Mail Stop 4561

								September 29, 2005

By U.S. Mail and Facsimile to (847) 205-7401

Mr. Simon C. Penney
Chief Financial Officer
HSBC Finance Corporation
2700 Sanders Road
Prospect Heights, Illinois 60070

Re:	HSBC Finance Corporation
	Form 10-K for Fiscal Year Ended December 31, 2004
      Filed February 28, 2005
	File No. 001-8198

Dear Mr. Penney:

      We have reviewed your filing and have the following
comments.
We have limited our review to the issues we have addressed in our
comments.  Where indicated, we think you should revise future
filings
in response to these comments and provide us with a draft of your
intended revisions. If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Financial Statements
Consolidated Balance Sheet, page 109

1. Please tell us and revise future filings to disclose how you
applied the guidance in paragraphs 8(b) and (c) of SOP 01-6 to the
receivables that you securitized during each of the periods
presented. In addition, given your history of securitizing
receivables, tell us how you considered whether all or a portion
of
your retail receivables should be reported as held for sale as of
each balance sheet date.





Consolidated Statement of Cash Flows, page 112

2. Please tell us how you considered the guidance in paragraph 9
of
SFAS 102 in determining the appropriate classification of cash
flows
related to the origination and securitization of receivables.

Note 2 - Significant Accounting Policies
Receivables, page 114

3. We note your disclosure that receivables are carried at
amortized
cost.  Please revise future filings to clarify your definition of
"amortized cost" and disclose how this policy complies with
paragraph
8(a) of SOP 01-6.


*	*	*


       As appropriate, please revise future filings in response to
these comments and provide us with a draft of your intended
revisions
within 10 business days or tell us when you will provide us with a
response.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested information.  Detailed cover letters greatly
facilitate
our review.  Please understand that we may have additional
comments
after reviewing your amendment and responses to our comments.

	 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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 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.

      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 filing or in
response to our comments on your filing.

	You may contact Isa Farhat at (202) 551-3485 or me at (202)
551-
3426 if you have questions regarding comments on the financial
statements and related matters.


      Sincerely,



      Angela Jackson
      Senior Accountant


Mr. Simon C. Penney
HSBC Finance Corporation
September 29, 2005
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