SecProbe.io

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Mail Stop 6010

      July 25, 2005

VIA U.S. MAIL AND FAX (251) 368-9797

Mr. Mitchell D. Staples
Principal Financial Officer
United Bancorporation of Alabama, Inc.
P.O. Drawer 8
Atmore, Alabama  36504

	Re:	United Bancorporation of Alabama, Inc.
		Form 10-K for the year ended December 31, 2004
		Filed March 30, 2005
		File No. 000-25917

Dear Mr. Staples:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may or may not
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
filings.
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.

Form 10-K for the year ended December 31, 2004

Consolidated Financial Statements

Report of Independent Registered Public Accounting Firm, page F-1
1. We note that your Report of Independent Registered Public
Accountants is signed by Maudlin & Jenkins, LLC.  We note that the
firm appears to be registered with the PCAOB as Mauldin & Jenkins,
Certified Public Accountants and Consultants, L.L.C. Please tell
us
whether your accounting firm has listed both names on their PCAOB
application or if the firm has changed their legal name.  If both
names are registered with the PCAOB, please also include the
accounting firm`s PCAOB registered name on audit reports in future
filings.  Alternatively, if the accounting firm has changed their
legal name, tell us whether they have notified the PCAOB of this
change.

Note 1.  Summary of Significant Accounting Policies, page F-9

(f) Loans, page F-10
2. In future filings, please disclose the method you use to
recognize
interest income on loans.  Please also disclose your policy for
the
recognition of loan fees and costs, including the method of
amortizing net deferred fees or costs.

Exhibit 31.1 and 31.2
3. We note that the Section 302 certifications were not in the
proper
form. The required certification must be in the exact form
prescribed; the wording of the required certification may not be
changed in any respect.  Certain portions of the certification
relating to internal control over financial reporting may be
omitted
as stated in Section III.E. of SEC Release No. 33-8238.
Accordingly,
please file an amendment to your Form 10-K that includes the
entire
filing together with the certifications of each of your current
CEO
and CFO in the form currently set forth in Item 601(b)(31) of
Regulation S-K.

      As appropriate, please amend your Form 10-K for the year
ending
December 31, 2004 and respond to these comments within 10 business
days or tell us when you will provide us with a response.  You may
wish to provide us with marked copies of the amendment to expedite
our review.  Please furnish a cover letter that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review.  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 includes 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 Kristin Lochhead, Staff Accountant, at (202)
551-3664 or me at (202) 551-3676 if you have any questions
regarding
these comments.  In this regard, do not hesitate to contact Martin
James, the Senior Assistant Chief Accountant, at (202) 551-3671

								Sincerely,

								Brian Cascio
								Accounting Branch Chief
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Mr. Staples
United Bancorporation of Alabama, Inc.
July 25, 2005
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