SecProbe.io

December 21, 2011
 Via E-mail

Robert Stiles Chief Financial Officer Altisource Portfolio Solutions S.A. 291, Route d’Arlon L-1150 Luxembourg Grand Duchy of Luxembourg
Re: Altisource Portfolio Solutions S.A.
 Form 10-K for Fiscal Year Ended December 31, 2010
Filed February 18, 2011 File No. 001-34354

Dear Mr. Stiles:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your facts and circumstances, please tell
us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.               Form 10-K for the Fiscal Year Ended December 31, 2010

Risk Factors, page 10
 General

1. In future filings, please revise your Risk F actor section to include a full discussion of
the most significant factors you face.  Expa nd the disclosure of the specific risks you
face by operating in the real estate servi ces and mortgage industry including, for
example, the on-going impact of the economic crisis and adverse regulatory consequences.  Other areas suitable for el aboration include risks associated with
customer resistance to third party servi ces, the long sales cycle for your technology
solutions and potential development set-back s, as well as more detailed discussion of

Robert Stiles Altisource Portfolio Solutions S.A. December 21, 2011 Page 2

 the risks you face as a highly regulated entity  subject to extensive and changing laws.
Refer to Item 503(c) of Regulation S-K.

Item 7. Management’s Discussion and Analysis  of Financial Condition and Results…, page 18

 Consolidated Results of Operations, page 22

2. In future filings, please explain either here , or in your Business  section, your global
delivery platform for collections.  Discuss why the build out of this platform has
resulted in lower revenues pe r account and higher margins.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Leigh Ann Sc hultz, Staff Accountant, at 202-551-3628 or Terry French,
Accountant Branch Chief, at 202-551-3828 if you have questions regarding comments on the
financial statements and related matters.  Plea se contact Kate Beukenka mp, Staff Attorney, at
202-551-6971 or me at 202-551-3810 with any other questions.

Sincerely,
   /s/ Larry Spirgel
Larry Spirgel Assistant Director