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                             April 17, 2023

       Barry Sloane
       Chief Executive Officer
       NewtekOne, Inc.
       4800 T Rex Avenue, Suite 120
       Boca Raton, FL 33431

                                                        Re: NewtekOne, Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-3
                                                            Filed March 31,
2023
                                                            File No. 333-269452

       Dear Barry Sloane:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our March
20, 2023 letter.

       Amendment No. 2 to Registration Statement on Form S-3

       General

   1.                                                   We have referred this
filing to the staff of the Division of Investment Management for
                                                        assessment of your
status under the Investment Company Act of 1940. Staff in that
                                                        division may contact
you separately in connection with their review.
 Barry Sloane
FirstName   LastNameBarry Sloane
NewtekOne,    Inc.
Comapany
April       NameNewtekOne, Inc.
       17, 2023
April 217, 2023 Page 2
Page
FirstName LastName
2.       In light of recent market events and activities within the banking
sector, please revise
         Business, Risk Factors, Management's Discussion and Analysis and other
sections, where
         appropriate, to address any material impact these events and
activities have had on your
         financial condition, operations, customer base, liquidity, capital
position and risk profile.
         For example, consider the need to further expand your discussion of
interest rate risk and
         asset/liability management policies and discuss any changes management
has undertaken
         in response to the recent events and activities.
3.       We note your references throughout the registration statement to the
Operating Agreement
         with the OCC. Please include a separate section that describes
material terms of this
         agreement.
Limits on Activities and Approval Requirements, page 11

4.       We note your response to our prior comment 4 and reissue in part.
Please revise your
         disclosure to explain what "broader array of financial activities" you
are permitted to
         engage in and clarify whether you have satisfied conditions outlined
in the Gramm-Leach-
         Bliley Act of 1999. If you have not satisfied such conditions at this
time, disclose how and
         when you plan to satisfy them.
       You may contact William Schroeder at 202-551-3294 or Ben Phippen at
202-551-3697 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Mateo at 202-551-3465 or Tonya Aldave at 202-551-3601 with
any other
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Finance
cc:      Jared Fishman, Esq.