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 March 26, 2025

William McCamey
Chief Financial Officer
Atlanticus Holdings Corporation
Five Concourse Parkway, Suite 300
Atlanta, GA 30328

 Re: Atlanticus Holdings Corporation
 Form 10-K for Fiscal Year Ended December 31, 2023
 Form 10-K for Fiscal Year Ended December 31, 2024
 Response Dated March 10, 2025
 File No. 001-40485
Dear William McCamey:

 We have reviewed your March 10, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our March 5,
2025 letter.

Form 10-K for Fiscal Year Ended December 31, 2024
Changes in Fair Value, page 25

1. We note your response to prior comment 1 and your statement that you
will revise
 future filings to include disclosure related to changes in fair value of
loans. We also
 note that this disclosure is not included in your subsequently filed
December 31, 2024
 Form 10-K. Please amend your December 31, 2024 Form 10-K to include
disclosure,
 similar to your proposed disclosure included in your response, to
quantify and discuss
 the underlying causes of each material loss or gain item impacting fair
value on a
 gross basis recognized within Changes in fair value of loans at fair
value, included in
 earnings.
 March 26, 2025
Page 2

Critical Accounting Estimates Measurements for Loans at Fair value, page 39

2. We note your disclosure that you forecast cash flows based on the
individual offer
 type or if two or more offer types share similar performance criteria
you aggregate
 those receivables into a single pool for evaluation and that for each
identified pool,
 valuation models are used to calculate a stream of expected cash flows
which are then
 discounted to derive a net present value. Please tell us in detail and
revise future
 filings to provide additional information regarding how many pools you
have, how
 they are determined, how often they are aggregated and whether they are
stratified by
 vintage. Additionally, clarify if you have specific assumptions for each
pool or
 whether you determine assumptions at the portfolio level. If you have
specific
 assumptions for each pool, please revise your discussion of the changes
in
 assumptions and the impact of these changes on fair value of loans,
included in
 earnings and disclosed on page 26, to focus on the changes of
assumptions at the pool
 level and its impact on fair value of loans, included in earnings as
opposed to the
 overall weighted-average measure of the assumption that does not
necessary explain
 the reasons for changes at the pool level and impact on earnings.

Note 3. Segment Reporting, page F-14

3. Please tell us the two operating segments that are aggregated into the
CaaS reportable
 segment. Additionally, please provide us your analysis detailing how
aggregation is
 consistent with the objective and basic principles of ASC 280-10, how
the segments
 have similar economic characteristics, and how the segments are similar
in the areas
 detailed in ASC 280-10-50-11. Specific to the two operating segments
having similar
 economic characteristics, please tell us in detail how you determined
each segment
 would have similar long-term financial performance and provide
quantified
 information detailing historical and current financial performance.
Please provide
 appropriate commentary to support your quantified information.
 Please contact William Schroeder at 202-551-3294 or Michael Volley at
202-551-
3437 if you have questions regarding comments on the financial statements and
related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
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