October 31, 2006

Via U.S. Mail and Facsimile

Nobuo Kuroyanagi
President and Chief Executive Officer
Mitsubishi UFJ Financial Group, Inc.
7-1 Marunouchi 2-chome
Chiyoda-ku, Tokyo 100-8330
Japan

	Re:	Mitsubishi UFJ Financial Group, Inc.
		Form 20-F/A for the Fiscal Year Ended March 31, 2005
		Filed February 28, 2006
		File No. 333-98061-99

Dear Mr. Kuroyanagi:

      We have reviewed your response letter dated October 19, 2006
and have the following comments.  We welcome any questions you may
have about our comments or on any other aspect of our review.
Feel
free to call us at the telephone numbers listed at the end of this
letter.

General
1. We refer you to your "Response to Comment No. 2," in which you
describe your trade finance transactions with entities in or
affiliated with Iran, Cuba, North Korea, Sudan and Syria.  We note
your representation that it would be impractical and extremely
burdensome for you to provide specific details regarding those
transactions.  To assist us in understanding the significance to
you
of the transactions, please tell us what percentage of your assets
as
of March 31, 2006, the total dollar amount of your risk exposure
in
connection with such transactions during the fiscal year ended on
that date represents.  Alternatively, you may confirm to us, if
true,
that the total dollar amount of your risk exposure in connection
with
trade finance transactions related to the referenced countries
during
the fiscal year does not represent a greater percentage of your
total
assets at March 31, 2006, than does the dollar amount of loans
outstanding to borrowers in or affiliated with Iran and Cuba at
that
date.

2.	If the total dollar amount of your risk exposure in
connection
with trade finance transactions with entities in or affiliated
with
Iran, Cuba, North Korea, Sudan and Syria during the fiscal year
represents a greater percentage of your total assets at March 31,
2006 than does the dollar amount of loans outstanding to borrowers
in
or affiliated with Iran and Cuba at that date, please advise us of
the percentage of your total assets at that date which your risk
exposure during the fiscal year in connection with each of the
five
countries represents.


* * * * *


      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response letter on EDGAR.

      Please understand that we may have additional comments after
we
review your response to our comments.  Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments or our review.  You may also contact me at (202) 551-
3470.

								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk



cc: 	Donald Walker
		Accounting Branch Chief
		Division of Corporation Finance
	Tong Yu, Esq.
	Paul, Weiss, Rifkind, Wharton & Garrison LLP
	Fax No: 011-81-3-3597-8120


Nobuo Kuroyanagi
Mitsubishi UFJ Financial Group, Inc.
October 31, 2006
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