February 17, 2006

Mail Stop 4561

By U.S. Mail and facsimile to (248) 312-6833

Mr. Paul D. Borja
Chief Financial Officer
Flagstar Bancorp, Inc.
5151 Corporate Drive
Troy, Michigan 48098-2639

Re:	Flagstar Bancorp, Inc.
	Form 10-K filed March 23, 2005
	File No. 001-16577


Dear Mr. Borja:

      We have reviewed your response letter dated February 13,
2006
and have the following additional comments.  Where indicated, we
think you should revise future filings, beginning with your
December
31, 2005 Form 10-K, 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.

Note 4 - Summary of Significant Accounting Policies
Secondary Marketing Reserve, page 84

1. We note your responses to comments 6 - 7 of our letter dated
November 23, 2005.  We do not agree that disclosure of the
components
of your secondary marketing reserve would be more confusing to
investors than helpful.  On the contrary, we think it is important
for investors to understand your estimation process and how
changes
in your estimates impact your financial statements, both
qualitatively and quantitatively. Furthermore, as previously
communicated, we do not feel that "net gain on loan sales" is an
accurate representation of the components included within that
income
statement line item as changes in estimates made subsequent to the
sale of a loan are not generally included in the calculation of
the
gain on sale of such loan.  Please revise future filings to
present
the component of your secondary market provision related to
changes
in estimates made subsequent to the sale of loan separately from
your
net gain on loan sales.  Alternatively, if you wish to continue
reporting these amounts together in a single line item, please
revise
the caption of this line item to more clearly reflect its
components
and provide footnote disclosure that quantifies each component.


*	*	*

      As appropriate, please revise your future filings, beginning
with the Form 10-K for the period ending December 31, 2005, and
respond to these comments within 10 business days or tell us when
you
will provide us with a response.  Please provide us with your
response to our comments along with drafts of the revised
disclosures
to be included in your future filings.  Please furnish a cover
letter
with your response that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please file your response on EDGAR.
Please
understand that we may have additional comments after reviewing
your
drafts of future disclosures and responses to our comments.

      You may contact Angela Connell 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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Mr. Paul D. Borja
Flagstar Bancorp, Inc.
February 17, 2006
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