Mail Stop 4561


								October 14, 2005


By U.S. Mail and facsimile to (952) 593-4733

William A. Houlihan
Executive Vice President and Chief Financial Officer
Metris Companies Inc.
10900Wayzata Boulevard
Minnetonka, MN  55305

Re:	Metris Companies Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
	File No. 001-12351

Dear Mr. Houlihan:

      We have reviewed your response letter dated October 4, 2005
and
have the following additional comments.

Form 10-K for the fiscal year ended December 31, 2004

Results of Operations, page 33

1. We note your supplemental response to comment 1 of our letter
dated September 23, 2005.  Please tell us your basis for
characterizing your borrowing to fund a maturing ABS series or
conduit as attributable to new securitizations of receivables to
the
Metris Master Trust.

2. Please tell us why you need to borrow on a new or existing
conduit
to fund a maturing ABS series or conduit facility.  Tell us who
initiates the transaction and the contractual provisions related
to
the maturing or termination of your ABS series and conduit
facilities.

3. Please provide us with a comprehensive example, including cash
flows, entities involved, journal entries and supporting
calculations, describing how you account for the defeasance of
maturing ABS series into your variable funding conduit.

4. Please tell us why you realize a gain with the establishment of
the interest-only receivable strip whereas the contractual
retained
interest and minimum spread reserve result in a loss.

5. We note your supplemental response to comment 3 of our letter
dated September 23, 2005.  Please tell us why you calculate the
gain/loss on replenishment of receivables on a monthly basis when
you
sell new credit card receivables to the Metris Master Trust on a
daily basis.

6. We note your supplemental response to comment 4 of our letter
dated September 23, 2005.  Please provide us with a comprehensive
example, including cash flows, entities involved, and supporting
calculations, describing the inception of a revolving credit card
securitization.  In your example, demonstrate how you allocate the
carrying amount of receivables securitized to your interest-only
strip, contractual retained interest, and spread reserve.

7. Please tell us how you evaluate your implicit forward contract
to
sell new receivables into the Trust during the revolving period.

Note 9 - Portfolio Sales, page 72

8. We note your supplemental response to comment 7 of our letter
dated September 23, 2005.  Please tell us why the OCC requested
you
to sell your deposits held by Direct Merchants Bank.

* * * * *

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response on EDGAR.  Detailed cover letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

      You may contact Matthew Komar (Staff Accountant) at (202)
551-
3781 or me at (202) 551-3449 if you have questions regarding
comments
on the financial statements and related matters.


      Sincerely,



      Joyce Sweeney
								Accounting Branch Chief

William A. Houlihan
Metris Companies Inc.
October 14, 2005
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