COMPUCREDIT HOLDINGS CORPORATION

July 5, 2012

VIA EDGAR AND FEDERAL EXPRESS

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: John P. Nolan

Re: CompuCredit Holdings Corporation

Form 10-K for the period ended December 31, 2011

Filed March 6, 2012

Form 10-Q for the period ended March 31, 2012

Filed May 10, 2012

File No. 000-53717

CompuCredit Holdings Corporation (the “Company”) acknowledges that:

• The Company is responsible for the adequacy and accuracy of the disclosure in its filings under the Securities Exchange Act of 1934, as amended;

• Staff comments or changes to disclosure in response to Staff comments do not foreclose the Securities and Exchange Commission (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.

Sincerely yours,

/s/ J.Paul Whitehead, III

J.Paul Whitehead, III

Chief Financial Officer