Mail Stop 4561

								January 9, 2006

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 response filed with the Commission on
October 18, 2005, and have the following additional 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. We note your response to comment 1 of our letter dated
September
29, 2005.  Please note that the guidance in SFAS 144 does not
apply
to financial instruments, which include receivables based on the
definition set forth in paragraph 3 of SFAS 107.  Paragraph 8(a)
of
SOP 01-6 states that receivables may be classified as held for
investment only if management has the intent and ability to hold
receivables for the foreseeable future, or until maturity or
payoff.
Please advise us as follows:

* Clearly explain how you determine whether your receivables meet
the
requirements of paragraph 8(a) to be classified as held for
investment upon origination.

* Reconcile your history of securitizing receivables with the
condition in paragraph 8(a) that at the time of origination you
have
the intent and ability to hold the receivables for the foreseeable
future, or until maturity or payoff.

* Explain what time period you consider to be the "foreseeable
future" when making this determination.

Consolidated Statement of Cash Flows, page 112

2. We note your response to comment 2 of our letter dated
September
29, 2005.  To the extent that you determine that any of your
receivables should be classified as held for sale, please revise
to
present your cash flows from the sale or securitization of such
receivables as operating cash flows.


*	*	*


      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter with your response indicating your intent to provide
the
requested disclosures in future filings.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

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


      Sincerely,



      Angela Connell
      Senior Accountant


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Mr. Simon C. Penney
HSBC Finance Corporation
January 9, 2006
Page 1