SecProbe.io

October 27, 2010
 J. Paul Whitehead, III Chief Financial Officer
CompuCredit Holdings Corporation
Five Concourse Parkway, Suite 400 Atlanta, GA  30328

Re: CompuCredit Holdings Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2009  Form 10-Q for the Quarterly Period Ended June 30, 2010  File No. 000-53717
Dear Mr. Whitehead:
 We have reviewed your response letter dated June 25, 2010 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 te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested  response.  If you do not believe our comments
apply to your facts and circumstances or do not believe future revisions are appropriate, please
tell us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
            December 31, 2008 Form 10-K

 Note 9. Fair Value of Assets, page F-33

1. We note your response to comment 7 in your letter dated June 25, 2010.  We could not
locate your disclosure of the information required by ASC 825-10-50-30.  Please revise
to disclose this information in future filings  or tell us where you disc lose the information.

5.875% Convertible Senior Notes Due 2035, page F-38

2. We note your response to comment 10 in your letter dated June 25, 2010.  Please revise
future filings to disclose the information included in your response to comments 10a and
10b.

J. Paul Whitehead, III CompuCredit Holdings Corporation October Page 2

3. We note your response to comment 10c in your  letter dated June 25, 2010.  Please revise
future filings to disclose the fair value of outstanding loaned shares as of the balance sheet date.
June 30, 2010 Form 10-Q

 Note 2. Significant Accounting Policies and Co ndensed Consolidated Financial Statement
Components
 Loans and Fees Receivable, page 7

4. We note your response to comments 13 and 16 in  your letter dated J une 25, 2010.  Please
revise future filings to repor t charge-offs related to receivables measured at fair value
using the fair value option in a line item se parate from the provision for loan losses on
loans measured at net realizable value.  Al so clearly discuss the relationship between the
charge-offs reported and the fair value adjust ments presented in fees and related income
on earning assets line item.

Investments in Previously Ch arged-Off Receivables, page 9

5. We note your response to comment 3 in your letter dated June 25, 2010 and your revised
disclosure.  Please tell us and include appropria te revisions in future filings to include the
following:
 a. Please clarify the basis for not eliminati ng upon consolidation the previously charged-
off receivables that you purchased from other subsidiaries.

b. Please clarify how amounts transferred to  credit cards under th e balance transfer
program are presented in this table and wh ere those amounts are disclosed subsequent
to being transferred under the program.
 You may contact Michael Volley, Staff Acc ountant, at (202) 551- 3437, or me at (202)
551-3851 if you have questions.
 Sincerely,

 Paul Cline Senior Accountant