June 28, 2006


Mail Stop 4561

VIA U.S. MAIL AND FAX (949) 440-7033

Ms. Patti M. Dodge
Executive Vice President and
  Chief Financial Officer
New Century Financial Corporation
18400 Von Karman
Suite 1000
Irvine, CA  92612

      Re:	New Century Financial Corporation
      Form 10-K for the year ended December 31, 2005
      Filed March 16, 2006
      File No. 001-32314

Dear Ms. Dodge:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Please be as detailed as necessary in
your explanations.  In some of our comments, we may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  After reviewing this information, we may or may
not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2005

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

1. We note the following trends during 2005:

* The company had $80.2 million of mortgage loans held for sale on
non accrual status versus $23.4 million on non accrual status at
December 31, 2004, an increase of 243%.  Refer to page F-24.
* The company had $666.6 million of mortgage loans held for
investment on non accrual status versus $179.2 million at December
31, 2004, an increase of 272%. Refer to page F-26.

* The company uses a qualifying interest rate that is equal to the
initial interest rate on the loan to determine the applicant`s
ability to repay an adjustable-rate loan.

* For interest-only adjustable rate mortgage loans the company
generally uses the initial interest-only payment for determining
the
borrower`s repayment ability.  Refer to page 9.

* Originations of interest-only loans were 31% of total loan
originations during 2005 versus 19% of originations in 2004, a
considerable increase as noted by the company.  Refer to page 58.

* In the fourth quarter of 2005 the company changed its product
design to provide for an interest-only payment period for at least
the first five years following origination.  Previously under most
of
these interest-only mortgage loans the interest-only period
extended
for only the first two or three years. Refer to page F-26.

* While the allowance for losses for mortgage loans held for
investment increased during 2005 by approximately $108 million or
120%, the charge offs during the period increased $26 million or
415%.  Refer to pages F-26 and F-27.

Given the above as well as the increasing interest rate
environment,
please clarify to us what consideration you gave to discussing in
Management`s Discussion and Analysis the unfavorable trends and
effect on future operating results including expected increases in
the loan loss provision.  Refer to Item 303(a) (3) (ii) of
Regulation
S-K.  In addition, please clarify to us how these trends were
considered in the assessment of the adequacy of the loan loss
provision.

Note (1) Summary of Significant Accounting Policies

(u) Investment in Carrington, page F-20

2. Please clarify to us and in future filings disclose how the
change
in ownership of Carrington as a result of Carrington`s raising of
additional capital was accounted for.  In addition, please address
the other disclosures specified by SAB Topic 5H, Question 6.

Note (4) Residual Interests in Securitizations, page F-27

3. Please advise us and revise your disclosure in future filings
to
explain the form of residual interest that you retain in your
securitization transactions referenced here, how such interests
are
initially and subsequently valued and how you characterize and
define
these residual interests disclosed in this note.  In this regard,
please clarify the individual components of your residual
interests,
such as retained interests or interest-only strips, and how you
account for such residual interests in accordance with SFAS 115.
Refer to paragraph 14 of SFAS 140.  Finally, please tell us what
consideration you gave to the disclosures specified by paragraphs
17(e)(3) and 17(f)(3) of SFAS 140.

Note (5) Mortgage Servicing Assets, page F-29

4. Tell us what consideration you gave to providing the
sensitivity
analysis for servicing assets as required by paragraph 17(g)(3) of
SFAS 140.


*  *  *  *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.









	You may contact Joshua S. Forgione, at (202) 551-3431, or me,
at
(202) 551-3780, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,



      Linda van Doorn
      Senior Assistant Chief Accountant
Ms. Patti M. Dodge
New Century Financial Corporation
June 28, 2006
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