October 13, 2006

Via Facsimile

Daniel H. Morris

Attorney-Adviser

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Impac Secured Assets Corp., Form S-3 Registration Statement

File No.: 333-134181         

Dear Mr. Morris:

In connection with the above-captioned registration statement, we wish to advise you that we hereby request that the effective date of such registration statement be accelerated so that the same will become effective on October 16, 2006 at 5:00 PM EST or as soon as practicable thereafter.

Impac Secured Assets Corp. (the “Company”) hereby acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) declare the Registration Statement effective, the Commission is not foreclosed from taking any action with respect to the Registration Statement, (ii) a declaration of the Registration Statement’s effectiveness by the Commission or its staff does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing, and (iii) the Company may not assert the declaration of the Registration Statement’s effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

IMPAC SECURED ASSETS CORP.

By:      /s/ Gretchen Verdugo  

Name:Gretchen Verdugo

Title:Chief Financial Officer