CORRESP 1 filename1.txt SANDLER INVESTMENT BANKING GROUP O'NEILL + PARTNERS February 9, 2007 Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Re: TFS Financial Corporation Registration Statement No. 333-139295 ------------------------------------- Ladies and Gentlemen: In accordance with Rule 461 of the Rules and Regulations of the Securities and Exchange Commission promulgated under the Securities Act of 1933, as amended, we hereby join TFS Financial Corporation (the "Company") in requesting that the Company's above-referenced registration statement on Form S-1 (the "Registration Statement") be declared effective on Monday, February 12, 2007, at 10:00 a.m. Eastern time, or as soon thereafter as is practicable. Very truly yours, SANDLER O'NEILL & PARTNERS, L.P. By: Sandler O'Neill & Partners Corp., the sole general partner By: /s/ Christopher S. Hooper --------------------------------- Christopher S. Hooper Authorized Signatory Sandler O'Neill + Partners, L.P. www.sandleroneill.com 919 Third Avenue, 6th Floor, New York, NY 10022 T: (212) 466-7700 F: (212) 466-7711