit risk for ADC
loans in addition to the co llateral provided by a project, you also obtain personal
guarantees of repayment and completion during construction from the borrower.  Please
tell us the following regard ing your ADC loan portfolio:

 Whether you have any ADC loans that have  been extended at or near original
maturity, for which you have not consider ed impaired due to  the existence of
guarantees.  If so, please tell us about th e types of extensions being made, whether
loan terms are being adjusted from the orig inal terms, and whether you consider these
types of loans as collateral-dependent;
 To the extent you extend ADC loans at or ne ar maturity at the existing loan rate due
to the existence of a guarantee, please tell us how you consider whether it is a
troubled debt restructuring;

Mr. Thomas R. Cangemi
New York Community Bancorp, Inc. November 5, 2010 Page 4

 Disclose in detail how you ev aluate the financial strength  of the guarantor.  Address
the type of financial information reviewe d, how current and objective the information
reviewed is, and how often the review is performed;
 Disclose how you evaluate the guarantor’s reputation and willingness to work with
you and how this affects any allowance fo r loan loss recorded and the timing of
charging-off the loan;
 Disclose how often you have pursued and successfully collected from a guarantor
during the past two years.  As part of  your response, please discuss the decision
making process you go through in deciding whether to pursue the guarantor and
whether there are circumstances you would not seek to enforce the guarantee; and
 Quantify the dollar amount of commercial lo ans in which your carrying value is in
excess of the appraised value but not consid ered impaired due to the existence of
guarantees.

Asset Quality, page 53

6. We note your disclosure on page 54 that when  necessary, you rely on current appraisals
to write down your non-performing loans (NPL s).  In addition, we note from your
disclosures on page 60 that your five largest NPLs had an updated appraisal within six
months of them being placed on non-accrual status.  Please tell us and revise future
filings to disclose the following:

 How often you obtain updated appraisals for your collateral dependent loans, both
performing and non-performing (non-accrual and/ or impaired).  If this policy varies
by loan type please disclose that also.
 Describe any adjustments you make to the fa ir value calculated, including those made
as a result of outda ted appraisals.
 Discuss how you consider the potential fo r outdated appraisal values in your
determination of the allowance for loan losses.
 How you determine, including the process, th e fair value of the collateral if an
appraisal is not available.

Mr. Thomas R. Cangemi
New York Community Bancorp, Inc. November 5, 2010 Page 5

Covered Loans and OREO, page 57

7. We note your disclosure on page 57 that th e loss share receivab le may increase or
decrease if losses on the covere d assets increase or fall short of the expected amounts.  In
addition, we note that the loss share receivab le may also increase due to accretion, which
was $22.9 million during the first half of 2010.  Please tell us  and revise your future
filings to be more specific with respect to how and when adjustments to the loss sharing
receivable are recognized.  Fo r example, when cash flow estimates are adjusted upward,
explain whether you are accreting those adjust ments over the life of the related covered
loans or taking the charge to reduce the loss sh aring receivable in the period identified.
Additionally, please elaborate on the $22.9 millio n accretion that increased the loss share
receivable and whether this  relates to the difference in the discounted versus
undiscounted cash flows.
8. We note your response to prior comment f our of our letter dated May 21, 2010.  In
addition, we note from your disclosures on page 58 that your NPLs increased from
$578.07 million at December 31, 2009 to $636.78 million at June 30, 2010 despite the
reclassification of $150.29 m illion of troubled-debt restru cturings (TDRs) from non-
accrual to accrual during the first half of 2010.  Please tell us and revise future filings to
include the following:

 Detailed discussion on the fluctuations in NPLs  considering th e reclassification of
TDRs from non-accrual to accru al and NPLs excluding TDRs;
 Discuss if the fluctuation relates to a few large credit relationships or several small
credit relationships or both;
 If several small credit relationships im pact the fluctuation please discuss the
following for each group of smaller creditors:
  Type of borrowers, location of the loa n, loan type, or ot her specific factors
that are unique to the gro up of creditors and loans;
 If any of the decline in asset quality relates to conditions confined to a
particular time period or may continue  into the foreseeable future; and
 Any other pertinent information deemed  necessary to understand the increase
in the NPLs.
 If a few large credit relationships make up the majority of the fluctuation in your
NPLs, discuss those relationshi ps in detail, including:
 General information about the borrower and location;
 The amount of total credit exposure outstanding;
 The amount of the allowance allocate d to the credit relationship; and

Mr. Thomas R. Cangemi
New York Community Bancorp, Inc. November 5, 2010 Page 6

 Provide additional information supporting the allowance for loan loss for each
credit.

9. We note your response to prior comment 19 and your disclosure on page 60 of the five
largest NPLs as of June 30, 2010.  For these fi ve largest NPLs pleas e tell us and include
in future filings the following:

 Total amount of loan at originati on and current lending commitment;
 Total outstanding balance on th ese loans at June 30, 2010;
 Average loan-to-value (LTV) ratio at origination and current LTV ratio; and
 Enhanced discussion about each loan including:

  General information about th e borrower and location; and
 Provide additional information supporting the allowance for loan loss for each
credit.
 You may contact Lindsay McCord, Staff Accounta nt, at (202) 551-3417 or me at (202) 551-3474
if you have questions.
Sincerely,

Sharon M. Blume Assistant Chief Accountant