July 25, 2024

Gary Zyla
Chief Financial Officer
AssetMark Financial Holdings, Inc.
1655 Grant Street, 10th Floor
Concord, California 94520

       Re: AssetMark Financial Holdings, Inc.
           Form 10-K for the Fiscal Year ended December 31, 2023
           Filed March 14, 2024
           File No. 001-38980
Dear Gary Zyla:

       We have reviewed your July 15, 2024 response to our comment letter and
have the
following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

        After reviewing your response to this letter, we may have additional
comments. Unless we
note otherwise, any references to prior comments are to comments in our July 3,
2024 letter.

Form 10-K for the Fiscal Year ended December 31, 2023
Management's Discussion and Analysis, page 54

1.     We note that in response to prior comment one, concerning the
requirement to disclose
       the extent to which changes in asset-based revenues are attributable to
changes in prices
       and changes in product mix, in addition to changes in volumes (as
represented by
       platform assets), you indicate that no portion of the revenue increase
during 2023 was due
       to higher prices. However, you also refer to the fee rate you charge and
state that the
       industry has experienced downward pressure on fees for several years,
although you
       declined to quantify the effects on asset-based revenues associated with
lower fees.

       Given that platform assets at the end of 2023 had increased 19.1%
compared to the end of
       the preceding fiscal year, and that the simple average of platform
assets for 2023 had
       increased 8.3% compared to the corresponding figure for 2022, it appears
that your
       discussion and analysis should address the apparent disparity between
these increases
 July 25, 2024
Page 2

       relative to asset-based revenues and clarify the reasons the increase in
asset-based
       revenues was limited to 3.6% in comparison. If weighted-average fees for
2023 were
       lower than in 2022, the effect on revenues may be quantified as an
offset to the
       increase that would otherwise be attributable to the increase in average
platform assets,
       i.e., if there were no change in fees. We suggest that you tabulate and
disclose the
       weighted-average fee range and weighted average platform assets for each
period.

       However, if you believe that further disclosures are unnecessary because
the effects of
       changes in prices or product mix were not material in any of the last
three fiscal years, or
       you do not regard information about fees to be of interest to investors,
please explain to us
       your rationale and provide us with the analyses that you performed in
formulating that
       view, including quantification of the effects associated with changes in
prices, product
       mix, and volumes for each period. We reissue prior comment one.
       Please contact John Cannarella at 202-551-3337 or Gus Rodriguez at
202-551-3752 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation