SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      June 29, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (334) 887-2772

Wayne Alderman
Director of Financial Operations
Auburn National Corporation
100 N. Gay Street
Auburn, Alabama 36830

Re:	Auburn National Corporation
	Form 10-K filed March 31, 2005
	File No. 0-26486

Dear Mr. Alderman:

	We have reviewed your response letter and have the following
comment.  Where indicated, we think you should revise your
document
in response to this comment.  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 our comment we ask you to provide us with supplemental
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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or 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 Year ended December 31, 2004

Note (1)(e). Summary of Significant Accounting Policies - Loans -
page 52

1. We refer to your response that the Company uses the effective
interest method required by paragraph 19 of SFAS 91 although the
footnote states you use the simple interest method. You conclude
the
difference in description is not material and propose including in
future filings a note stating you determine interest on loans by
using the effective interest method.

	In this regard, please provide us with the following
information:

* Describe what quantitative and qualitative materiality
assumptions
you used to determine that there are no material differences
between
using, or stating that you use, the simple interest method instead
of
the effective interest method required by SFAS 91.

* Explain the effects on the comparability of current and prior
years
financial information with respect to your proposal to state in
future filings that you are using the effective interest method
without having corrected the disclosure in prior years financial
statements which state you are using the simple interest method.
Consider in your response that your proposed disclosure in future
filings would be considered by a reasonable investor as a
correction
of an accounting error under APB 20 without having provided the
required restatement of your prior financial statements.

*	*	*

Closing Comments

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your amendment that keys your
response to our comment and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comment.

      You may contact Edwin Adames (Senior Staff Accountant) at
(202)
551-3447 or me at  (202) 551-3492 if your have any questions
regarding these comments.

						Sincerely,

						John P. Nolan
						Accounting Branch Chief
??

??

??

??

Wayne Alderman
Auburn National Corporation
Page 1 of 2

</TEXT>
</DOCUMENT>