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                          September 8, 2020

       James Shanahan
       Chief Financial Officer
       Focus Financial Partners Inc.
       875 Third Avenue, 28th Floor
       New York, New York 10022

                                                        Re: Focus Financial
Partners Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 25,
2020
                                                            File No. 001-38604

       Dear Mr. Shanahan:

              We have reviewed your August 18, 2020 response to our comment
letter 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 10 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. Unless we note otherwise, our references to prior comments are
to comments in our
       July 28, 2020 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       How We Evaluate Our Business
       Adjusted Net Income and Adjusted Net Income Per Share, page 50

   1.                                                   We acknowledge your
response to prior comment 2. You characterize your Adjusted Net
                                                        Income as a non-GAAP
performance measure. As such, it is inappropriate to include
                                                        income tax deductions
and related tax benefits associated with expenses removed from
                                                        a non-GAAP performance
measure; the resulting non-GAAP tax provision not being
                                                        commensurate with the
non-GAAP measure of profitability as stipulated in C&DI 102.11
                                                        on Non-GAAP Financial
Measures. As a result, please represent to us that you will
                                                        remove the income tax
benefit associated with your intangible asset amortization from
                                                        your Adjusted Net
Income and related per share non-GAAP performance measures
 James Shanahan
FirstName LastNameJames
Focus Financial Partners Inc.Shanahan
Comapany 8,
September NameFocus
             2020      Financial Partners Inc.
September
Page 2    8, 2020 Page 2
FirstName LastName
         beginning with your next Form 10-Q filing. In addition, represent to
us that you will not
         otherwise disclose or discuss a non-GAAP performance measure that
excludes intangible
         asset amortization but includes the related tax benefit in any future
earnings release,
         presentation slide deck, earnings conference call or similar
communication. Finally, note
         that removal of this tax benefit from your non-GAAP performance
measure does not
         preclude you from separately disclosing the income tax benefit
associated with tax
         deductions for intangible asset amortization.
Notes to Consolidated Financial Statements
Note 2: Summary of Significant Accounting Policies
Revenue Recognition, page F-11

2.       We acknowledge your response to prior comment 3. Please address the
following
         additional comments:
             Provide us proposed revised disclosure from page 44 in
Management's Discussion
             and Analysis that:
                o Removes reference to the variety of billing practices across
your partner firms
                  impacting your revenue related to the timing of any impact of
short-term
                  financial markets movements. As your response did not address
the billing
                  component of the first bullet of our prior, we presume that
you concur that
                  billing practices do not impact the timing of revenue
recognition. To the extent
                  that varying contract provisions impact the timing of revenue
recognition related
                  to short-term market movements, revise your proposed
disclosure accordingly.
                o Clarifies that the one-quarter lag effect of short-term
market movements on your
                  revenue is the result of your contractual provisions that set
your fees based on
                  the market value of your clients' assets at the beginning of
each quarter
                  consistent with your response to the first bullet of our
prior comment.
             Tell us why you disclose in critical accounting estimates on page
60 and in your
             policy note on page F-11 that your client arrangements may contain
multiple
             performance obligations when it appears from your response that
each type of
             contract (i.e., percentage of client assets, a flat fee or an
hourly rate) has only one
             single performance obligation. In your response, tell us:
                o The general or standard term (i.e., contractual length) of
each contact type;
                o Your consideration of the guidance in ASC 606-10-25-15 as to
whether your
                  contracts call for a series of distinct services that are
substantially the same and
                  that have the same pattern of transfer to the customer; and
                o Your consideration of the guidance in ASC 606-10-25-9 related
to whether you
                  combine two or more separate contracts into a single contract
for accounting
                  purposes. In this regard, it appears from your response to
the second bullet of
                  our prior comment that your hourly rate contracts are
typically separate
                  contracts with existing clients for special client projects.
             To the extent you have contracts with multiple performance
obligations provide us
             proposed revised disclosure that indicates how you determine the
transaction price
 James Shanahan
FirstName LastNameJames
Focus Financial Partners Inc.Shanahan
Comapany 8,
September NameFocus
             2020      Financial Partners Inc.
September
Page 3    8, 2020 Page 3
FirstName LastName
              and how you allocate it to the multiple performance obligations.
To the extent you
              do not have contracts with multiple performance obligations
provide us proposed
              revised disclosure that either:
                o   Removes reference to multiple performance obligations; or
                o   Indicates how you would determine the transaction price and
how you would
                    allocate it to the multiple performance obligations.
                Tell us why you indicate in your response to the second bullet
of our prior comment
              that your revenue generating contracts do not contain any
"constraints" when it is not
              the contract that contains constraints but instead is the result
of your ability to
              reasonably estimate variable consideration to include in the
transaction price
              allocated to all performance obligations that is not probable of
a significant revenue
              reversal. In your response tell us why you do not appear to
include the variable
              consideration associated with your market-correlated fees and
your hourly-rate fees
              in the transaction price. For the former, tell us whether market
uncertainty causes
              you to constrain this variable consideration until it is known as
that is when a
              significant revenue reversal is no longer probable. For the
latter, tell us whether you
              apply the practical expedient from ASC 606-10-55-18.
                In conjunction with your response to the preceding bullet, we
note that although you
              acknowledge in your response to the third bullet of our prior
comment that your
              market-correlated fee contracts and your hourly rate contracts
contain variable
              consideration, you do not appear to disclose any of the
information required by ASC
              606-10-50-20. As a result, provide us proposed revised disclosure
that:
                o   Specifically indicates that these contracts contain
variable consideration; and
                o   Provides information about the methods, inputs and
assumptions used to:
                         Determine the transaction price, specifically
indicating why you do or do
                         not include estimates of variable consideration in the
transaction price;
                         Assess whether an estimate of variable consideration
is constrained; and
                         Allocate the transaction price to performance
obligations (if applicable).
                The disclosure you highlight in response to our query about the
requirements in ASC
              606-10-50-18 provides no real indication about the methods you
use to recognize
              revenue and why those methods provide a faithful depiction of the
transfer of
              services. In this regard, for example, a statement that you
recognize revenue "over
              the period in which the services are provided" provides no
indication how that
              revenue is recognized. As a result, provide us proposed revised
policy disclosure that
              describes, for each type of contract, the specific input or
output methods used to
              recognize revenue and why those methods provide a faithful
depiction of the value of
              the services transferred.

      You may contact Mark Brunhofer at (202) 551-3638 or Sharon Blume at (202)
551-
3474 with any questions.



                                                               Sincerely,
 James Shanahan
Focus Financial Partners Inc.
September 8, 2020
Page 4
FirstName LastNameJames Shanahan
Comapany NameFocus Financial Partners Inc.
                                             Division of Corporation Finance
September 8, 2020 Page 4                     Office of Finance
FirstName LastName