July 21, 2011
VIA EDGAR SUBMISSION
Ms. Stephanie L. Hunsaker, Senior Assistant Chief Accountant
Ms. Yolanda Crittendon, Staff Accountant
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
| Re: | E*TRADE Financial Corporation |
Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 22, 2011
File No. 001-11921
Dear Ms. Hunsaker and Ms. Crittendon:
This letter is in response to your letter of July 19, 2011. As discussed by phone, the Company proposes to respond to your letter no later than August 31, 2011. The Company requests additional time in order to ensure that it can provide a complete response to the comments, some of which will require a significant amount of data to be extracted, organized and analyzed. In addition, the Company’s finance and accounting staff is currently concentrating its efforts on preparing its quarterly report on Form 10-Q for the second quarter, which is a more time- and resource-consuming effort than in the past because the Company must for the first time meet the Level 4 detail XBRL tagging requirements. The Company confirms that in preparing its quarterly report the Company will use all reasonable efforts to incorporate the Staff’s requested disclosures or revisions in the Form 10-Q to the extent the Company believes they are applicable and appropriate. In certain instances, the Company will in its response letter explain why the Company believes revised disclosure would be inappropriate or not meaningful. Please feel free to contact Katy Albers, VP of Financial Reporting and Accounting Policy at (703) 236-8687 with any questions.
Very truly yours,
/s/ Matthew J. Audette
Matthew J. Audette
Chief Financial Officer
| cc: | Karl A. Roessner |
E*TRADE Financial Corporation
Sarah K. Solum
Daniel G. Kelly, Jr.
Davis Polk & Wardwell
Robert A. Crawford
Deloitte & Touche LLP
