SecProbe.io

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Mail Stop 6010
      September 29, 2005

Mr. H. Averett Walker
President, Director and Chief Executive Officer
Security Bank Corporation
4219 Forsyth Road
Macon, Georgia 31210

      Re:	Security Bank Corporation
		Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 16, 2005
Forms 10-Q for the Quarterly Periods Ended March 31, and June 30,
2005
      File No. 000-23261

Dear Mr. Walker:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  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 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.

Form 10-K for the Fiscal Year Ended December 31, 2004

Item 9a. Controls and Procedures, page 53

1.	We note your disclosure that your "Chief Executive Officer
and
principal Financial and Accounting Officer concluded that [y]our
disclosure controls and procedures provide reasonable assurance of
their effectiveness for gathering, analyzing and disclosing the
information that [you] are required to disclose in the reports
that
[you] file under the Securities Exchange Act of 1934, within the
time
periods specified in the SEC`s rules and forms.  [Your] Chief
Executive Officer and Principal Financial and Accounting Officer
also
concluded that [your] disclosure controls and procedures provide
reasonable assurance of their effectiveness in timely alerting
them
to material information relating to [your] company (including its
consolidated subsidiaries) required to be included in our periodic
SEC filings."  The language that is currently included after the
word
"effectiveness" in your disclosure does not appear to be
consistent
with the meaning of disclosure controls and procedures as
established
by Rule 13a-15(e) of the Exchange Act. As such, it does not appear
that your certifying officers have reached a conclusion that your
disclosure controls and procedures are effective.  Please revise
to
address your officers` conclusions regarding the effectiveness of
your disclosure controls and procedures.  In addition, please note
that if you wish to include the definition of disclosure controls
and
procedures following your conclusion, please ensure the definition
is
consistent with the definition included in Rule 13a-15(e) of the
Exchange Act.  Please similarly revise your March 31, and June 30,
2005 Forms 10-Q.

2. We note your disclosure that there were "no significant changes
in
your internal controls or in other factors that could
significantly
affect internal controls subsequent to the date of this
evaluation,
and there have been no corrective actions with respect to
significant
deficiencies or material weaknesses."  To the extent that your
disclosure was provided to address Item 308(c) of Regulation S-K
which requires disclosure of any change that occurred during the
quarter that materially affected, or is reasonably likely to
materially affect, your internal control over financial reporting,
please note that the need for disclosure is not limited to
significant changes that could affect your internal control over
financial reporting subsequent to the date of your evaluation.
Please correct the disclosure in future filings, including the
amended 2004 Form 10-K and the amendments to your March 31, and
June
30, 2005 Forms 10-Q, to address all changes or advise us.

Exhibits 31.1 and 31.2

3.	We note that the certifications filed as Exhibits 31.1 and
31.2
were 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, except for the modifications
temporarily permitted to be made to the fourth paragraph of the
certification required to be filed as Exhibit 31.1 pursuant to
Part
III.E of Release No. 8238. Accordingly, please file an amendment
to
your Form 10-K that includes the entire filing together with the
certifications of each of your current CEO and CFO in the form
currently set forth in Item 601(b)(31) of Regulation S-K.  Please
similarly amend your March 31, and June 30, 2005 Forms 10-Q.

      As appropriate, please amend your Form 10-K for the fiscal
year
ended December 31, 2004 and Forms 10-Q for the quarterly periods
ended March 31, and June 30, 2005 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
amendments to expedite our review.  Please furnish a cover letter
with your amendments 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 amendments 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 information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed 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 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 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 filing or in
response to our comments on your filing.

	You may contact Kate Tillan, Assistant Chief Accountant, at
202.551.3604 or me at 202.551.3671 if you have any questions.

      Sincerely,

      Martin James
      Senior Assistant Chief
        Accountant

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H. Averett Walker
Security Bank Corporation
September 29, 2005
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