SecProbe.io

Mail Stop 3720
December 4, 2017

William B. Shepro
Director and Chief Executive Officer
Altisource Portfolio Solutions S.A.
40, avenue Monterey
L-2163 Luxembourg
Grand Duchy of Luxembourg

Re: Altisource Portfolio Solutions S.A.
 Form 10-K for Fiscal Year Ended December 31, 2016
Filed February 16, 2017
Form 10 -Q for Quarterly Period Ended September 30, 2017
Filed  October 26, 2017
File No. 001 -34354

Dear Mr. Shepro :

We have reviewed your filing an d have the following comments.  Please comply with the
following comments in future filings.  Confirm in writing that you will do so and explain to us
how you intend to comply.  In some of our comments, we may ask you to provide us w ith
information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments appl y to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -Q for Quarterly  Period Ended September 30, 2017

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Consolidated Results of Operations

Revenue, page 35

1. We note your disclosure that the reason for the decline in your service revenues was
primarily due to declines in your customer relationship ma nagement revenue (partly as a
result of the transition of services from one customer to another) and “the normal runoff
of Ocwen’s portfolio in the Mortgage Market.”  Provide greater detail as to the

William B. Shepro
Altisource Portfolio Solutions S.A.
December 4, 2017
Page 2

 significance of Ocwen’s portfolio to your financial resu lts, clarify what you mean by
“normal” runoff, and describe the decline referenced above with respect to any impact on
your operating results given that the Mortgage Market is your largest segment and Ocwen
is your most significant customer within that seg ment.

Legal Proceedings

Regulatory M atters, page 47

2. We note that the Consumer Financial Protection Bureau (CFPB) is considering a
potential enforcement action against Altisource .  You disclose that the alleged violation
“primarily concerns certain technology services provided to Ocwen.”  Enhance your
disclosure to include a description of the factual basis alleged by the CFPB that underlies
the potential enforcement action.  Refe r to Item 103 of Regulation S -K.

Risk Factors

We have entered into a Brokerage Agreement with NRZ’s licensed brokerage subsidiary with
respect to the Ocwen  Transferred Portfolio.  If the Brokerage Agreement is terminated, our
business and results of operations could be affected, page 47

3. Enhance your risk factor disclosure to address the specific events that could result in the
Brokerage Agreement being term inated early.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may cont act Christie Wong , Senior Staff Accountant , at (202) 551 -3684  or Terry
French , Accountant  Branch Chief , at (202) 551 -3828  if you have questions regarding comments
on the financial statements and related matters.  Please contact Joshua Shainess, Attorney -
Adviser , at (202) 551 -7951 , or me at (202) 551 -3810 with any other questions.

Sincerely,

 /s/ Larry Spirgel

 Larry Spirgel
Assistant Director
AD Office 11 – Telecommunications