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CORRESP
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Correspondence

 615 MERRICK AVENUE, WESTBURY, NY 11590

 516-683-4014 — Fax # 516-683-8344 — www.myNYCB.com

Thomas R. Cangemi

 Senior Executive
Vice President &

 Chief Financial Officer

 December 3, 2010

 VIA EDGAR

 Sharon M. Blume

 Assistant Chief Accountant

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, DC 20549

 Re:   New York Community Bancorp, Inc.

Form 10-K for the 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 Ms. Blume:

 On behalf of New York Community Bancorp, Inc.
(“NYB” or the “Company” or “we”), I am writing in response to the Staff’s letter, dated November 5, 2010, containing comments on NYB’s Annual Report on Form 10-K for the year ended December 31, 2009
(the “10-K Report”), Form 10-Q for Fiscal Quarter Ended March 31, 2010 and Form 10-Q for Fiscal Quarter Ended June 30, 2010 (together, the “Form 10-Q Reports”).

NYB’s responses to the Staff’s comments are set out below. For convenience, each response follows the text of the comment to
which it relates.

 United States Securities and Exchange Commission

 December 3, 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 allowance for the covered loan loss will be established. Please revise your future interim and annual filings to clearly present the allowance for loan loss related to “Covered loans” 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 please present the “Covered loans” line item before the allowance for
loan losses line item and subtotal for “Total loans”.

 In future interim and annual
filings, we will separately present the allowance for loan losses relating to non-covered loans and the allowance for loan losses relating to covered loans, if any. Please note that the $140.58 million allowance established at June 30, 2010 and
the $155.87 million allowance established at September 30, 2010 only related to non-covered loans. There was no allowance established for covered loans at either date.

 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 acquired 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 application of ASC 310-30:

•

 How you segregated the acquired loans into pools for accretion and impairment testing purposes. Identify the specific loan characteristics that were
used for segregation and whether performing and 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 addition, in an effort
to provide clear and transparent disclosures please provide separate ASC 310-30-50 disclosures for both groups of loans.

 We segregated the loans acquired in the AmTrust acquisition, which were substantially (99.94%) residential mortgage and home equity loans, by loan product type, i.e., Prime, Sub-prime and Alt-A, then
by whether or not they were modified or non-modified, and finally by fixed or adjustable rate. Performing and non-performing classifications were not used, as all the loans, except loans serviced by others, acquired in the AmTrust transaction were
performing at the time of acquisition.

 United States Securities and Exchange Commission

 December 3, 2010

 Page 3

 Regarding the loans acquired in the Desert
Hills transaction, they were segregated by loan type, i.e., commercial real estate, construction/land, multi-family, residential, and consumer. Given the immaterial nature of this acquisition (loans acquired were 0.7% of the Company’s total
loan portfolio at March 31, 2010), the loans were not segregated further by performing or non-performing status.

 We determined that at least part of the discount on the acquired loans was attributable to credit quality by reference to the valuation model used to estimate the fair value. The valuation model
incorporates over 40 different data inputs, including inputs that resulted in estimates of uncollectible cash flow (i.e., reductions in fair value attributable to credit quality). Some of the key drivers of the model include, but are not limited to,
original loan-to-value (“LTV”), current LTV, geographic location of the collateral property, payment status of the loan, FICO scores, and whether the loan interest rate was fixed or adjustable. The model compares each loan’s
characteristics to a comprehensive loan performance database. This database provided access to loan balances totaling over $1.5 trillion. The model then produced estimates about constant prepayment rates, credit default rates, loss severity curves,
and cumulative credit losses for each loan. Based on the model’s results, we concluded that at least part of the discount on the acquired loans was attributable to credit quality. We therefore analogized all loans in the pools to ASC 310-30.
Consequently, the disclosures under ASC 310-30-50 were provided for these loans, and we don’t consider there to be two groups of loans that require disclosures.

 Note 5. Loans, net, page 21

3.
We note your response to prior comment nine 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, New Jersey, Ohio, Florida, and Arizona. Given your expansion in your geographic operations during 2009 and 2010 from your primary lending area of New York and New 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 related non-performing loans by geographic location.

In future interim and annual filings we will provide a breakdown of our loan portfolio and related 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 disclosure on pages 24 and 58 we
were unable to locate your revisions to the rollforward that clearly show 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 quantifying the provision before expected reimbursements from the FDIC was not included please revise to include in future filings.

 We determine the allowance for loan losses attributable to post-acquisition decreases in expected collections from borrowers on covered loans without giving consideration to amounts estimated to be
recoverable from the FDIC under the loss sharing agreements. There were no post-acquisition decreases in expected collections from borrowers on covered loans through June 30, 2010. Accordingly, the loss sharing agreements had no effect on our
provision for loan losses for the six months ended June 30, 2010 and a revision to the allowance for loan loss rollforward was not necessary for such period. If, in future periods, the loss sharing agreements have a material effect on our
provision for loan losses, we will include appropriate disclosures.

 United States Securities and Exchange Commission

 December 3, 2010

 Page 4

 Item 2. Management’s Discussion and Analysis of Financial
Condition and Results of Operations

 Summary of Financial Condition at June 30, 2010

Acquisition, Development and Construction (“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 collateral provided by a project, you also obtain
personal guarantees of repayment and completion during construction from the borrower. Please tell us the following regarding your ADC loan portfolio:

•

 Whether you have any ADC loans that have been extended at or near original maturity, for which you have not considered impaired due to the existence
of guarantees. If so, please tell us about the types of extensions being made, whether loan terms are being adjusted from the original terms, and whether you consider these types of loans as collateral-dependent;

•

 To the extent you extend ADC loans at or near 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;

•

 Disclose in detail how you evaluate the financial strength of the guarantor. Address the type of financial information reviewed, 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 for 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 loans in which your carrying value is in excess of the appraised value but not considered impaired due to
the existence of guarantees.

 At June 30, 2010, the Company had three ADC loans in
the aggregate amount of $38.4 million that have been extended at or near original maturity which the Company has not considered impaired due to the existence of personal guarantees. The loan terms were modified from the original terms; however, they
are structured on market terms. Typically the extension requires from the borrower such things as a principal reduction or conversion from an interest only to an amortizing structure. Further, the borrower typically is required to be able to meet
debt service out of pocket. In addition, we did not provide an interest reserve from the loan proceeds at extension. While these loans are substantially collateralized by real estate values supported by current appraisals, they are not considered
collateral dependant given the strength of the personal guarantees required from the principals.

 United States Securities and Exchange Commission

 December 3, 2010

 Page 5

 We do not extend ADC loans at the
existing/original interest rate unless that rate is consistent with the current market at extension, and unless the borrower is determined to be creditworthy. Further, the existence of a personal guarantee does not influence the Company’s
decision on interest rate. ADC loans that are extended at or near maturity are considered troubled debt restructuring (“TDR”) if, at the time of the extension, the borrower is experiencing financial difficulty and a concession on the
restructured loan was granted that we might not otherwise offer on a new loan application.

 The financial
strength of the guarantor is evaluated based on objective documentation. The Company requires a signed copy of the prior two years federal tax returns for the guarantor and borrowing entity. In addition, the borrower’s credit history is
verified through an independent credit reporting agency engaged by the Company. The guarantor and borrowing entity names are also run through Westlaw for a public records search of litigation and liens. In addition, we confirm the borrower’s
credit history with other lending institutions.

 The Company also requires a current personal financial
statement (“PFS”) certified as of the date submitted by the guarantor. The Loan Underwriter evaluates the PFS along with all other financial documentation, including a global cash flow analysis, to determine the guarantor’s capacity
to carry the indebtedness. This financial review is performed at origination and upon any extension of the loan. A review of the underlying real estate project is performed on a continuous basis, but not less than monthly.

Guarantor reputation and willingness to work with the Company are subjective factors that only influence the allowance for
loan loss recognition to the extent the borrower’s cooperation is determined to add tangible value and economic support to the credit. In this context, reputational considerations might include our prior history with the guarantor, and how well
the guarantor is performing on other credits, if any, with the Company and with other institutions. Similarly, the guarantor’s willingness to work with the Company may be considered if the guarantor is agreeable to making an increased
commitment to the transaction such as additional collateral, a principal reduction, or converting from an interest-only to an amortizing structure.

 For loans with personal guarantees, the Company may choose to pursue a suit under the note or guaranty. Depending on the jurisdiction, this is done either simultaneously with the foreclosure action or as
a deficiency after the property has been foreclosed. The decision to pursue a guarantor is dependent upon the location of the collateral and the guarantor’s financial strength. This decision is also based upon the collateral value, whether the
Company has a first or second lien, financial strength of the property/guarantor, and other possible legal considerations that vary with each loan. To date the Company has not collected on any personal guarantees on ADC loans; however, we are
currently pursuing collection efforts on several personal guarantees through the foreclosure process.

 At
June 30, 2010, the Company had three ADC loans totaling $38.4 million, for which the carrying value of the loans exceed the appraised value but are not considered 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 (NPLs). 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.

 United States Securities and Exchange Commission

 December 3, 2010

 Page 6

•

 Describe any adjustments you make to the fair value calculated, including those made as a result of outdated appraisals.

•

 Discuss how you consider the potential for outdated appraisal values in your determination of the allowance for loan losses.

•

 How you determine, including the process, the fair value of the collateral if an appraisal is not available.

Our future filings will be revised to include the following:

It is the Company’s policy to order updated appraisals for all non-performing loans (“NPLs”), irrespective
of loan type, that are collateralized by commercial real estate (“CRE”), multi-fami