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SEC Company Response from ALTISOURCE PORTFOLIO SOLUTIONS S.A. (ASPS, ASPSW, ASPSZ) (CIK 0001462418) (ASPS) — Jul 20, 2009

ALTISOURCE PORTFOLIO SOLUTIONS S.A. (ASPS, ASPSW, ASPSZ) (CIK 0001462418)
Date: July 20, 2009 · CIK: 0001462418 · Accession: 0000950123-09-023616

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File numbers found in text: 001-34354

Date
July 21, 2009
Author
Altisource Portfolio Solutions S.A.
Form
CORRESP
Company
ALTISOURCE PORTFOLIO SOLUTIONS S.A. (ASPS, ASPSW, ASPSZ) (CIK 0001462418)

Letter

Re: Altisource Portfolio Solutions S.A.

SEC CORRESPONDENCE LETTER

July 20,

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-7010

Attention: Larry Spirgel, Assistant Director

Registration Statement on Form 10 (File No. 001-34354)

Ladies and Gentlemen:

In accordance with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended (the “Act”), Altisource Portfolio Solutions S.A. (the “Company”) hereby requests that the effective date of the above referenced Registration Statement be accelerated so that the Registration Statement, as then amended, will become effective under the Act by 5 p.m., New York City time, on July 21, 2009, or as soon thereafter as practicable.

In connection with the request for acceleration of the above-referenced Registration Statement, the Company hereby acknowledges that:

•

should the Securities and Exchange Commission (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;

•

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 disclosure in the filing; and

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

It would be appreciated if, as soon as the Registration Statement is declared effective, you would so inform the undersigned at (407) 737-5419.

Very truly yours,
Altisource Portfolio Solutions S.A.

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CORRESP
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SEC CORRESPONDENCE LETTER

July 20,
2009

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-7010

Attention: Larry Spirgel, Assistant Director

    Re: Altisource Portfolio Solutions S.A.

Registration Statement on Form 10 (File No. 001-34354)

Ladies and Gentlemen:

     In accordance with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as
amended (the “Act”), Altisource Portfolio Solutions S.A. (the “Company”) hereby
requests that the effective date of the above referenced Registration Statement be accelerated so
that the Registration Statement, as then amended, will become effective under the Act by 5 p.m.,
New York City time, on July 21, 2009, or as soon thereafter as practicable.

     In connection with the request for acceleration of the above-referenced Registration
Statement, the Company hereby acknowledges that:

    •

    should the Securities and Exchange Commission (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;

    •

    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 disclosure in the
filing; and

    •

    the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

     It would be appreciated if, as soon as the Registration Statement is declared effective, you
would so inform the undersigned at (407) 737-5419.

    Very truly yours,

    Altisource Portfolio Solutions S.A.

    By:

    /s/ Robert D. Stiles

    Name: Robert D. Stiles

Title: Chief Financial Officer

2015 Vaughn Road, Bldg 400 | Kennesaw, GA 30144