SecProbe.io

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                         First Pacific Mutual Fund, Inc.
                       2756 Wooodlawn Drive, Suite #6-201
                              Honolulu, HI  96822
                                 (808) 988-8088

February 3, 2005

Ms. Christina Delano
Staff Accountant
United States Securities and Exchange Commission
Office of Compliance Inspections and Examinations
450 5th Street, NW
Washington, DC  20549

		RE:  First Pacific Mutual Fund, Inc. ("Group")

Dear Ms. Delano,

We are responding to your phone audit conducted on January 6, 2005.  Listed
below are the Group's responses to each of your questions/comments.

1.	The www.fpchawaii.com website contains outdated information.

The information contained on the fpchawaii.com website is outdated.  The
parent company changed its name from First Pacific Corporation to Lee
Financial Group Inc.  Subsequently, a domain name was being sought to
reflect the corporate name change and the fpchawaii.com website was being
redesigned.  Effective, February 1, 2005 the new domain, www.Leehawaii.com
will be available for use.  Leehawaii.com will have available current Group
information.

2.	The Form N-CSR contains the chart "$10,000 Investment in Fund Compared to
Lehman Muni Bund Index."  The 1 year average return figure does not
correlate with the plot points for the Hawaii Municipal Fund Investor
Class and the Hawaii Municipal Fund Institutional Class.

In future Group filings, the plot points will be verified with total return
figures.

3.	The Form N-CSR table for the Statement of Changes in Net Assets was not
EDGARized properly.

     The EDGAR help desk will be contacted for guidance on how to format tables
in a readable fashion.

4.	The Form N-CSR Notes to Financial Statements relating to Security
Valuation stated that "All other securities are valued at their fair
value as determined in good faith by the Board of Directors."  The
information should be expanded to include procedures used by the Board to
determine fair value.

Future Form N-CSR Group filings will contain the following statement:
Securities for which market quotations are not readily available will be
valued at their "fair value" in good faith.  For these purposes, "fair
value" means the price that the Fund Accountant and the Investment Manager
reasonably expect the Fund could receive from an arm's-length buyer upon the
current sale of the securities within seven (7) days, after considering all
appropriate factors and indications of value available to them.  Such value
will be cost if the Investment Manager determines such valuation is
appropriate after considering a multitude of factors in accordance with
established procedures.

5.	The Form N-CSR Notes to Financial Statements relating to Distribution
Costs should be enhanced to include disclosure of distribution costs by
class and by Fund.

Future Form N-CSR Group filings will contain the following statement:
The Plan provides that the Hawaii Municipal Fund Investor Class and the
Hawaii Intermediate Fund may incur certain costs, which may not exceed .25%
per annum of the Funds' average daily net assets, for payment to the
distributor for items such as advertising expenses, selling expenses,
commissions or travel, reasonably intended to result in sales of shares of
the Funds.  The Hawaii Municipal Fund Institutional Class will not incur any
distribution costs.

6.	Form N-CSR Item 3.(a)(3) should explain why the Board concluded it was
not necessary to have a financial expert.

Future Form N-CSR Group filings will contain the following statement:
(a)(3) The board of directors concluded that based on the required
attributes, no independent member of the Board qualified as a financial
expert.  Based on the size of the Fund, the Board further concluded that a
financial expert was not required.

Tandy Representation:
In connection with responding to comments from the Securities and Exchange
Commission, First Pacific Mutual Fund, Inc. (the "Fund") acknowledges that:

o	The Fund is responsible for the adequacy and accuracy of the
	disclosure in the filings;
o	Staff comments or changes to disclosure in response to staff
	comments in the filings reviewed by the staff do not foreclose the
	Commission from taking any action with respect to the filing; and
o	The Fund 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 any questions regarding this information, please contact me at
(302) 897-6782.

Sincerely,

/s/ Nora B. Simpson

Nora B. Simpson
Chief Compliance Officer

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