SecProbe.io

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Securities and Exchange Commission
September 1, 2005
Page 1

                         MACKEY PRICE THOMPSON & OSTLER
                           A Professional Corporation
                         Attorneys and Counselors at Law

                                American Plaza II
                          57 West 200 South, Suite 350
                          Salt Lake City, UT 84101-3663
                             Telephone 801-575-5000
                                Fax 801-575-5006

Randall A. Mackey
rmackey@mpwlaw.com

                                September 1, 2005

VIA FACSIMILE    (202) 772-9218
--- ---------
AND EDGAR

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Mail Stop 0408
Judiciary Plaza
Washington, D.C. 20549

Attn:    Julie Sherman
         Staff Accountant

         Re:      Security National Financial Corporation
                  Form 10-K for the year ended December 31, 2004
                  Filed April 15, 2005
                  File No. 0-9341

Ladies and Gentlemen:

     On behalf of Security National Financial Corporation (the "Company") and in
connection  with the  above-captioned  Form 10-K (the "Form  10-K"),  we enclose
responses to the comment  letter dated August 11, 2005,  which we received  from
the staff of the Securities and Exchange Commission.  The following responses to
the comments are tied to the numbered paragraphs in the comment letter.

     1(a). All loans originated by  SecurityNational  Mortgage Company, a wholly
owned  subsidiary  of  the  Company,  are  funded  by two  affiliated  insurance
companies  under the terms of certain  loan  funding and fee  agreements.  These
agreements are between the mortgage  company and the two insurance  subsidiaries
of the Company -- Security  National  Life  Insurance  Company,  a wholly  owned
subsidiary of the Company,  and Southern  Security  Life  Insurance  Company,  a
wholly owned subsidiary of Security National Life Insurance  Company.  Under the
terms of these  agreements,  the insurance  subsidiaries  agree to fund mortgage
loans  for  SecurityNational  Mortgage  Company  and,  upon  completion  of  the
documentation  thereto,  all  rights  and  interest  in the loans  funded by the
insurance subsidiaries are immediately assigned to unrelated final institutions,
such as Countrywide Home Loan or CitiMortgage,  Inc.  SecurityNational  Mortgage
Company records  mortgage fee income,  commission  expense and other  associated
expenses when the loans are funded by the insurance subsidiaries and transferred
to the unrelated financial  institutions.  Fees on these loans are recorded as a
receivable and then eliminated upon receipt of cash.

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     The loans funded by the  insurance  subsidiaries  are then  transferred  to
unrelated financial institutions under line of credit agreements.  Proceeds from
the  line  of  credit  agreements  are  then  paid  directly  to  the  insurance
subsidiaries  that  initially  funded  the  loans.  All  rights and title to the
mortgage loans are then assigned to the unrelated  financial  institutions prior
to their advancing funds under the line of credit agreements.  Approximately 75%
of all loans are funded on outside warehouse lines.

     1(b). Mortgage fee income consists of origination fees, processing fees and
certain  other income  related to the sale of  mortgages.  For  mortgages  sold,
mortgage  fee income and related  expenses are  recognized  at the time the loan
meets the sales criteria for financial assets, which according to paragraph 9 of
SFAS 140, are (i) the transferred assets have been isolated from the Company and
its  creditors,  (ii) the  transferee  has the right to pledge or  exchange  the
mortgage,  and (iii) the Company  does not maintain  effective  control over the
transferred  mortgage.  Based on the mortgage loan funding and transfer  process
described in the preceding paragraphs,  the Company believes the three tests are
met and the  mortgages are  considered  sold at loan funding and the transfer to
the unrelated financial institutions is completed.

     1(c). Mortgage fee income consists of origination fees, processing fees and
certain other income fees related to the sale of mortgages.  Since all loans are
determined to be sold in accordance  with paragraph 9 of SFAS 140,  mortgage fee
income and expenses are  recognized at that time and not  deferred.  The Company
believes that it follows the guidance received in paragraph 27.c of SFAS 91.

     1(d).  In 2004,  the Company  adopted a policy to increase its purchases of
fixed  securities  held to maturity by $32,000,000 and also to increase its rate
of lending on commercial and  construction  loan portfolios by $35,000,000.  The
decrease in mortgage loans sold to investors is approximately $67,000,000, which
reflects this change in investment strategy. All these strategies pertain to the
insurance  subsidiaries  and the changes are reflected on their books and not on
the books of SecurityNational Mortgage Company.

     2. The Company  does not retain any  servicing  on the loans that are sold.
All loans are transferred or sold to investors as "servicing released."

     3. As described in the notes to financial  statements in the Company's Form
10-K for the year ended  December 31, 2004,  SecurityNational  Mortgage  Company
maintains a reserve for future loan  losses.  This  reserve was  established  to
offset any actual losses on loans sold to investors  due to  misrepresentations,
early payment defaults or other similar demands.  The estimates used are accrued
on a monthly basis based upon  historical  information  and the  Company's  best
estimate  of  future   recourse   based  on  current  and  prior  loan   funding
transactions.  The amount  currently  held in  reserve is listed on the  balance
sheet of the financial statements under other liabilities and accrued expenses.

<PAGE>

     4. The gains from sale of loans was  included in mortgage fee income in the
income statement of the financial statements, and was $14,786,000 and $7,051,000
for the fiscal years ended December 31, 2003 and 2004, respectively.

     5.  Although  the Company is a  registered  seller and  servicer  with both
Fannie Mae and Freddie Mac, it did not, as of December 31, 2004, have agreements
or  commitments  to sell  loans to these or any  other  investors  or  unrelated
financial  institutions.  As the  criteria  listed in paragraph 9 of SFAS 140 is
met,  all loans are  determined  to be sold and not held for sale.  As a result,
there are no forward  contracts.  Thus,  the  Company  believes  it applies  the
guidance in paragraph 3 of SFAS 149.

     Finally, this will confirm that the Company acknowledges the following: (i)
the Company is  responsible  for the adequacy and accuracy of the  disclosure in
the filings;  (ii) staff  comments or changes to disclosure in response to staff
do not  foreclose  the  Commission  from taking any action  with  respect to the
filing;  and (iii) the Company may not assert staff comments as a defense in any
proceeding  initiated by the Commission or any person of the federal  securities
laws of the United States.

     The  Company  has  prepared  these  responses  in an effort to address  the
comments from the staff. Any additional comments or questions should be directed
to Randall A. Mackey, Esq, at (801) 575-5000, counsel for the Company.

                                   Very truly yours,

                                   /s/ Randall A. Mackey

                                   Randall A. Mackey
Enclosures
cc:      Scott M. Quist
         G. Robert Quist
         Stephen M. Sill
         Virgil R. Pugsley
         Douglas D. Hawkes
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