TFS FINANCIAL CORPORATION
                              7007 Broadway Avenue
                              Cleveland, Ohio 44105

February 9, 2007

VIA FACSIMILE AND EDGAR
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(202) 772-9216

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

     Re:     TFS Financial Corporation
             Registration Statement on Form S-1 (Registration Number 333-139295)
             Request for Acceleration of Effectiveness

Ladies and Gentlemen:

     TFS Financial  Corporation,  a federal corporation (the "Company"),  hereby
requests  that the  Company's  Registration  Statement  on Form S-1 be  declared
effective  on  February  12,  2007 at 10:00 a.m.,  or as soon  thereafter  as is
practicable.

     The Company hereby acknowledges that:

     o     should  the  Commission or  the  staff,  acting pursuant to delegated
           authority,  declare  the filing effective,  it does not foreclose the
           Commission from taking any action with respect to the filing;

     o     the  action of  the  Commission  or  the staff,   acting  pursuant to
           delegated authority,   in declaring the  filing effective,   does not
           relieve the Company from its full responsibility for the adequacy and
           accuracy of the disclosure in the filing; and

     o     the Company may not assert this action as a defense in any proceeding
           initiated   by  the   Commission  or  any  person  under  the federal
           securities laws of the United States.

                                                   Very truly yours,



                                                   /s/ David S. Huffman
                                                   -----------------------------
                                                   David S. Huffman
                                                   Chief Financial Officer (Duly
                                                   Authorized Representative)