SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

       DIVISION OF
CORPORATION FINANCE

           September 23, 2010  Mr. Edward C. DeFeudis President and Chief Financial Officer WikiLoan, Inc. 1093 Broxton Avenue, Suite 210 Los Angeles, CA  90024

Re: WikiLoan, Inc.
 Form 10-K for Fiscal Year Ended January 31, 2010  Filed May 17, 2010  Form 10-Q for Fiscal Quarter Ended April 30, 2010  Filed June 21, 2010  Form 10-Q for Fiscal Quarter Ended July 31, 2010  Filed September 13, 2010  File No. 033-26828

Dear Mr. DeFeudis:

We have reviewed your filing and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your docum ent.  Where indicated, we
think you should revise your docum ent 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 deta iled as necessary in your expl anation.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.  After reviewing this info rmation, we may raise additional comments.
 Please understand that the purpose of our re view 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 comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Edward C. DeFeudis
WikiLoan, Inc.
September 23, 2010 Page 2 of 3  Form 10-K for Fiscal Year Ended January 31, 2010

 Report of Independent Registered Public Accounting Firm, page F-1

1. We note that your independent accountant’s report, as included in your Form 10-K, does not include the name of the accounting firm or a conformed signature.  Please amend your filing to provide an i ndependent accountant’s report that fully
complies with Item 2-02(a) of Regulati on S-X and Rule 302 of Regulation S-T.
Please ensure that your amendment comp lies with Exchange Act Rule 12b-15.

Note 7. Convertible Notes Payable, page F-9

2. We note you have convertible notes paya ble outstanding at each of January 31,
2010, January 31, 2009 and at July 31, 2010 which were issued in current and
prior periods.  It appears that the conv ersion feature of each of these notes is
based on a conversion price equal to the ten day average closing price of your common stock multiplied by a factor ranging from .75 to .80 of such ten day average closing price.  Ther efore, it appears that each  of these convertible notes
payable may have had a beneficial convers ion feature at the time of issuance.
Please tell us how you considered th e guidance in ASC 470-20-25-4 through 25-9
and ASC 470-20-30-3 through 30-10 in r ecognizing the beneficial conversion
features for each issuance of these notes payable in your financial statements and
how your accounting was in accordance with GAAP.
 Forms 10-Q for Fiscal Quarters Ended April 30, 2010 and July 31, 2010

 Certifications

3. Please amend these filings to provide the certifications of your Chief Executive
Officer required by Item 601(B)(31 )(i) and (32) of Regulation S-K.

As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent 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 co ver letters greatly faci litate our review.
Please understand that we may have addi tional 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 filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are

Mr. Edward C. DeFeudis
WikiLoan, Inc. September 23, 2010 Page 3 of 3  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
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     You may contact Sondra Snyder at ( 202) 551-3332 or me at (202) 551-3737 if
you have questions regarding the comments or any other matters.

Sincerely,

Jennifer Thompson
 Branch Chief