[LETTERHEAD OF LATHAM & WATKINS LLP]
January 18, 2005
Mr. Robert Telewicz
Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-0306
| Re: | ECC Capital Corporation |
| Registration Statement on Form S-11 filed on August 13, 2004, as amended by |
| Amendment No. 1 to Form S-11 filed on October 29, 2004 and Amendment No. 2 |
| to Form S-11 (File No. 333-118253) filed on December 17, 2004. |
Dear Mr. Telewicz:
Thank you for taking the time today to discuss certain comments to ECC Capital Corporation’s (the “Company”) Amendment No. 2 contained in the comment letter dated January 5, 2005. As we discussed, we have included below the supplemental information you requested in support of the Company’s draft response to comment number 13.
Financial Statements
Note N – Stock Options, page F-27
| 13. | We have reviewed your response to our prior comment 49 and the related changes to your disclosures. It appears that the value of your stock has almost doubled from August 2004 to September 2004. In a supplemental response, explain the changes in circumstances that have caused the increase in the value of your stock. |
Supplemental Information:
*
| * | Confidential Treatment Requested by ECC Capital Corporation |
Mr. Robert Telewicz
January 18, 2005
Page 2
LATHAM & WATKINS LLP
Warm regards,
/s/ Jeevan B. Gore
Jeevan B. Gore
of LATHAM & WATKINS LLP
| cc: | Roque Santi |
| Greg Lubushkin |
| William J. Cernius |
