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CORRESP
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CORRESP

 July 5, 2012

 FOIA CONFIDENTIAL TREATMENT REQUESTED

 This letter omits confidential information
included in the unredacted version of this letter

 that was delivered to the Staff. Redacted information is reflected with an
“*.”

 VIA EDGAR AND FEDERAL EXPRESS

 United States Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E.

 Washington, D.C. 20549

 Attn: John P. Nolan

Re:
CompuCredit Holdings Corporation

Form 10-K for the period ended December 31, 2011

Filed March 6, 2012

Form 10-Q for the period ended March 31, 2012

Filed May 10, 2012

File No. 000-53717

 Dear Mr. Nolan:

 This letter is being submitted in response to the comments provided by the Staff of the Division of Corporation Finance of the
United States Securities and Exchange Commission (the “SEC”) set forth in your letter dated June 21, 2012 (the “Comment Letter”) to J.Paul Whitehead, III, Chief Financial Officer of CompuCredit Holdings Corporation (the
“Company”), with respect to the above-referenced SEC filings.

 We are authorized by the Company to provide the
responses contained in this letter on its behalf. The terms “we,” “us,” and “our” in the responses refer to the Company. For your convenience, we set forth each comment from the Comment Letter in bold typeface and
include the Company’s response below it. The numbered paragraphs in this letter correspond to the numbered paragraphs of the Comment Letter. We also are sending a courtesy copy of this letter to you by Federal Express.

Because of the commercially sensitive nature of certain information contained herein, this submission is accompanied by a request for
confidential treatment for a portion of this letter. We have filed a separate letter with the Office of Freedom of Information and Privacy Act Operations (the “FOIA Office”) in connection with the confidential treatment request, pursuant
to Rule 83 of the SEC’s Rules on Information and Requests [17 C.F.R. § 200.83] (“Rule 83”).

 Confidential Treatment Requested by CompuCredit Holdings Corporation

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 For the Staff’s reference, we have enclosed a copy of our letter to the FOIA Office (the “Request”) with this copy of the correspondence marked to show the portions redacted from the
version filed via EDGAR and for which the Company is requesting confidential treatment.

 In accordance with Rule 83, the
Company requests confidential treatment of (a) the marked portions (the “Confidential Information”) of this response letter (this “Letter”) and (b) the accompanying Request (collectively, the “Confidential
Material”). Please promptly inform the undersigned of any request for disclosure of the Confidential Material made pursuant to the Freedom of Information and Privacy Act or otherwise so that the undersigned may substantiate the Request for
confidential treatment in accordance with Rule 83.

 In accordance with Rule 83, this Letter also has been clearly marked with
the legend “Confidential Treatment Requested by CompuCredit Holdings Corporation” and each page is marked for the record with the identifying numbers and code “CHC – 001” through “CHC – 010.”

December 31, 2011 Form 10-K

General

1.
Please tell us in detail and revise future filings to present financial information in your MD&A related to your coal mining operation. Additionally, please
revise your financial statements in future filings to disclose your accounting policies related to your coal mining operation and tell us how you considered whether these activities represent a reportable segment.

Company Response:

 Our coal mining operation does not represent a material aspect of our business, and we do not believe that further discussion of this operation would be meaningful to the readers of our financial
statements. The notes to the financial statements provide on page F-7 of the Form 10-K as follows:

 One such investment was a
lending arrangement to a start-up coal strip mine operation located in the state of Alabama, and in late 2011, the lending arrangement was modified to give us a controlling interest in the entity, resulting in its consolidation onto our financial
statements as of December 31, 2011.

 This investment represents a non-core operation of our specialty
finance business, the consolidation of this operation results exclusively as a result of a debt work-out, and the operation currently is not expected to be a meaningful ongoing operation for us. As of December 31, 2011, the coal mining
operation owed $3.5 million in principal under its

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outstanding note payable to us. Because of the work-out status of this note, we currently are consolidating the coal mining
operation’s $2.0 million of total assets as of December 31, 2011, which represented 0.3% of our total assets on that date. Further, the operation is not producing any meaningful revenues, and its results of operations represent less than
0.4% of our combined reported profit of all operating segments that did not report a loss.

 When determining
whether the coal mining operation represented a segment, we followed the guidance prescribed by ASC 280-10-50-1, which states that an operating segment must have the following three characteristics:

a.
It engages in business activities from which it may earn revenues and incur expenses (including revenues and expenses relating to transactions with other components of
the same public entity).

b.
Its operating results are regularly reviewed by the public entity’s chief operating decision maker to make decisions about resources to be allocated to the segment
and assess its performance.

c.
Its discrete financial information is available.

 Although the coal mining operation does have the characteristics set forth in (a) and (c) above, it is lacking the characteristic set forth in (b) above. Given that the operation represents
a work-out loan that is not material to our overall specialty finance business and is not an operation with respect to which we expect to have long-term involvement, its operating results are not regularly reviewed by our chief operating decision
maker. Further, the investment would not meet the quantitative thresholds prescribed in ASC 280-10-50-12 as referenced above.

 We intend to continue to monitor the coal mining operation and to increase disclosures associated with the operation (including providing separate segment disclosures as applicable) at such time, if any,
that it becomes material to our financial statements.

 Adjusted Charge-Off Ratio, page 21

2.
Your adjusted charge-off ratio appears to be a non-GAAP financial measure as defined by Item 10(e) of Regulation S-K. Please revise future filings to:

a.
Clearly label this financial measure as non-GAAP;

b.
Provide a reconciliation to the most directly comparable financial measure presented in accordance with GAAP for all periods presented; and

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c.
Disclose the reasons why you believe this presentation provides useful information to investors and specify how management uses this measure.

 Company Response:

 We do not believe that our adjusted charge-off ratio is a non-GAAP financial measure. The Company corresponded with the Staff about this matter in 2002 and 2003. (See our comment letter response dated
April 22, 2003.) The Company also received a similar comment from the Staff in a letter dated September 6, 2007. In our response letter dated September 27, 2007, the Company communicated the results of its 2002 and 2003 dialogue with
the Staff and the rationale for conclusions that the adjusted charge-off ratio (and other similar financial, operating and statistical ratios included in the Company’s Credit Cards Segment and Auto Finance segment tabular data within
management’s discussion and analysis of the Company’s results) is not a non-GAAP financial measure. In neither of our prior interactions with the Staff did the Staff express any further disagreement with our determination that our adjusted
charge-off ratio was not a non-GAAP financial measure.

 Under Rule 101(a)(2) of Regulation G, a non-GAAP
financial measure does not include “operating and other financial measures and ratios or statistical measures” calculated using GAAP financial measures and operating and other non-GAAP financial measures. Our adjusted charge-off ratio
falls within this exception from the definition of non-GAAP financial measure. Essentially, the adjusted charge-off ratio is calculated by dividing the accounting basis of principal receivables charged off (i.e., such basis reflecting discounted
purchase prices of certain purchased receivables portfolios) by average managed receivables for the quarter. The accounting basis of principal receivables charged off is a GAAP financial measure that is used to determine two line items on the
Company’s consolidated statements of operations: (1) the Provision for losses on loans and fees receivable recorded at net realizable value; and (2) Losses upon charge off of loans and fees receivable recorded at fair value.

 Because we operate in the financial industry, some of the relevant measures of productivity and effectiveness
regularly will be dollar-denominated and financial in nature. Nonetheless, as with measures of productivity and effectiveness in other industries, the adjusted charge-off ratio is an operating and financial measure and ratio or statistical measure
determined as permitted by Rule 101(a)(2). Our adjusted charge-off ratio is analogous to the per mile cost of a seat for an airline or a cost per unit produced for a manufacturer—both of which are based upon underlying GAAP data combined with
other data.

 Further, we believe that the adjusted charge-off ratio also is not non-GAAP because of the
exception provided by Rule 101(a)(3) of Regulation G, which excludes from the definition of non-GAAP Financial Measures “financial measures required to be

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disclosed by . . . Commission rules. . . .” Full disclosure of our financial performance requires, or at least may require, the
inclusion of this ratio. We believe this is consistent with the SEC’s stated position that merely providing GAAP information may not be sufficient. We believe that Rule 10b-5 requires, or at least may require, disclosure of the adjusted
charge-off ratio, thereby bringing it within the exclusion from the definition provided in Rule 101(a)(3). We believe that this ratio is necessary for readers to compare our financial performance to that of our credit card and auto finance peer
groups. Thus, certain readers of our financial statements would consider this ratio material to an understanding of our financial performance.

 Because we do not believe that our various MD&A financial, operating, and statistical tabular data are non-GAAP measures, we do not believe that Item 10 of Regulation S-K is applicable.

 Note 2. Significant Accounting Policies and Consolidated Financial Statement Components – Investments in Previously Charged-Off
Receivables, page F-10

3.
Please revise future filings to clarify how you recognize revenue on a portfolio after cash collections exceed your investment. For example, do you recognize revenue
on a cash, accrual, or some other basis.

 Company Response:

In future filings we will revise the language to read as follows:

Further, we record each static pool at cost and account for each pool as a single unit for payment application and income recognition
purposes, thereby applying the cost recovery method on a portfolio-by-portfolio basis. Under the cost recovery method, we do not recognize income associated with a particular portfolio until cash collections have exceeded the investment. Once cash
collections exceed each particular static pool investment, we include them in revenue as we receive them. These revenues are included in our Fees and related income on earning assets in the accompanying statement of operations.

Note 6. Investments in Equity-Method Investees, page F-19

4.
Please tell us in detail and revise future filings to fully and clearly disclose all the relevant facts and circumstances related to your 50.0% interest in a joint
venture that in March 2011 purchased the outstanding notes issued out of your U.K. portfolio structured financing trust at fair value. Your response to us and your disclosure should include, but not be limited to, the following information:

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-
Whether your joint venture partner is a related party and if so, the name the related party.

-
The face value and estimated fair value of the notes purchased and how the price of the notes was determined.

-
The amount of notes purchased that were held by related parties.

-
The nature of and estimated fair value of consideration provided to the holders of the notes. We note on page F-32, you disclose that no consideration was paid for
the notes.

-
You disclose the joint venture purchased the notes at fair value in the quarter ended March 31, 2011 and subsequently recognized a $34.2 million gain in the
same quarter. Please explain in detail why the fair value of the notes increased so significantly shortly after you purchased them.

 Company Response:

 In future filings we will disclose the
following within our Investments in Equity-Method Investees section:

 We also use the equity method to account for our March
2011 investment to acquire a 50.0% interest in a joint venture with an unrelated third party that purchased all $164.0 million in face amount) of the outstanding notes issued out of the structured financing trust underlying our U.K. portfolio of
credit card receivables (the “U.K. Portfolio”) for a discounted purchase price of $64.5 million in cash, a price that the joint venture partners determined to be attractive based on a discounted cash flow analysis of the remaining expected
payments on the notes (all of which were allocable to the class “A” portion of the outstanding notes given that no payments were expected associated with the class “B” portion of the outstanding notes thereby rendering them
worthless). At the time of their acquisition by the joint venture, we carried the notes as a liability on our consolidated balance sheet at their fair value of $98.7 million. The 50.0%-owned joint venture elected to account for its investment in the
U.K. Portfolio structured financing notes at their fair value, and it recognized a $34.2 million gain (of which our 50% share represented $17.1 million) in the three months ended March 31, 2011 equal to the excess of the fair value of the notes
at that date over the joint venture’s discounted purchase price of the notes. We record our respective interests in the income or losses of our equity-method investees within the equity in income (loss) of equity-method investees category on
our consolidated statements of operations.

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With respect to the Staff’s comment regarding “no consideration was paid for the notes” above, this
particular disclosure on page F-32 of the Form 10-K is directed toward class “B” notes issued out of the U.K. Portfolio structured financing trusts and held in part by certain related parties (as discussed in detail in Note 18,
“Related Party Transactions,” to our consolidated financial statements on page F-33 of the Form 10-K