SecProbe.io

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                 NATIONAL HOUSING PARTNERSHIP REALTY FUND TWO
                         55 Beattie Place, P.O. Box 1089
                              Greenville, SC 29602

July 14, 2005

Correspondence Filing Via Edgar and Overnight Delivery

United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 4561
450 Fifth Street, NW
Washington, D.C.  20549
Attn:  Mr. Steven Jacobs

Re:   National Housing Partnership Realty Fund Two
      Form 10-KSB for the year ended December 31, 2004 File No. 0-14458

Ladies and Gentlemen:

This letter responds to the comments of the staff of the Securities and Exchange
Commission (the "Staff")  addressed to National Housing  Partnership Realty Fund
Two, a Maryland limited partnership (the "Partnership"),  in a letter dated June
15, 2005, which was sent in response to the Partnership's  June 9, 2005 response
to the Staff's  second  comment  letter  dated May 25,  2005,  which was sent in
response  to the  Partnership's  May 10, 2005  response to the Staff's  original
comment letter dated April 13, 2005. The  Partnership's  response to the Staff's
comments are set forth below and are numbered to  correspond to the numbering of
the Staff's comments in the Staff's letter dated June 15, 2005.

                        *     *     *     *     *

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

Financial Statements and Notes

Note 1 -  Summary  of  Partnership  Organization  and  Significant  Accounting
Policies

Recent Accounting Pronouncements

1.       Comment:  Considering the disproportionate voting rights of the
         Partnership  and your  response to our May 25, 2005 comment 2 stating
         the   Partnership   has  not   identified   parties  other  than  the
         Partnership  and NHP, a related party,  involved in the activities of
         the local limited  partnerships,  and for whom these  activities  are
         conducted,  it appears you have met the criteria in  paragraph  5(c).
         Please  explain  how  you  have  concluded  that  the  local  limited
         partnerships  are not VIEs  under  paragraph  5(c) as  stated in your
         response to our April 13, 2005 comment 2 in light of these facts.

         Response:  After  considering the Staff's comments and the requirements
         of FIN 46R,  the  Partnership  has  concluded  that the  local  limited
         partnership  is a VIE because it meets the criteria in paragraph  5(c).
         The Partnership's  prior conclusion that the local limited  partnership
         is not a VIE did not properly consider footnote 11 to paragraph 5(c) of
         FIN 46R, which states in part "activities that involve or are conducted
         on behalf of the related parties of an investor with disproportionately
         few voting  rights shall be treated as if they involve or are conducted
         on behalf of that investor".  In instances in which the general partner
         of the local limited  partnership is The National Housing  Partnerships
         ("NHP"),  activities  that  involve or are  conducted  on behalf of the
         general partner of the local limited  partnership must be treated as if
         they involve or are conducted on behalf of the  Partnership  due to the
         related party relationship between NHP and the Partnership. Because the
         activities  of the local limited  partnership  does not involve and are
         not conducted on behalf of parties other than NHP and the  Partnership,
         it is  necessary  to  treat  substantially  all  of the  activities  as
         involving or being conducted on behalf of the Partnership, the investor
         with disproportionately few voting rights. Therefore, the local limited
         partnership meets the conditions in paragraph 5(c) and is a VIE.

         The Partnership has considered the requirements of paragraphs 16 and 17
         of FIN 46R and determined that the general partner is the member of the
         related party group that is most closely associated with, and therefore
         is the primary  beneficiary of, the local limited  partnership  that we
         now  consider  to be a VIE based on our  reconsideration  of  paragraph
         5(c).  Accordingly,  the Partnership should not consolidate the VIE and
         the basic  financial  statements are not affected by the  Partnership's
         determination that the local limited partnership is a VIE.

         The  Partnership  will revise its disclosure of significant  accounting
         policies in future filings to include information required by paragraph
         24 of FIN 46R as it applies to the local limited  partnership  that was
         determined to be a VIE.

2.       Comment:  Given the related party relationship of the Partnership and
         the general partner of the local limited  partnerships,  please explain
         the  substance  of the  Partnership's  ability  to remove  the  general
         partner  without  cause.  Please  provide  the  relevant  terms  of the
         partnership agreements, as applicable.

         Response:  NHP, as general  partner of the  Partnership  has  fiduciary
         responsibilities  to  the  limited  partner  of  the  Partnership.  The
         Partnership  believes  that these  fiduciary  responsibilities  provide
         substance to the Partnership's ability to remove the general partner of
         the local limited partnership without cause.  However, the right of the
         Partnership to remove the general partner without cause is a moot issue
         as  it  impacts  the   determination   of  whether  the  local  limited
         partnership is a VIE, based on the Partnership's  revised determination
         that the local limited  partnership is a VIE as discussed  above in the
         response to comment 1.

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                                    * * * * *

As requested by the Staff in its letter  dated April 13, 2005,  the  Partnership
again acknowledges that: (a) the Partnership is responsible for the adequacy and
accuracy of the  disclosure  in the  filings;  (b) Staff  comments or changes to
disclosure in response to Staff  comments do not foreclose the  Commission  from
taking any action with respect to the filings;  and (c) the  Partnership 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.

If you have further questions regarding the information provided, please contact
the undersigned or Stephen Waters.  Mr. Waters can be reached  directly at (864)
239-1554 or by fax at (864) 239-5824.

                                    Sincerely,

                                    /s/ David R. Robertson
                                    David R. Robertson
                                    President and Chief Executive Officer of
                                    National Corporation for Housing
                                    Partnerships, the general partner of The
                                    National Housing Partnership, the general
                                    partner of National Housing Partnership
                                    Realty Fund Two

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