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    1655 Grant Street, 10th Floor

     Concord, CA 94520

July 15, 2024

Via EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, N.E.

Washington, D.C. 20549-3720

    Attention:
    John Cannarella

    Gus Rodriguez

    Re:
    AssetMark Financial Holdings, Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2023

    Filed March 14, 2024

    File No. 001-38980

Ladies and Gentlemen:

AssetMark Financial Holdings, Inc. (“AssetMark”,
the “Company”, “we”, “us” or “our”) submits this letter in response to a comment from
the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) received by letter dated July
3, 2024 (the “Comment Letter”) relating to the Company's Form 10-K for the fiscal year ended December 31, 2023 filed on March
14, 2024.

In this letter, we have recited the comment from
the Staff in bold and italicized type and have followed it with the Company's response.

Form 10-K for the Fiscal Year Ended December
31, 2023

Management’s Discussion and Analysis of Financial Condition
and Results of Operations, page 54

 1. We note your disclosures on pages 52 and 54 indicating that your asset-based revenues are derived from fees charged as a percentage
of platform assets, and attributing the increase in asset-based revenue during 2023 to higher incremental average assets although without
addressing the effects associated with changes in prices.

Please expand your disclosures to report the extent
to which changes in your asset-based revenues are attributable to changes in prices and separately to changes in volumes, to comply with
Item 303(b)(2)(iii) of Regulation S-K.

For example, this may involve quantifying the extent
to which the variances in asset-based revenues are attributable to (i) changes in the weighted average fees charged as a percentage of
platform assets, (ii) changes in the average platform assets and, if applicable, (iii) changes in other factors such as product mix.

Response: We acknowledge the Staff's comment
and respectfully advise the Staff that the fees (prices) we charge have not increased in the recent past and accordingly none of the period-to-period
increase in 2023 was due to price increases. Our higher asset-based revenue is due to an increase in average platform assets as our disclosure
indicates. With respect to the fee rate we charge (the price), the industry has in fact experienced, to some degree, a general downward
pressure on fees over the last several years as larger volume clients negotiate lower fees and lower cost investment alternatives are
made available in the marketplace. We expect that future changes in asset-based revenue will continue to be driven by the total assets
on the platform rather than changes in the prices we charge. However, if changes in prices were to have a meaningful impact on asset-based
revenue in future periods, we will reflect that in the appropriate disclosure for that period.

*****

    1655 Grant Street, 10th Floor

 Concord, CA 94520

In connection with our response to the Staff's
comment, we acknowledge that the Company and its management are responsible for the accuracy and adequacy of its disclosures, notwithstanding
any review, comments, action or absence of action by the Staff.

Please direct any questions or comments regarding
this letter to the undersigned at 925-521-2790 or gary.zyla@assetmark.com.

    Sincerely,

    /s/ Gary Zyla

    Gary Zyla

    Chief Financial Officer

  cc:
  Ted Angus

  AssetMark Financial Holdings, Inc.

  Alan F. Denenberg

  Davis Polk & Wardwell LLP