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    O   L   S   H   A   N

1325 AVENUE OF THE AMERICAS ● NEW YORK, NEW YORK 10019

TELEPHONE: 212.451.2300 ● FACSIMILE: 212.451.2222

EMAIL:  AFREEDMAN@OLSHANLAW.COM

DIRECT DIAL:  212.451.2250

June 18, 2025

VIA EDGAR AND ELECTRONIC MAIL

Laura McKenzie

Perry Hindin

Office of Mergers & Acquisitions

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3628

100 F Street, NE

Washington, D.C. 20549

 Re: Findell Capital Management LLC

Oportun Financial Corp

Additional Soliciting Material filed June 3 and June 5, 2025, by Findell Capital Management LLC et al.

File No. 001-39050

Dear Ms. McKenzie and Mr. Hindin:

We acknowledge receipt
of the comment letter of the Staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”), dated
June 16, 2025 (the “Staff Letter”), with regard to the above-referenced matters. We have reviewed the Staff Letter with Findell
and provide the following responses on Findell’s behalf. For ease of reference, the comments in the Staff Letter are reproduced
in italicized form below.

General

 1. The letter to shareholders issued on June 3, 2025, and filed as additional soliciting material states
that:

 · “legacy directors who control the majority of the Board have no lending experience and share
close personal and professional ties with CEO Raul Vazquez”;

 · “Mr. Vazquez has worked to destroy a great lending business”;

 · “the Board’s self-defeating and entrenching behavior has made it clear to us that the main
goal of the legacy directors is not delivering stockholder value, but preventing industry experience and independence from having a real
voice in the boardroom”;

 · “management decisions would have bankrupted the Company without Findell’s involvement”;
and

 · “[a]mong the legacy Board members, there are many overlapping personal and professional relationships
with each other and with CEO Vazquez that raise serious questions about the ability of these directors to provide appropriate oversight.
For example, Mr. Vazquez is a board member of Intuit and oversaw Mr. Williams and Ms. Lee in that capacity.”

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Such statements appear to impugn the
character, integrity and personal reputation of Mr. Vazquez and the Board without adequate factual foundation. Please do not use these
or similar statements in soliciting materials without providing a proper factual foundation for the statements. 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 note that characterizing a statement as one’s opinion or
belief does not eliminate the need to provide a proper factual foundation for the statement; there must be a reasonable basis for each
opinion or belief that the filing persons express. Please refer to Note (b) to Rule 14a-9.

Findell acknowledges the
Staff’s comment and provides the following information on a supplemental basis.

Findell believes each of
the above-referenced statements has a proper factual foundation and the opinions expressed in such statements are reasonable in light
of this foundation. Specifically, with respect to each of the statements identified by the Staff:

 · “legacy directors who control the majority of the Board have no lending experience and share
close personal and professional ties with CEO Raul Vazquez”;

Findell respectfully submits
that, based on the proxy statement filed by Oportun Financial Corporation (“Oportun” or the “Company”) with the
SEC on May 28, 2025 (the “Oportun Proxy Statement”), the board of directors (the “Board”) of Oportun currently
consists of ten members, six of whom, constituting a majority, have tenures longer than one year, and whom Findell identifies in all of
its soliciting materials as “legacy directors”: Raul Vazquez (13 years), Jo Ann Barefoot (11 years), R. Neil Williams (8 years),
Louis Miramontes (4 years), Ginny Lee (4 years) and Sandra Smith (4 years). Based on the biographical information provided by the Oportun
Proxy Statement and information published by the directors on their LinkedIn profiles and as noted by Findell in its letter of June 3,
2025 (the “June 3 Letter”), none of these six directors have a background working in consumer lending. Specifically, prior
to Oportun, Mr. Vazquez worked at Walmart Inc., a retail business; Ms. Barefoot founded the nonprofit Alliance for Innovative Regulation,
an organization focused on building regulatory technology capacity in emerging economies, co-founded Hummingbird RegTech, a risk and compliance
platform servicing banks and fintech businesses, and served as CEO of Barefoot Innovation Group, which focuses on technology and regulation
in the U.S. and globally; Mr. Williams served as CFO at Intuit Inc. (“Intuit”), a global technology platform known for financial
management and tax preparation software; Mr. Miramontes served as a senior partner at KPMG LLP, a public accounting firm; Ms. Lee worked
at Khan Academy, a digital learning platform, and Intuit; and Ms. Smith served as CFO of Segment.io, a customer data platform. None of
these experiences fall within the realm of the consumer lending industry.

Findell further submits
that, as noted in the June 3 Letter and as described in detail in its proxy statement filed with the SEC on May 29, 2025 (the “Findell
Proxy Statement”), based on public filings made by Intuit and the LinkedIn profiles of members of the Board, Mr. Vazquez served
on the board of directors of Intuit while Mr. Williams served as Intuit’s CFO, and Ms. Lee worked for Intuit in a variety of roles
reporting to Mr. Williams as CFO, and was overseen by Mr. Vazquez in his capacity as a director. Further, as described in the Findell
Proxy Statement, based on an article published by The Wall Street Journal and material published on Ms. Barefoot’s website for her
podcast, Intuit acquired social media marketing start-up FlowTown in 2012, and in 2016, Ms. Barefoot interviewed FlowTown founder Ethan
Bloch on her podcast, further indicating a web of relationships between four of the six directors whose tenure exceeds one year, with
Mr. Vazquez appearing in a central position of that web.

    Page 3

Findell respectfully submits
that, based on these facts, it is reasonable to conclude, as Findell has, that the majority of the Board is controlled by legacy directors
who lack experience in consumer lending and maintain interconnected professional relationships, including ties to Mr. Vazquez.

 · “Mr. Vazquez has worked to destroy a great lending business”;

Findell respectfully submits
that, during Mr. Vazquez’s tenure as CEO of Oportun, the price of its stock has dropped from an initial public offering price of
$15 per share to its current trading range between approximately $4.00 to $7.00 per share. Findell further notes the increasing operating
expenses (“OpEx”) of Oportun during this time and the increase in net charge-offs, as identified and described in the June
3 Letter, and respectfully submits that this negative shareholder return, when considered alongside these deteriorating operating results,
would permit an observer to reasonably conclude that the CEO responsible for these results had “destroyed” such a business,
particularly where, as here, Findell believes and has expressed the view that Oportun’s lending business has significant unrealized
potential that has not been reflected in its financial performance or operational execution.

 · “the Board’s self-defeating and entrenching behavior has made it clear to us that the main
goal of the legacy directors is not delivering stockholder value, but preventing industry experience and independence from having a real
voice in the boardroom”;

Findell respectfully submits
that Scott Parker, the director whose removal from the Company’s slate of director candidates for election at the 2025 annual meeting
it is criticizing here, had a background in consumer lending, having previously worked at OneMain Holdings, Inc. (“OneMain”),
a consumer lending company and peer of Oportun. Further, Findell notes that Mr. Parker was appointed to the Board in April 2024 pursuant
to a cooperation agreement between the Company and Findell, and that during Mr. Parker’s tenure on the Board, the stock price of
Oportun rose significantly, resulting in a total stockholder return of approximately 190%. Findell also notes that Oportun announced Mr.
Parker’s removal from its slate on May 7, 2025, well after Findell began its public proxy campaign at the Company, which had repeatedly
emphasized insufficient consumer lending expertise and lack of shareholder focus on the Board.

Findell respectfully submits
that, in light of these facts, it was reasonable to characterize the removal of Mr. Parker as “self-defeating” (since, in
Findell’s opinion, it deprives the Board of a valuable and experienced asset who has driven demonstrable results) and “entrenching”
(since it targeted a Findell-supported director and appeared to result from Findell’s engagement at the Company agitating for further
governance change), and to conclude that it may have been driven by the motivations it attributes to the Board, since Mr. Parker represents
both industry experience and, as a stockholder-backed director added only last year, independence from management and the incumbent Board.
Therefore, his absence in the boardroom would predictably result in less of both.

 · “management decisions would have bankrupted the Company without Findell’s involvement”;
and

Findell respectfully submits
that its concerns regarding potential bankruptcy were motivated by the 129% increase in OpEx per loan origination from 2019 to 2023, combined
with the $211 million expense of the acquisition of Hello Digit Inc. (“Digit”) in 2021 and subsequent $108 million goodwill
write-down in 2022 and the precipitous decline in stock price to a low of approximately $2.18 in April 2024 (a year after Findell began
its engagement in March 2023, as noted in the June 3 Letter). Specifically, if the increase in OpEx per loan continued to grow, and if
further acquisition expenses and write-downs occurred, continuing a trend established by Digit, the rise in the Company’s costs
would rapidly outpace its ability to finance its operations. Further, the dramatic drop in stock price would have resulted in an increased
cost of capital, making it more difficult for the Company to acquire the financing necessary to continue its operations. Under these circumstances,
Findell respectfully submits that insolvency and bankruptcy are not unreasonable potential outcomes.

    Page 4

 · “[a]mong the legacy Board members, there are many overlapping personal and professional relationships
with each other and with CEO Vazquez that raise serious questions about the ability of these directors to provide appropriate oversight.
For example, Mr. Vazquez is a board member of Intuit and oversaw Mr. Williams and Ms. Lee in that capacity.”

Findell respectfully refers
to the facts identified above with respect to the connections between Mr. Vazquez, Mr. Williams, Ms. Lee and Ms. Barefoot, and expresses
its belief that, on the basis of these facts, it was not unreasonable to suggest that it had serious questions about the ability of certain
members of the Board to provide oversight of Mr. Vazquez, the CEO.

Additional Soliciting Material filed June
5, 2025

Item 1

 2. We note the following statements:

 · "Ms. Lee and the Rest of the Legacy Directors Have Overseen Massive Value Destruction and Lack
Lending Experience, Making Them Underqualified to Serve as Lead Independent Director";

 · "the legacy directors [ ] collectively appear interested only in entrenching themselves and ignoring
the best interests of Oportun"; and

 · "these legacy directors are unqualified to serve on this board, let alone serve as lead independent
director."

Refer to our prior comment above. Please
do not use these or similar statements in your filings without providing a proper factual foundation. Please refer to filing persons'
obligations under Exchange Act Rule 14a-9.

Findell acknowledges the
Staff’s comment and provides the following information on a supplemental basis.

Findell believes each of
the above-referenced statements has a proper factual foundation and the opinions expressed in such statements are reasonable in light
of this foundation. Specifically, with respect to each of the statements identified by the Staff:

 · "Ms. Lee and the Rest of the Legacy Directors Have Overseen Massive Value Destruction and Lack
Lending Experience, Making Them Underqualified to Serve as Lead Independent Director"

Findell respectfully submits
that the negative stockholder returns to which it refers above and which it identifies in its letter of June 5, 2025 (the “June
5 Letter”) as corresponding to each of the directors it refers to as “legacy directors” provide a factual foundation
making it reasonable to state that such directors have overseen “massive value destruction”. Specifically, since Mses. Lee
and Smith joined the Board in 2021, the total stockholder return as calculated by Findell based on the stock price over that period has
been approximately negative 74%; while Ms. Barefoot and Messrs. Miramontes, Vazquez and Williams, all of whom have served on the Board
since the initial public offering of Oportun stock, served on the Board during a period in which the total stockholder return has been
approximately negative 58%. Findell further refers to its description of the respective backgrounds of each of Mses. Barefoot, Lee and
Smith and Messrs. Miramontes, Vazquez and Williams, as described above, which Findell respectfully submits provide a factual foundation
sufficient to conclude that these directors “lack lending experience.”

    Page 5

Finally, Findell respectfully
submits that directors whose tenure corresponds to significantly negative stockholder returns and who lack industry-specific experience
that it reasonably believes valuable in overseeing the management of a business in a specific industry might reasonable be considered
 “underqualified” particularly in respect of serving as a Lead Independent Director, a leadership role in the Boardroom that
a stockholder could reasonably expect to have a significant impact on the decisions of the Board regarding oversight and the resulting
returns to stockholders.

 · "the legacy directors [ ] collectively appear interested only in entrenching themselves and ignoring the best interests of
Oportun”

Findell respectfully submits
that, as described in the Findell Proxy Statement and its other solicitation materials, Findell has engaged in extensive conversation
and negotiation with Oportun seeking a negotiated settlement that avoids changes to the composition of the Board. Specifically, Findell
has requested that Oportun commit to placing directors with experience working in the consumer lending industry in positions of leadership
on the Board, including the role of Lead Independent Director. Findell respectfully submits that it is reasonable for a stockholder to
believe that placing directors with industry-specific experience in leadership roles would be in the “best interests” of the
Company, and that members of a Board who reject such requests in favor of waging a proxy contest to retain the Board seat of one of their
own, as Oportun has done, might reasonably appear to be placing the value of “entrenching themselves” – which is to
say retaining their Board seats and leadership positions in the Boardroom – over the ”best interests of Oportun” which
Findell believes would be served by the governance changes it has requested.

 · "these legacy directors are unqualified to serve on this board, let alone serve as lead independent direc