February 9, 2011
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, DC 20549
| Re: | Franklin Financial Corporation |
| Registration Statement on Form S-1 |
| Request for Acceleration of Effectiveness |
| File No. 333-171108 |
Ladies and Gentlemen:
In accordance with Rule 461 of the Rules and Regulations of the Securities and Exchange Commission promulgated under the Securities Act of 1933, as amended, we hereby join Franklin Financial Corporation (the “Company”) in requesting that the Company’s above-referenced Registration Statement on Form S-1 be declared effective at 3:00 p.m. on February 11, 2011 or as soon thereafter as practicable.
| Very truly yours, | ||
| SANDLER O’NEILL & PARTNERS, L.P. | ||
By: Sandler O’Neill & Partners Corp., the sole general partner | ||
| By: | /s/ Jennifer Docherty | |
| Name: Title: | Jennifer Docherty Authorized Signatory | |
