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Correspondence

 LPL INVESTMENT HOLDINGS INC.

One Beacon Street

Boston, MA 02108

January 23, 2012

 BY EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

 Attn: Suzanne Hayes

Re:
Comment Letter Dated January 6, 2012

LPL Investment Holdings Inc.

Form 10-K for the Fiscal Year Ended December 31, 2010 Filed March 9, 2011

Form 8-K Filed April 27, 2011

File No. 001-34963

 Dear Ms. Hayes:

 LPL Investment Holdings Inc. (the “Company”) respectfully submits this letter in response to comments contained in your
letter dated January 6, 2012 relating to the Company’s Annual Report on Form 10-K and Current Report on Form 8-K filed with the Securities and Exchange Commission on March 9, 2011 and April 27, 2011, respectively. We have, for
your convenience, reproduced the Staff’s comments, followed by the Company’s responses, below.

 Form 10-K for the Fiscal Year
Ended December 31, 2010

 Item 1. Business

 Our Financial Advisors, page 2

 1. We note that you disclose the compound annual growth
rate for your advisor base. Please also disclose in this section the annual growth rate for the most recently completed fiscal year.

Response to Comment 1:

 We confirm that
for any future periods in which we discuss the compound annual growth rate for our advisor base, we will also disclose the annual growth rate for the most recently completed fiscal year.

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January 23, 2012

 Item 1A. Risk Factors

 Regulatory developments and our failure to comply with regulations…, page 17

 2. In
future filings, please expand this risk factor to specifically discuss any pending legislation, rules or regulations that could have a material effect on you.

 Response to Comment 2:

 We confirm that in future filings we will expand this risk factor
to specifically discuss any pending legislation, rules or regulations that could have a material effect on us. For example, future filings will discuss certain provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, including
the potential implementation of a more stringent fiduciary standard for broker-dealers and enhanced regulatory oversight of incentive compensation.

 Our indebtedness could adversely affect our financial health…, page 20

 3. In
future filings, please revise this risk factor to specifically describe the effects your indebtedness could have on you. Among other things, the revised risk factor should describe and quantify your debt service obligations, describe and quantify
the effect of one and two notch credit rating downgrades and describe the financial and restrictive covenants contained in your debt agreements.

 Response to Comment 3:

 We confirm that in future filings we will revise this risk factor
to specifically describe the effects our indebtedness may have on us. Specifically, we expect to revise the disclosure to read substantially as follows in our upcoming Annual Report on Form 10-K (revised language in bold):

Our indebtedness could adversely affect our financial health and may limit our ability to use debt to fund future capital needs.

 At December 31, 2011, we had total indebtedness of $xxx billion. Our level of indebtedness could increase our
vulnerability to general adverse economic and industry conditions. It could also require us to dedicate a substantial portion of our cash flow from operations to payments on our indebtedness, thereby reducing the availability of our cash flow to
fund working capital, capital expenditures and other general corporate purposes. In addition, our level of indebtedness may limit our flexibility in planning for changes in our business and the industry in which we operate, place us at a
competitive disadvantage compared to our competitors that have less debt and limit our ability to borrow additional funds.

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January 23, 2012

 Our Third Amended and Restated Credit Agreement (“senior secured credit
agreement”) requires quarterly repayments of our term loans. These payments equal approximately $3.50 million per quarter through March 31, 2013, $2.70 million per quarter through March 31, 2015 and $1.45 million per quarter through
March 31, 2017. In addition, we have a revolving credit facility under our senior secured credit facility with an available balance of $163.5 million. This facility matures on June 28, 2013, and we will be obligated to repay any
outstanding balance under this facility at that time. Our ability to make scheduled payments on or to refinance indebtedness obligations depends on our financial condition and operating performance, which are subject to prevailing economic and
competitive conditions and to certain financial, business and other factors beyond our control.

 We may not be able to maintain
a level of cash flows from operating activities sufficient to permit us to pay the principal, premium, if any, and interest on our indebtedness. In addition, as discussed above, we are limited in the amount of capital that we can draw from our
broker-dealer subsidiaries. If our cash flows and capital resources are insufficient to fund our debt service obligations, we could face substantial liquidity problems and could be forced to sell assets, seek additional capital or seek to
restructure or refinance our indebtedness. These alternative measures may not be successful or feasible. Our Third Amended and Restated Credit Agreement (“senior secured credit
agreement”) restricts our ability to sell assets. Even if we could consummate those sales, the proceeds that we realize from them may not be adequate to meet any debt service obligations then due. Furthermore, if an
event of default were to occur with respect to our senior secured credit agreement or other future indebtedness, our creditors could, among other things, accelerate the maturity of our indebtedness.

In addition, as a result of reduced operating performance or weaker than expected financial condition, rating agencies could
downgrade our senior unsecured subordinated notes, which would adversely affect the value of shares of our common stock.

 Our senior secured credit agreement permits us to incur additional indebtedness. Although our senior secured credit agreement contains restrictions on the incurrence of additional indebtedness, these
restrictions are subject to a number of significant qualifications and exceptions, and the indebtedness incurred in compliance with these restrictions could be substantial. Also, these restrictions do not prevent us from incurring obligations that
do not constitute “indebtedness” as defined in our senior secured credit agreement. To the extent new debt or other obligations are added to our currently anticipated debt levels, the substantial indebtedness risks described above would
increase.

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 A credit rating downgrade would not impact the terms of or our repayment obligations
under our senior secured credit agreement. However, any such downgrade would negatively impact our ability to obtain comparable rates and terms on any future refinancing of our debt and could restrict our ability to refinance.

We supplementally advise the Staff that the financial and restrictive covenants contained in our senior secured credit agreement, which is our only
currently outstanding debt agreement, are summarized in the risk factor titled “Restrictions under certain of our outstanding indebtedness….” In future filings, we will revise this risk factor to clarify that we are referring to our
senior secured credit agreement and will specifically reference the leverage ratio test and interest coverage ratio test included therein.

Item 6. Selected Financial Data, page 34

 4. It appears that you have identified Adjusted EBITDA, Adjusted Earnings, and Adjusted Earnings per Share as non-GAAP on pages 41 and 43 of your filing, but these measures are not clearly labeled as
non-GAAP in each location where they are used including here. Please revise your disclosure in future filings, including your earnings releases furnished in Forms 8-K, to clearly label these measures as non-GAAP wherever presented in the filing,
including when they are part of a financial metric. Refer to Item 10(e) of Regulation S-K.

 Response to Comment 4:

We confirm that in future filings, including our earnings releases furnished in Forms 8-K, we will expressly label these measures as non-GAAP wherever
presented.

 5. You disclose that the 2010 gross margin measure excludes $222 million in share-based compensation to advisors related to the
restriction on common stock that was released upon closing of your IPO in the fourth quarter of 2010. As you are adjusting this measure for the year ended December 31, 2010 to exclude these charges, it appears to be a non-GAAP measure for that
period. Please revise your disclosure in future filings to change the label of this measure in 2010 to reflect that it has been adjusted. Also, revise your disclosure to clearly label the 2010 adjusted gross margin and adjusted gross margin as a %
of net revenue as non-GAAP.

 Response to Comment 5:

 We advise the Staff that in future filings we will revise our disclosure to identify gross margin as a non-GAAP measure. In addition, we will revise our disclosure regarding gross margin to identify more
clearly the expense categories from the consolidated statements of income that are deducted from net revenues for the purposes of computing gross margin, including the $222 million in share-based compensation that we excluded in 2010.

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 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

 Our Operating Expenses

 Production Expenses, page 38

 6. You disclose here that you refer to your production
expenses, including brokerage, clearing and exchange fees as production payout. You also disclose on page 38 that you adjusted your production payout measure for 2010 to exclude the $222 million in share- based compensation charges triggered by your
initial public offering. You also provide disclosure and discussion of a production payout percentage on page 49 for each period presented. Furthermore, your Form 10-Q for the Quarterly Period Ended September 30, 2011 provides definitions of
production expenses and production payout that appear contradictory. You disclose on page 27 of the Form 10-Q that you refer to production expenses including brokerage, clearing, and exchange fees as production payout. However, on page 39 of the
Form 10-Q you disclose that your production payout includes all production expenses except brokerage, clearing and exchange expenses for the three months ended September 30, 2011 and 2010. In light of the adjustments to these measures and
changes in their respective definitions between periods, please address the following:

•

 Revise your disclosure in future filings to clearly and consistently define how you calculate the production payout measure and percentage metric
that you disclose.

•

 Tell us and clearly disclose in future filings the extent to which you changed the calculation during any of the periods presented. Identify the
date at which you changed the definition, and discuss why you believed it was appropriate to make such a change.

•

 Change the title of the adjusted production payout measure and adjusted production payout percentage for 2010 to reflect the fact that it has been
adjusted to exclude the $222 million in share-based compensation charges.

•

 Clearly label the adjusted production payout measure and percentage as non-GAAP where used throughout the document and provide a reconciliation to
the unadjusted measures and percentages.

 Response to Comment 6:

As provided in our filings, production expenses are comprised of the following: gross commissions and advisory fees that are earned and paid out to
advisors based on the sale of various products and services; production bonuses for achieving certain levels of production;

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recognition of share-based compensation expense from stock options and warrants granted to advisors and financial institutions based on the fair value of the awards at each interim reporting
period; amounts designated by advisors as deferred commissions in a non-qualified deferred compensation plan that are marked to market at each interim reporting period; and brokerage, clearing and exchange fees. Our production payout includes all of
the production expenses, except brokerage, clearing and exchange expenses. Our production payout percentage is calculated as commission and advisory fees divided by commission and advisory revenues, and we exclude brokerage, clearing and exchange
fees from this measure.

 We advise the Staff that though our Annual Report on Form 10-K and page 27 of our Quarterly Report on Form 10-Q
incorrectly stated that brokerage, clearing and exchange expenses were included in production payout, the actual calculations of production payout excluded such amounts, consistent with our other filings in fiscal 2011. There was no change in
calculation during the periods presented.

 In future filings, we will revise our disclosures regarding production payout to define this
measure clearly and consistently. We present production payout as a percentage, and we believe this percentage or ratio is best categorized as a statistical or operating measure rather than a non-GAAP financial measure. However, we will include
disclosure in our description of production payout to state that it is an operating or statistical measure rather than a GAAP-based measure. Specifically, we expect to revise the disclosure under “Operating Expenses – Production
Expenses” in “Management’s Discussion and Analysis of Financial Condition and Results of Operations” to read substantially as follows in our upcoming Annual Report on Form 10-K (revised language in bold):

Production Expenses. Production expenses are comprised of the following: gross commissions and advisory fees that are
earned and paid out to advisors based on the sale of various products and services; production bonuses for achieving certain levels of production; recognition of share-based compensation expense from stock options and warrants granted to advisors
and financial institutions based on the fair value of the awards at each interim reporting period; amounts designated by advisors as deferred commissions in a non-qualified deferred compensation plan that are marked to market at each interim
reporting period; and brokerage, clearing and exchange fees. Our production payout, a statistical or operating measure, includes all production expenses except brokerage, clearing and exchange expenses. Substantially all of the production
payout is variable and correlated to the revenues generated by each advisor. Our production payout percentage is calculated as commission and advisory fees divided by commission and advisory revenues, and we exclude brokerage, clearing and
exchange fees from this measure.

 Upon closing of our IPO in the fourth quarter of 2010, the restriction of approximately
7.4 million shares of common stock issued to advisors under the Fifth Amended and Restated 2000 Stock Bonus Plan was released. Accordingly, we recorded a share-based

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compensation charge of $222.0 million in the fourth quarter of 2010, representing the offering price of $30.00 per share multiplied by 7.4 million shares. This charge has been
classified as production expense, but has been excluded from our production payout for 2010 for consistency and comparability to other periods presented because this charge related to equity awards granted in prior periods.

How We Evaluate Growth