SANDLER                                                INVESTMENT BANKING GROUP

O'NEILL

+ PARTNERS




                                February 9, 2007


Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.  20549

           Re:      TFS Financial Corporation
                    Registration Statement No. 333-139295
                    -------------------------------------

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 TFS Financial  Corporation (the "Company") in requesting
that the  Company's  above-referenced  registration  statement  on Form S-1 (the
"Registration Statement") be declared effective on Monday, February 12, 2007, at
10:00 a.m. Eastern time, or as soon thereafter as is practicable.

                                          Very truly yours,

                                          SANDLER O'NEILL & PARTNERS, L.P.

                                          By:  Sandler O'Neill & Partners Corp.,
                                               the sole general partner


                                          By:  /s/ Christopher S. Hooper
                                               ---------------------------------
                                               Christopher S. Hooper
                                               Authorized Signatory








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