Mail Stop 4561


								August 25, 2005


By U.S. Mail and facsimile to (215) 444 5915

Phillip M. Browne
Chief Financial Officer
Advanta Corp.
Welsh & McKean Roads, P.O. Box 844
Spring House, Pennsylvania  19477

Re:	Advanta Corp.
	Form 10-K for the Fiscal Year Ended December 31, 2004
Forms 10-Q for the Quarters Ended March 31, 2005 and June 30, 2005
	File No. 000-14120

Dear Mr. Browne:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  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.

Form 10-K for the Fiscal Year Ended December 31, 2004

Advanta Business Cards, page 29

1. In future filings, starting with your next 10-Q, please revise
to
explain fully the reasons for the changes in your provision for
loan
losses by discussing specific events that cause management to
adjust
the provision and conclude on the adequacy of the provision and
allowance for loan losses.

Managed Receivable Data, page 36

2. Presentation of non-GAAP statements of income even when
reconciled
to reported results is potentially confusing to investors.  Please
confirm you will remove pro forma statements of income in all
future
filings, including the reconciliation of actual owned (GAAP)
income
statement measures and statistics to income statement measures and
statistics on a managed basis on page 36.  Instead, consider
expanding your disclosures to discuss and quantify the impact of
securitizations on your reported results, including the impact on
specific income statement captions and on net interest margins.

3. Please tell us the how management uses `Risk-adjusted revenues`
to
evaluate the Advanta Business Cards segment.  We noted that this
is
the only section in the filing that includes this measure.
Amended
Item 10(1) of Regulation S-K, requires disclosure of the reasons
why
management feels a non-GAAP term is useful to investors.

Market Risk Sensitivity, page 46

4. We note that your business credit card receivables include
interest rate floors, as described on page 46 of Form 10-K.
Please
tell us the extent to which you use derivative instruments to
hedge
interest rate risk and other risks.

Liquidity, Capital Resources and Analysis of Financial Condition,
page 47

5. The consolidated statement of cash flows indicates cash used in
operating activities totaled $92.3 million for the year ended
December 31, 2004.  In future filings, please revise your
liquidity,
capital resources and analysis of financial condition to discuss
the
reason for this cash use from operating activities and describe
how
you plan to fund growth and continued operations.

Note 2- Summary of Significant Accounting Policies, page 55

Allowance for Receivable Losses, page 56

6. You disclose that your charge-off and re-age policies for
business
credit card accounts conform to the Uniform Retail Credit
Classification and Account Management Policy, as well as the
Credit
Card Lending Guidance, issued by the Federal Financial
Institutions
Examination Council ("FFIEC").  Please tell us your re-age
policies
and how such policies are incorporated in your calculation of the
allowance for loan losses.
Securitization Income, page 57

7. You state that during the revolving period of each business
credit
card securitization, you record securitization income representing
estimated gains on the sale of new receivables to the
securitization
trust on a continuous basis.  Please tell us how the transfers of
receivables to the securitization trust during the revolving
period
qualify for sales accounting according to paragraph 9 of SFAS 140.

8. Please tell us the amount of outstanding commitments to
transfer
assets to the securitization trust during the revolving period as
of
December 31, 2004.

Servicing Assets, page 58

9. You state that you do not recognize servicing assets associated
with business credit card securitizations because the benefits of
servicing are not expected to be more or less than adequate
compensation for performing the servicing.  Please provide us your
analysis that indicated the benefits of servicing are just
adequate
to compensate for your servicing responsibilities.  Refer to
paragraph 62 of SFAS 140.

Investment in Limited Partnership, page 59

10. We note subsequent to May 28, 2004, the date of your agreement
with Bank of America you accounted for your investment in Fleet
Credit Card Services, L.P. using the cost method.  Please tell us
why
the agreement with Bank of America caused you to change from the
equity to the cost method to account for your investment in the
Limited Partnership.

Note 11 - Commitments and Contingencies, page 73

11. Please tell us how you accounted for the remaining legal
reserve
related to litigation with Fleet related to the Consumer Credit
Card
Transaction after the court issued the final judgment in February,
2004.

12. Please tell us how you determined that the SFAS 5 legal
reserves
related to discontinued operations were adequate at December 31,
2004.  Include the amount of such reserves in your response.

Note 16 - Segment Information, page 82

13. Please tell us the basis for allocating interest income to the
Other segment, considering the Other segment`s total assets at the
end of the period.

Form 10-Q for the Period Ended, March 31, 2005

Note 12 - Income Taxes, page 18

14. We note that upon receiving the IRS`s approval of the
settlement
of the tax disputes with Fleet, the remaining valuation allowance
of
$12 million was evaluated, and management determined that it was
more
likely than not that the remaining deferred tax asset was
realizable
and therefore, no valuation allowance was needed.  Please provide
us
with your analysis of realizability of the deferred tax asset in
2003
and 2004 that indicated the need for a valuation allowance.  In
addition, tell us what event(s) took place in 2005 that made you
conclude that the realizability of the deferred tax asset was more
likely than.
* * * * *

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response on EDGAR.  Detailed cover letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.






      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Matthew Komar (Staff Accountant) at (202)
551-
3781 or me at (202) 551-3490 if you have questions regarding
comments
on the financial statements and related matters.


      Sincerely,



      Don Walker
Senior Assistant
Chief Accountant

Phillip M. Browne
Advanta Corp.
August 25, 2005
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