April 12, 2006


Mail Stop 4561

Mr. Jose Rafael Fernandez
President and Chief Executive Officer
Oriental Financial Group Inc.
998 San Roberto Street
Professional Offices Park SE 4th Floor
San Juan, Puerto Rico 00926
Via Facsimile and U.S. Mail

Re:	Oriental Financial Group Inc.
	Form 10-K for Fiscal Year Ended June 30, 2005
	Form 10-Q for Fiscal Quarter Ended September 30, 2005
	File No. 001-12647

Dear Mr. Fernandez:

We have reviewed your response letter filed March 27, 2006 and
have
the following comments.

Form 10-K for Fiscal Year Ended June 30, 2005

Part I

Item 1. Business, page 2

1. We note your response to comment two of our letter dated
December
9, 2005 that you will provide an enhanced discussion of your
banking
activities including your underwriting procedures and criteria as
well as your process for determining whether transfers of
financial
assets qualify for true sale accounting pursuant to paragraph 9 of
SFAS 140 in future filings.  In light of your reevaluation of
accounting and financial reporting related to certain loan
purchases
and the fact that you will be filing an amendment to your June 30,
2005 Form 10-K, please include such discussion in your amendment.

Item 9A. Controls and Procedures, page 15

2. We note that you plan to amend your periodic reports to file
restated financial statements.  Please describe the effect of the
restatement on the officers` conclusions regarding the
effectiveness
of the company`s disclosure controls and procedures.  See Item 307
of
Regulation S-K.  If the officers` conclude that the disclosure
controls and procedures were effective, despite the restatement,
describe the basis for the officers` conclusions.

Attestation Report of Independent Registered Public Accounting
Firm
on Section 404

3. We note your response to comment three of our letter dated
December 9, 2005 that you will amend your June 30, 2005 Form 10-K
to
include a signed copy of your Attestation Report on Section 404.
Please tell us when you plan to file the amendment.

Management`s Discussion and Analysis

General

4. In your response to comment four of our letter dated December
9,
2005 as well as in your Form 8-K filed on April 28, 2005 you
discuss
your new business model adopted in fiscal 2004 which was put in
place
to speed up your transition to become a more traditional asset-
based
financial institution.  In future filings, beginning with your
December 31, 2005 Form 10-K please include a robust discussion of
this new model.  Your disclosure should address the impact that
the
new business model will have, or is reasonably likely to have, on
the
company`s liquidity, capital resources and results of operations
as
well as help readers ascertain the likelihood that past
performance
is indicative of future performance.  Please refer to Interpretive
Release Number 33-8350.

* * *

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

	You may contact Benjamin Phippen, Staff Accountant, at (202)
551-3697 or me at (202) 551-3490 if you have any questions.


Sincerely,



Donald A. Walker
Senior Assistant Chief Accountant

Mr. Jose Rafael Fernandez
Oriental Financial Group Inc.
April 12, 2006
Page 1