February 1, 2019

Kathleen Layton
Assistant General Counsel
Oportun Financial Corp
2 Circle Star Way
San Carlos, CA 94070

       Re: Oportun Financial Corp
           Amendment No. 3 to
           Draft Registration Statement on Form S-1
           Submitted December 14, 2018
           CIK No. 0001538716

Dear Ms. Layton:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amended Draft Registration Statement on Form S-1

Financial Statements
Notes to Consolidated Financial Statements
14. Fair Value of Financial Instruments, page F-48

1.     You disclose in a risk factor on page 25 that a variety of factors, such
as changes in the
       interest rate environment and the credit markets, unexpected changes in
customer
       prepayment speeds, higher than anticipated delinquency and default
levels, or financial
       market illiquidity may ultimately affect the fair values of your loans
receivable and asset-
       backed notes. Material differences in these ultimate values, determined
based on
       management's estimates and assumptions, may require you to adjust the
value of certain
 Kathleen Layton
Oportun Financial Corp
February 1, 2019
Page 2
         assets and liabilities, which could adversely affect your results of
operations. Please
         disclose significant unobservable inputs for interest rates, credit
spreads and customer
         prepayments, or tell us why you do not believe these are significant
unobservable inputs in
         your Level 3 valuations.
       You may contact David Irving at 202-551-3321 or Gus Rodriguez at
202-551-3752 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Erin Purnell at 202-551-3454 or Michael Clampitt at 202-551-3434 with
any other
questions.



FirstName LastNameKathleen Layton                             Sincerely,
Comapany NameOportun Financial Corp
                                                              Division of
Corporation Finance
February 1, 2019 Page 2                                       Office of
Financial Services
FirstName LastName