September 26, 2019

Danfeng Xu
Treasurer and Controller
Santa Fe Financial Corporation
12121 Wilshire Boulevard
Suite 610
Los Angeles, CA 90025

       Re: Santa Fe Financial Corporation
           Form 10-K for the Fiscal Year Ended June 30, 2019
           Filed August 30, 2019
           File No. 000-06877

Dear Ms. Xu:

       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 Fiscal Year Ended June 30, 2019

Item 9A. Controls and Procedures.
Management's Report On Internal Control Over Financial Reporting, page 40

1.    Please clarify for us whether your internal control over financial
reporting was effective or
      ineffective as of June 30, 2019. In your response, please tell us the
status of the material
      weakness identified in your report as of June 30, 2019.
2.    We note your statement that management's report on internal controls over
financial
      reporting "shall not be deemed to be filed for purposes of Section 18 of
the Exchange Act,
      or otherwise subject to the liabilities of that section, and is not
incorporated by reference
      into any filings of the Company, whether made before or after the date
hereof, regardless
      of any general incorporation language in such filing." This statement
appears to have
      been made in reliance on Item 308T of Regulation S-K, a special temporary
provision that
      is no longer in effect. Refer to SEC Release No. 33-9142, including
footnote 15. Please
 Danfeng Xu
Santa Fe Financial Corporation
September 26, 2019
Page 2
         confirm that the company will not include the statement in future
filings.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Isaac Esquivel at (202) 551-3395 or Robert Telewicz at
(202) 551-3438
with any questions.



                                                               Sincerely,
FirstName LastNameDanfeng Xu
                                                               Division of
Corporation Finance
Comapany NameSanta Fe Financial Corporation
                                                               Office of Real
Estate and
September 26, 2019 Page 2                                      Commodities
FirstName LastName