SecProbe.io

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                                Asta Funding, Inc
                                210 Sylvan Avenue
                           Englewood Cliffs, NJ 07632

                                     REVISED
October 7, 2005

Mr. John P. Nolan
Accounting Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
Office of Financial Services
450 Fifth Street, N.W.
Washington, DC 20549

Dear Mr. Nolan:

Please be advised this response letter is a REVISION to our original submission
dated October 4, 2005. The change refers comment #14. paragraph 3. "Total
Collections representing sales for the years 2004 and 2003 are $40.2 million and
$21.5 million, respectively", which corresponds to the correct figures reported
in comment #3. Our previous submission for comment #14 contained $51.9 million
and $21.5 million in collections representing sales for the 2004 and 2003,
respectively. The correction for comment # 14 was inadvertently not changed to
conform with comment #3. We apologize for this inconvenience.

We are in receipt of your letter dated September 16, 2005, and are responding to
the Staff's comments. To assist the Staff, our responses are numbered to
correspond to the numbered paragraphs in the Staff's comment letter.

Form 10-K for the period ended September 30, 2004
Item. Description of Business, page 3
Consumer Receivables Business, Receivable Purchase Program, page 5

         1.    We refer to the second paragraph on page 6 that states you have
               entered into joint ventures and participation and profit sharing
               agreements with your financial and service providers, as part of
               your strategy to acquire consumer receivable portfolios. In this
               regard, please tell us and provide us in future filings with the
               following information:

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         Describe the terms of the joint ventures that you have entered into and
         provide the disclosures required by paragraph 20 of APB 18, as amended
         by paragraph 15.e of SFAS 94.

         We have described our profit participation arrangements in the text
         loosely with the term "joint venture". With the exception of a
         partnership participation with one entity that produced revenue of
         approximately $384,000 for year ended 2004, which we did not consider
         significant, the arrangements we enter into are master servicing
         agreements with our third party servicers. When we enter into
         agreements of this type, we purchase the charged off receivables and
         the collecting or servicing entity will share in the cash flows after
         we recoup, at a minimum, our cost plus an interest factor. After the
         above criteria have been met, the arrangement is generally a 50/50
         split on the subsequent cash flows plus any other pre-arranged
         contingency fees.

         We acknowledge the Staff's comment and will not refer to these
         arrangements as joint ventures in future filings.

         With regard to accounting for such arrangements according to paragraph
         15.e of Statement of Financial Accounting Standards No. 94 ("SFAS 94")
         we currently have only one immaterial partnership referred to above,
         therefore we do not believe that paragraph 15.e. of SFAS 94 applies. We
         acknowledge the Staff's comment and will disclose all material
         partnership arrangements, if any, if we enter into any such
         arrangements in the future.

         State the gains or losses recorded on your equity investments in joint
         ventures and disclose where they are recorded in the income statement.

         As previously mentioned, we have only entered into a partnership
         participation with one entity that, for the fiscal year ended 2004,
         produced revenue of $384,000 and the cost basis of the assets purchased
         was only $6,600,000 compared to our total portfolio purchases of
         approximately $104,000,000. We did not consider this significant, and
         in no other instance has equity been exchanged, no gain or loss has
         been recognized or recorded in our income statement.

         We acknowledge the Staff's comment and if we enter into any material
         equity investments in joint ventures, we will disclose them properly in
         the income statement and further describe the investment in the
         footnotes to the financial statements.

         Describe the terms of any material current and future funding
         requirements and discuss in MD &A their effects on your on your current
         and future cash flows and liquidity.

         The Company from time to time enters into flow agreements to purchase
         charged off receivable for liquidation. Flow agreements are purchases
         of charged off receivables which the Company buys contractually on a
         monthly basis. For the fiscal year, 2004, the Company did not have any
         such agreements in place. In March 2005, the Company entered into a
         flow agreement which requires the Company to purchase charged-off
         receivables for approximately $150,000 to $300,000 per month until
         November of 2005. We considered this amount not significant to
         disclose.

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         We acknowledge that if we enter into any material agreements that
         require future funding, we will disclose them in future filings as
         warranted, or state we have not entered into any material agreements
         that may require future funding or effect future liquidity.

         State the duration and terms of the profit arrangements, including the
         conditions for revenue sharing and cost allocation.

         Inapplicable in the circumstances.

2.       We refer to the penultimate paragraph on page 7 that states you can
         return certain accounts to the seller. In this regard, please tell us
         and disclose in future filings;

         o     The conditions, including any contractual maximum amounts of
               loans and the time period under which you can return these
               accounts to the seller;

         o     If material, state the total dollar amount of loans you have
               returned to the seller for each fiscal period or that have been
               replaced with other receivables.

         Accounts returned to the seller on purchased portfolios, as described
         on page 7 would be accounts collected prior to the cutoff date by the
         seller, debtors who declare bankruptcy filing prior to cutoff date, or
         the death of any debtors prior to the cutoff date as set forth in the
         respective purchase agreements. It should be noted that the seller, in
         most cases, analyzes the sale portfolio for debtors who have declared
         bankruptcy, for debtors who died, and for debtors who have paid in full
         or settled in full. We, after closing on the portfolio, then do the
         same analysis and return those accounts to the seller at the
         contractual cost. As an example, for the fiscal year ended September
         30, 2004, we purchased portfolios with a total purchase price of
         approximately $104 million and we returned approximately $875,000 or
         less than 1%. In fiscal 2003, the percentage of returns was even less
         than fiscal year ended 2004. Our agreements have no stated maximum
         number of accounts to be returned due to the conditions listed above.

         We acknowledge the Staff's comment and will state in future filings
         that returns are immaterial and there is no maximum number of accounts
         that can be returned stipulated in our purchase contracts.

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Portfolio Sales, page 10

3.       We refer to the statement that you sell certain receivables to other
         debt buyers to increase revenue and cash flows. In this regard, please
         tell us and in future filings provide the following information:

         Describe the revenue recognition policies with the respect of the sale
         of receivables, including your consideration of paragraph 11.c of SFAS
         140 with respect to recording recourse obligations on loans sold on a
         recourse basis;

         When the Company purchases a portfolio of non-performing consumer
         accounts, management estimates the cash flow by period. Included in
         this estimate is the expectation that some accounts will be sold as a
         package to other investors and that the remainder of the portfolio will
         be acted upon for collection, either in-house or through our servicers.
         Therefore, in accordance with Practice Bulletin No. 6 and SOP 03-03,
         the collections represented by account sales are not considered
         separate transactions for which gain or loss is recognized, but rather
         implicit in the cash flow projections. Accordingly, there is no
         separate revenue recognition related to these transactions.

         These accounts are sold with limited recourse similar to when we
         purchase receivables, generally on the same terms as the Company's
         purchase from the original seller (i.e. bankruptcy of a debtor, death
         of a debtor, and accounts collected by the seller prior to the cut-off
         date). The Staff should note that the Company has the contractual
         right, when we sell accounts within the cut-off period, to put back to
         the original seller these accounts at the price we originally paid for
         such accounts. Such repurchases by us are limited recourse provisions
         but are de minimis and infrequent. As noted above, for the fiscal year
         ended 2004, such put backs amounted to less than 1% of our cost to
         acquire the portfolios. In accordance with FAS 140 paragraph 11 c., the
         Company estimates the fair value of the liability for such returns as
         approximately zero.

         Disclose the nature and total dollar amount of receivables sold during
         the last two fiscal years and the total gain or loss on sale of
         receivables for each period;

         Total collections represented by account sales for the years ending
         2004 and 2003 amounted to $40.2 million and $21.5 million, respectively
         and finance income recognized from these sales was $14.9 million in
         2004 and $3.3 million in 2003. The significant part our collections
         represented by account sales are part of our business model to maximize
         our collection efforts though our suit strategy as further described in
         the Staff's our response to comment #5. We attempt to sell accounts
         that we deem to be not worthy of our suit strategy, after we exhaust
         attempts to collect them through our typical collection methods.

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         State in what line item of the Consolidated Statement of Operations on
         page F-4 you have included the gain or loss on these sales;

         Disclose in the Consolidated Statement of Cash Flows on page F-6 the
         cash flows that have resulted from the sale of these receivables and
         the adjustment to reconcile net income to net cash provided by
         operating activities.

         In accordance with Practice Bulletin No. 6 and SOP 03-03, the
         collections represented by account sales are not considered separate
         transactions for which gain or loss is recognized, but rather implicit
         in the cash flow projections. Accordingly, there is no separate revenue
         recognition related to these transactions. An estimate of portfolio
         collections, including those arising from collections represented by
         sales activity, is imbedded in the estimated yield on the specific
         portfolio. Such yield is the internal rate of return based upon the
         remaining carrying value of the portfolio and estimated amount and
         timing of future cash flows. We acknowledge the Staff's comment and
         will include the collections represented by account sales as a
         disclosure item in future filings.

         The income derived from collections and sales of receivables is
         included in the "Finance income" line of the Consolidated Statements of
         Operations. However, no separate gain or loss is recognized upon the
         sale of a specific portfolio loan.

         We account for sales of receivables in the same manner as collections
         in the normal course of events. Therefore, since there is no separate
         gain or loss recognized on the sale, there is no non-cash component to
         be reflected as an adjustment to reconcile net cash provided by
         operating activities.

Other Activities, page 11

4.       We refer to the forbearance agreement entered into with SBR in April
         2002 in connection with the loans the Company provided to SBR.
         Considering you wrote off your entire investment in 2001, please tell
         us and in future filings disclose:

         The business reasons for entering into a forbearance agreement in 2002
         with respect to loans provided to SBR;

         As a practice, we do not enter into forbearance agreements. However;
         the only case as referenced, the forbearance agreement was entered into
         with an entity named SBR, in order to try to preserve the Company's
         interest in an investment made in 2000. SBR is an internet
         business-to-business e-commerce company which markets services to small
         businesses. We expected that SBR would become a profitable business and
         an additional source to purchase receivables through their access to
         small business, and thus derive additional income.

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         The conditions of the forbearance and warrant agreements with SBR,
         including any contingencies retained by the Company.

         As the investment was fully written off by 2001, it is no longer
         necessary to refer to SBR in any future filings. The Company originally
         had a debt investment in SBR and subsequently exchanged that debt for
         equity. There is a chance that under certain remote circumstances, the
         Company might recoup some portion of its investment. However, we
         acknowledge the Staff's comment and will include the necessary comments
         in future filings to describe any Other material activities we may
         enter into in the future.

Risk Factors, page 13

5.       We refer to the risk factor on page 15 titled "We are dependent upon
         third parties to service a majority of our consumer receivable
         portfolios". Please reconcile the statement that you outsource a
         majority of your receivable servicing with the following statements in
         MD & A by telling us how they are applicable or consistent with page
         15:

         The "Third-Party Servicing Revenues" section on page 29 states you
         recorded in 2004 a 76.3% decrease in third party servicing expenses as
         compared to 2003 due to the elimination of accounts being serviced by
         third parties during 2004; and,

         The "Revenues" section on page 28 states that management decided in
         2004 to implement a greater collection effort using its attorney
         networks and the courts for collection which partially resulted in a
         change in accounting estimate for recognizing a $9.8 million increase
         in finance income in 2004.

         The statement regarding outsourcing of the majority of our work refers
         to the collectors with whom we contract on a contingent fee basis. The
         collections received by our servi