SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

								July 26, 2005

Mr. Lawrence Stumbaugh
Director, Chief Executive Officer and President
AssuranceAmerica Corporation
5500 Interstate North Pkwy., Suite 600
Atlanta, Georgia   30328

      Re:	AssuranceAmerica Corporation
		Form 10-KSB for Fiscal Year Ended December 31, 2004
		Filed May 3, 2005
      File No. 000-06334

Dear Mr. Stumbaugh:

      We have limited our review of your filing to only those
issues
we have addressed in our comments.  In our comments, we ask you to
provide us with information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
After reviewing this information, we may raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Financial Statements

Report of Independent Public Accountants, page F-2

1. Provide us information that demonstrates that "Miller Ray
Houser &
Stewart LLP" was currently registered with the Public Company
Accounting Oversight Board as of the date of their report. "Miller
Ray & Houser LLP" appears to be the closest firm, in name, to be
currently registered with the Public Company Accounting Oversight
Board.

(6)  Unpaid Losses and Loss Adjustment Expenses, page F-9

2. Please provide us the disclosures that are required by
paragraph
11 of SOP 94-5.

	Please respond to these comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
response letter that keys your responses to our comments and
provides
any requested information.  Detailed letters greatly facilitate
our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.  Please understand that we may have additional comments
after reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Ibolya Ignat, Staff Accountant, at (202)
551-
3656, or Oscar M. Young, Senior Staff Accountant, at (202) 551-
3622,
if you have questions regarding the comments. In this regard, do
not
hesitate to contact me, at (202) 551-3679.

								Sincerely,

								Jim B. Rosenberg
								Senior Assistant Chief
								Accountant
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Lawrence Stumbaugh
AssuranceAmerica Corporation
July 26, 2005
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