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May 13, 2005

Linda Van Doorn
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Washington, D.C. 20549

Dear Ms. Van Doorn:

This letter is a follow up response to our letter of May 2, 2005 that was
written in answer to your letter dated April 20, 2005 regarding the Commission's
review of our Form 10-K for the fiscal year ended December 31, 2004. We
acknowledge that we are responsible for the adequacy and accuracy of the
disclosures in this filing. We acknowledge that neither your comments nor
changes to disclosure that we make in response to your comments foreclose the
Commission from taking any action with respect to the filing. We also
acknowledge that we may not assert your comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.

Comment:
You asked for additional clarification on Note 1 to the consolidated financial
statements, specifically item (d) Revenue Recognition, page A-10. You asked for
us to clarify the basis for recognizing management fee revenue including the
profit sharing component.

Response:
The second paragraph of item (d) now reads:

         Our insurance services revenues related to management fees are
         recognized monthly as a percentage of the earned premiums of the
         managed company. The profit sharing component of the management
         services agreement is recognized when it is reasonable certain that the
         managed company will have an annual profit, generally in the fourth
         quarter of each year.

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We propose replacing the second paragraph in its entirety in all future filings,
as follows:

         Our insurance services revenues related to management fees are
         recognized monthly at 13.5% of the earned premiums of the managed
         company. We also share equally any profits of the managed company, to a
         maximum of 3% of earned insurance premiums. Any past losses of the
         managed company are carried forward and applied against earnings before
         any profits are shared. The profit sharing component is recorded in the
         fourth quarter based on the audited financial results of the managed
         company.

You may contact me at 512-314-4403 if you have any further questions.

Sincerely,

/s/ W.H. Hayes
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W.H.Hayes
Senior Vice President

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