January 30, 2006


Mail Stop 4561


By U.S. Mail and Facsimile to (847) 205-7401

Ms. Beverley A. Sibblies
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 Ms. Sibblies:

      We have reviewed your response dated January 19, 2006, 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.

Liquidity and Capital Resources, page 63

1. We note your response to comment 1 of our letter dated January
9,
2006.  We do not believe that it is appropriate to use the
guidance
in paragraph 30 of SFAS 144 regarding when a long lived asset to
be
sold should be classified as held for sale to assess whether in
accordance with paragraph 8 of SOP 01-6 you have the intent and
ability to hold a loan or receivable for the foreseeable future or
until maturity. The held for sale model for long lived assets in
SFAS
144 presumes held for investment classification unless the
specific
held for sale criteria are met. The model for loans and
receivables
in SOP 01-6 presumes held for sale classification unless the
holder
has the intent and ability to hold that loan or receivable for the
foreseeable future or until maturity. If at origination management
believes it is reasonably possible that it will sell a loan or
receivable in the foreseeable future, management has not formed an
intention to hold that loan or receivable for the foreseeable
future
and therefore at origination that loan or receivable should not be
classified as held for investment.  A commitment to sell that
specific receivable is not needed at origination for that
receivable
to be required by the guidance of paragraph 8 of SOP 01-6 to be
classified at origination as held for sale.  Please provide us
with
the following information so that we may better understand your
assertion that at the time of origination management did have the
intent and ability to hold receivables for the foreseeable future
or
until maturity or payoff.

* Please tell us whether you perform periodic cash flow
projections
to assess your liquidity needs.  If so, tell us whether during the
last three fiscal years these cash flow projections contemplated
the
sale of receivables as a source of liquidity and if so, to what
extent.

* Please quantify the percentage of auto finance, MasterCard/Visa,
private label and personal non-credit card receivables originated
during fiscal years ended December 31, 2003 and 2002 that were
subsequently sold.

* Please advise us as to how often you typically securitize or
sell
receivables.

2. On page 64 you disclose that proceeds from the December 2003
sale
of $2.8 billion of real estate secured loans to HSBC Bank USA were
temporarily held as securities available for sale at year-end
2003.
Please clarify to us what exactly you recorded as securities
available for sale - the proceeds from the sale or the receivables
themselves.

Notes to Consolidated Financial Statements

Note 2 - Summary of Significant Accounting Policies
Receivables Sold and Serviced with Limited Recourse and
Securitization Revenue, page 117

3. We note that you maintain limited recourse on certain
securitized
receivables and that you reduce the gain on sale of the
receivables
by a provision for estimated probable losses under the recourse
provision. You have disclosed that the provision is established at
the time of sale to "cover all probable credit losses over-the-
life
of the receivables sold based on historical experience and
estimates
of expected future performance."  Please tell us whether you
believe
that the recourse provision that you establish at the time of sale
is
recorded at fair value.  Refer to paragraph 113 of SFAS 140.

4. We note that any changes to your estimates for the reserve for
receivables serviced with limited recourse are made in the period
they become known.  In the table at the bottom of page 42, you
disclose that gains on initial and replenishment securitizations
are
shown net of your estimate of probable credit losses under
recourse
provisions. In future filings, please revise to separately
quantify
amounts recorded to initially establish a provision at the time of
securitization and any subsequent changes to the provision, if
material.

*	*	*


      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 Angela Connell, Senior Accountant, at (202) 551-3426
or
me at (202) 551-3494 if you have questions regarding comments on
the
financial statements and related matters.


      Sincerely,



      Kevin W. Vaughn
      Accounting Branch Chief


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Ms. Beverley A. Sibblies
HSBC Finance Corporation
January 20, 2006
Page 1