April 9, 2020

Jonathan Clark
Executive Vice President, Chief Financial Officer and Treasurer
Encore Capital Group Inc.
350 Camino de La Reina, Suite 100
San Diego, California 92108

       Re: ENCORE CAPITAL GROUP INC
           Form 10-K
           Filed February 26, 2020
           File No. 000-26489

Dear Mr. Clark:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K filed February 26, 2020

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Purchases and Collections
Cabot (Europe), page 29

1.    We note your disclosure on page 30 regarding the "co-investment
agreements" you
      entered into during the fourth quarter of 2019 and the $9.3 million gain
recognized on the
      sale of certain portfolios related to these agreements. Please revise
future filings to
      discuss any:

           material terms, conditions, and obligations under the agreements,
and

           material impact on your liquidity, capital resources or results of
operations, including
           any trends and uncertainties.

      In addition please file these agreements as an exhibit or tell us why
they are not required.
 Jonathan Clark
Encore Capital Group Inc.
April 9, 2020
Page 2
         Refer to Item 601(b)(10) of Regulation S-K.
Notes to Consolidated Financial Statements
Note 1. Ownership, Description of Business, and Summary of Significant
Accounting
Policies - Recent Accounting Pronouncements, page F-8

2.       We note your disclosure that upon adoption of ASU 2016-13, you will
include expected
         recoveries of upfront court costs in the measurement of the investment
in receivable
         portfolios at a discounted value. We also note that you provided us
information related to
         court costs and accounting literature supporting your prior policy in
your response to
         comment six in your letter dated September 14, 2012. Please tell us if
the information is
         still accurate. If not, please clarify and specifically identify the
accounting guidance that
         supports your new policy. Also, please tell us:

              when you recognize an amount for expected recoveries of upfront
court costs in your
              receivables portfolio. For example, do you include these cash
flows in your initial
              estimate of cash flows at acquisition, when court costs are paid,
etc.,
              how the cash flows impact your income recognition on your
receivables portfolio,
              whether you would include expected recoveries of upfront court
costs only in
              situations where you expect to collect the full unpaid principal
balance, and
              if you believe these amounts represent expected recoveries of
amounts previously
              written off as used in ASC 326.

         Lastly, please provide us example journal entries with supporting
commentary illustrating
         your new accounting policies.
3.       We note your disclosure that upon adoption of ASU 2016-13, an
adjustment will be made
         to retained earnings to reflect the net change from an undiscounted to
discounted value
         prior to writing-off uncollectible court costs and that the decrease
to opening retained
         earnings is estimated to be between $40 and $50 million. Please tell
us in detail how you
         calculated the estimated decrease to opening retained earnings.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      You may contact William Schroeder, Staff Accountant, at 202-551-3294 or
Michael Volley, Staff Accountant, at 202-551-3437 if you have any questions.



FirstName LastNameJonathan Clark                                Sincerely,
Comapany NameEncore Capital Group Inc.
                                                                Division of
Corporation Finance
April 9, 2020 Page 2                                            Office of
Finance
FirstName LastName