August 7, 2015

Mail Stop 4546

Via Email
Mr. Jason A. Kulas
Chief Executive Officer
Santander Consumer USA Holdings Inc.
1601 Elm Street, Suite 800
Dallas, TX 75201

       Re:    Santander Consumer USA Holdings Inc.
              Form 10-K for the Fiscal Year Ended December 31, 2014
              Filed March 2, 2015
              File No. 001-36270

Dear Mr. Kulas:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2014

Item 7 - Management's Discussion and Analysis of Financial Condition and
Results of
Operations, page 36

Credit Quality, page 50

1.     Please provide a breakdown of the typical maturity periods for each
category of your loan
       and other finance receivables categories.

Deferrals and Troubled Debt Restructurings, page 52

2.     We note your disclosure on page 88 that you consider troubled debt
restructurings
       (TDRs) to include all individually acquired retail installment contracts
that have been
       modified at least once, deferred for a period of 90 days or more, or
deferred at least twice,
 Mr. Jason A. Kulas
Santander Consumer USA Holdings
August 7, 2015
Page 2

       as well as all restructurings through bankruptcy proceedings. Please
respond to the
       following:
            We note that you disclose the number of deferrals provided on your
retail
               installment contracts on page 52, and then separately
information about loans that
               have received modifications involving things such as reduction
in interest rate or
               reduction in loan principal balance, etc. per your table on page
53. Please clarify
               whether in all cases the loans receiving the modifications in
the table on page 53
               are classified as TDRs.
            We note your disclosure that changes in deferral levels do not have
a direct impact
               on the ultimate amount of consumer finance receivables charged
off by you, but
               the timing of the charge off may be affected. Please tell us and
expand your
               disclosure to discuss how your provisioning methodology is
capturing the risk of
               future default at the time the earlier deferrals are granted.

3.     We note your statement that your policies and guidelines limit the
number and frequency
       of deferrals to one every six months and eight months over the life of
the loan. Please
       respond to the following to clarify in further detail how this policy
works in operation:
            Tell us whether this means the maximum amount of deferral a
borrower can
               receive in a six-month period is three months, and then whether
the borrower
               would have to wait six months after that three-month deferral
period is over
               before they could request a new deferral, or whether they could
request the
               deferral three months after the three-month deferral period.
            In situations where a one-or-two month deferral period is
originally granted, tell
               us whether you would grant another one-or-two month deferral
period within six
               months, or whether that original deferral of less than three
months would be
               limited to that deferral given your policy to limit deferrals to
one every six
               months.
            In regards to the eight months over the life of the loan, clarify
whether this means
               the maximum number of monthly payments that could be deferred
over the life of
               the loan is eight payments. Clarify whether this is your policy
regardless of the
               term of your retail installment contracts.
            We note a significant amount of retail installment contacts are
categorized in the
               deferred 3-4 times category. Please tell us whether the deferral
periods are
               typically granted three months at a time, one month a time, or
whether it may
               depend on the number of prior deferrals the borrower has already
been offered.

Notes to Consolidated Financial Statements, page 75

Note 4   Loan and Lease Allowance and Credit Quality, page 85

4.     In light of the significant volume of transactions accounted for as
TDRs, please revise
       future filings to provide a rollforward of the balance during the
period, with specific
       quantification of new TDRs, paydowns, charge-offs, and sales.
 Mr. Jason A. Kulas
Santander Consumer USA Holdings
August 7, 2015
Page 3

5.      We note your disclosure on page 90 that a TDR is considered to have
subsequently
        defaulted upon charge-off, which for retail installment contracts is at
the earlier of the
        date of repossession or 120 days past due. However, in light of the
fact that the vast
        majority of your TDRs appear to be due to deferrals, tell us how this
policy captures the
        fact that you may grant a 90 day deferral which is considered a TDR,
but then a
        subsequent deferral is needed.


         We urge all persons who are responsible for the accuracy and adequacy
of the disclosure
in the filing to be certain that the filing includes the information the
Securities Exchange Act of
1934 and all applicable Exchange Act rules require. 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 responding to our comments, please provide a written statement from
the company
acknowledging that:

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

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

       You may contact Svitlana Sweat at (202) 551-3326 or me at (202) 551-3512
with any
questions.


                                                             Sincerely,

                                                             /s/ Stephanie
Ciboroski

                                                             Senior Assistant
Chief Accountant
                                                             Office of
Financial Services II