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 May 14, 2025

Brian Finn
Chief Investment Officer
Findell Capital Management LLC
88 Pine Street, 22nd Fl.
New York, NY 10005

 Re: Findell Capital Management LLC
 Oportun Financial Corp
 Preliminary Proxy Statement filed May 7, 2025, by Findell Capital
Management
 LLC, Findell Capital Partners LP, Finn Management GP LLC, Brian
Finn, and
 Warren Wilcox
 File No. 001-39050
Dear Brian Finn:

 We have reviewed your filing 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 these comments by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comments
apply to your
facts and circumstances, please tell us why in your response.

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

Preliminary Proxy Statement filed May 7, 2025
Reasons for the Solicitation, page 13

1. We note your statement in the fourth bullet on page 14 that you "believe
Oportun
 should be able to achieve 8-10% pre-tax ROA." Please describe how you
reached this
 conclusion, including a description of any assumptions and specific
citations to
 underlying information.
2. We note that the disclosure in the first paragraph on page 16 regarding
the Company's
 acquisition of Digit appears to impugn the character, integrity and
reputation of the
 Board without adequate factual foundation. Please do not use these or
similar
 statements without providing a proper factual foundation for the
statements.
 Statements that purport to know the motivation or intent of another
soliciting party
 may be difficult to support and should be reconsidered, absent adequate
factual
 May 14, 2025
Page 2

 foundation. In addition, as to matters for which the filing persons do
have a proper
 factual foundation, please avoid making statements about those matters
that go
 beyond the scope of what is reasonably supported by the factual
foundation. Please
 refer to Note (b) to Rule 14a-9. Please revise your proxy statement
accordingly
 and refrain from including such statements in future materials.

Solicitation of Proxies, page 28

3. Please fill in the blanks in this section.
General

4. Please revise your proxy statement in light of the changes to the Board
announced by
 the Company in its press release dated May 7, 2025, and subsequently
filed as
 soliciting materials on May 8, 2025.
5. Please disclose which Company nominee you do not oppose and explain why
you
 have chosen not to oppose such nominee instead of another Company
nominee.
6. We note that on page 2 you refer to both a white voting instruction form
and a gold
 voting instruction form. Please revise to ensure all proxy materials are
described
 consistently throughout your proxy statement.
 We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.

 Please direct any questions to Laura McKenzie at 202-551-4568 or Perry
Hindin at
202-551-3444.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers &
Acquisitions
cc: Andrew Freedman
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