SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

   Mail Stop 4561
         April 23, 2009
Mr. James J. McEntee, III Chief Executive Officer and President   Alesco Financial, Inc. Cira Centre 2929 Arch Street  17
th Floor
Philadelphia, PA  19104

Re: Alesco Financial, Inc.
  Form 10-K for the year ended December 31, 2008
  Filed 03/05/09   File No. 001-32026

Dear Mr. McEntee:
We have limited our review of your filing to the issue we have addressed in our
comment.  Please be as detailed as necessary in your response. In our comment, we ask you
to provide us with information so we may better understand your disclosure. After reviewing
this information, we may raise additional comments.

 Please understand that the purpose of our re view 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 for the year ended December 31, 2008

Item 1 – Business, page 12

1. We note your disclosure of summarized information regarding your investments
in your target asset classes that are fina nced through securiti zation vehicles that
are included in your consolidated financia l statements.  Specifically, we note that
you present a column titled ‘Our Initial E quity Investment.’  We also note that
you presented a similar column on page 15 in your 2007 Form 10-K; however, it was titled ‘Our Maximum Exposure to Loss. ’  Please clarify for us the purpose for

Mr. James J. McEntee, III
Alesco Financial, Inc.
April 23, 2009 Page 2
the change in the title of the column.  Pl ease also reconcile any differences in the
amounts disclosed in these columns in your explanation.

*****

Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please understa nd that we may have additional comments
after reviewing your response to our comment.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
   In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filing.
You may contact Jessica Ba rberich, Assistant Chief Accountant, at (202) 551-
3782 or me at (202) 551-3498 if you have ques tions regarding comments on the financial
statements and related matters.             S i n c e r e l y ,
Linda van Doorn  Senior Assistant Chief Accountant

Mr. James J. McEntee, III
Alesco Financial, Inc. April 23, 2009 Page 3