SecProbe.io

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Mail Stop 4561

      							September 16, 2005

Via U.S. Mail and Fax (925) 935-1486
Mr. Bryan H. Draper
Chief Financial Officer and Secretary
Owens Financial Group, Inc.
2221 Olympic Boulevard
Walnut Creek, CA 94595

	RE:	Owens Mortgage Investment Fund, a California Limited
Partnership
      Form 10-K for the fiscal year ended December 31, 2004
		Filed March 24, 2005
Forms 10-QSB for the quarterly period ended March 31, 2005 and
June
30, 2005
		File No. 0-17248

Dear Mr. Draper:

      We have reviewed the above referenced filings and have the
following comments.  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 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.

Note (3) Loans Secured by Trust Deeds

1. Based on the information in Note (3) there appears to have been
a
deterioration in loan performance as the investment in impaired
loans
that were delinquent in payments, delinquent in principal and in
foreclosure with the borrower in bankruptcy, have increased from
December 31, 2003.  In light of these developments, clarify why no
provision for losses was recognized in 2004.

Note (4) Real Estate Held for Sale

(b) Investments in Limited Liability Companies

2. Please clarify to us whether your ownership interests in Oregon
Leisure Homes, LLC; Dation, LLC; and 720 University, LLC,
discussed
in Note (5), coincide with the distribution percentages disclosed.

3. Please tell us how you have accounted for your investment in
Dation, LLC.  Specifically clarify whether this investment is
consolidated or accounted for under the equity method.

Exhibits 31.1 and 31.2

4. We note that the certifications filed as Exhibits 31.1 and 31.2
to
your Form 10-K are not in the proper form.  The required
certifications must be in the exact form prescribed; the wording
of
the required certifications may not be changed in any respect.
Certain portions of the certifications 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 your current Principal Executive Officer and
Principal Financial Officer in the form currently set forth in
Item
601(b)(31) of Regulation S-K.  You should also revise your
disclosure
relating to Controls and Procedures included in Item 9A of your
filing to reflect the corrected wording of the certifications.

*    *    *    *

      As appropriate, please amend your filings 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
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that they
have provided 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 filings; 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 filings or
in
response to our comments on your filings.

      You may contact William Demarest, Staff Accountant, at (202)
551-3432 or me at (202) 551-3780 with any questions.

							Sincerely,

							Linda van Doorn
							Senior Assistant Chief
Accountant

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Mr. Bryan H. Draper
Owens Financial Group, Inc.
September 16, 2005
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