SecProbe.io

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                                   REFCO INC.
                           One World Financial Center
                           200 Liberty Street, Tower A
                            New York, New York 10281

                                                     August 5, 2005

VIA EDGAR AND FACSIMILE
-----------------------

Mr. Christian Windsor
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.  20002

                   Re:    Refco Inc. - Registration Statement
                          on Form S-1 (No. 333-123969)
                          -----------------------------------

Dear Mr. Windsor:

           Refco Inc. (the "Company"), hereby respectfully requests that the
effective date of the Company's Registration Statement on Form S-1 (File No.
333-123969) (the "Registration Statement") be accelerated so that it becomes
effective at 4:00 p.m. (Eastern time) on August 10, 2005 or as soon thereafter
as practicable.

           In connection with the filing of the Registration Statement, the
Company acknowledges that the disclosure in the filing is the responsibility of
the Company. The Company further acknowledges that staff comment or changes in
response to staff comment in the disclosure in the Registration Statement may
not be asserted in any defense in any proceeding which may be brought by any
person. The Company represents to the Commission that should the Commission or
the staff acting pursuant to delegated authority, declare the filing effective,
it does not foreclose the Commission from taking any action with respect to the
filing and the Company represents that it will not assert this action as a
defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

           The Company further acknowledges that the action of the Commission or
the staff, acting pursuant to delegated authority, in declaring the filing
effective does not relieve the Company from its full responsibility for the
adequacy and accuracy of the disclosures in the filing.

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           I hereby confirm to you that the Company is aware of its obligations
under the Act and the Securities Exchange Act of 1934, as amended, with respect
to the public offering of securities specified in the Registration Statement.

           Please call the undersigned at (212) 587-6035 to confirm such
effectiveness and if you have any questions.

                                            Very truly yours,

                                            /s/  Dennis A. Klejna

                                            Dennis A. Klejna

cc:  Alexander D. Lynch, Esq.
     Weil, Gotshal & Manges LLP

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