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CORRESP
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First Community
Corporation
First Community Bank, N.A.
5455 Sunset Boulevard

Lexington, South Carolina 29072

November 16, 2005

Via EDGAR

John P. Nolan
Accounting
Branch Chief
Securities and Exchange Commission
Division of Corporate
Finance, Office of Financial Services
450 Fifth Street, N.W.
Washington, D.C. 20549

     Re:

     First Community Corporation

     Amendment to Form 10-K filed on March 23, 2005

     File No. 0-28344

Dear Mr. Nolan:

        On
behalf of First Community Corporation (the “Company”), the undersigned is hereby
transmitting this response to the Staff’s comment letter dated September 9, 2005. The
paragraphs below respond to the Staff’s numbered comments.

Form 10-K for the Year
ended December 31, 2004

Description of Business,
General, page 1

          1.

          Please tell us and revise to state if you continue to qualify as a Small
          Business filer under the requirements of Item 10(a) and (b) of Regulation S-B
          after the acquisition of DutchFork Bancshares (“DutchFork”) in October
          2004. In this regard we note you filed a 10-KSB for the year ended December 31,
          2004 but filed Form 10-Qs for the three and six month periods ended March 31,
          2005 and June 30, 2005, respectively.

As
of December 31, 2005, the Company no longer met the requirements to qualify as a small
business  issuer. The Company exceeded the public float limitation for each of the
fiscal years ended December  31, 2003 and 2004. As a result, we do not believe an
amendment to the 10-KSB is necessary.

Disclosure that the Company no longer qualifies as a Small Business filer will be made in future
filings  beginning with the September 30, 2005 10-Q.

Provision and Allowance
for Loan Losses, page 22

          2.

          We refer to the statement that as of December 31, 2003 management implemented a
          system for allocating the allowance for loan losses to specific
          components of the loan portfolio and that prior to that date the allowance
          was allocated on an overall portfolio basis. In this regard, provide us
          with the following information:

•

The authoritative accounting or regulatory basis you relied upon prior to December 31,
2003 to use the overall portfolio basis for allocating the loan loss allowance;

•

The factors that prompted the Company to change its methodology for allocating the loan
loss allowance in 2004.

•

The effects on the allowance for loan losses due to the changes in the allocation
methodology in 2004 as compared to prior periods.

The statement referred to in the comment above was not based on authoritative accounting or
regulatory  guidance. The statement was made to inform the reader as to the basis
for not including the table in  the format outlined in the Securities Act Industry
Guide for bank holding companies (Guide 3) prior to  December 31, 2003. Footnote 2
of the Guide 3 instructions to the table provide that “In lieu of the
breakdown of the allowance for loan losses by loan category called for, the registrant
may furnish a  narrative discussion of the risk elements in the loan portfolio and
the factors considered in  determining the amount of the allowance for loan
losses.”

In all filings prior to December 31, 2003, the Company disclosed that management evaluated
the allowance  on an overall portfolio basis and would implement and allocate the
allowance to various loan categories  at the time the size and mix of the portfolio
supported a meaningful allocation system. Because the  bank was formed in August
1995 and had limited historical loss experience during the initial years of
operation, past due statistics and historical migration analysis and other factors that
assist in  developing the allocation were not supportive of a meaningful allocation
system.

The change to allocating the allowance for loan losses to loan categories and presenting the
table as  per the instructions to Guide 3 had no financial statement effect on the
allowance for loan losses.  Management has consistently applied the methodology,
whether reviewing portfolio segments or the  portfolio as a whole, used to develop
the estimation of credit losses by evaluating all of the factors  available. The
process includes detailed and regular analyses of the loan portfolio including a review
 of large loans and groups of loans. Management estimates the credit losses by
evaluating all of the  factors and utilizing the common elements outlined in
paragraph 9.05 of the AICPA Audit and Accounting  Guide for
Depository and Lending Institutions.

A sample of the disclosure that will be included in future filings is shown in response to
question  number 3. The table outlined in Guide 3 has been included in the filings
since December 31, 2003 and  will be included in future filings.

          3.

          We refer to the following statements by the Company regarding how it determined
          its loan loss allowance:/FONT>

•

The provision of $245,000 in 2004 maintained the allowance for loan loss within
management’s desired  levels.

•

It was the objective of management to fund the allowance at approximately 1.1% to
1.5% of total loan until a tested historical experience has been established.

In this regard, please tell us the methodology that management uses, considering the
requirements of SFAS 5 and SFAS 114, to determine the adequacy of the loan loss allowance.
Refer in your response to how you considered paragraph 9.19 of the AICPA Audit and
Accounting Guide for Depository and Lending  Institutions which states the
allowance for loan losses should be established in conformity with generally accepted
accounting principles rather than in accordance with specified percentages.

To determine the adequacy of the allowance for loan losses, a formal analysis is completed
quarterly to  assess the risk within the loan portfolio. The portfolio is
segregated into similar risk components for  which historical loss ratios are
calculated and adjusted for identified changes in current portfolio
characteristics. Historical loss ratios are calculated by product type and by

 regulatory credit risk classification. The allowance for loan losses consists of an
allocated and unallocated allowance. The  allocated portion is determined by types
and ratings of loans within the portfolio. The unallocated  portion of the
allowance is established for losses that exist in the remainder of the portfolio. This
 also compensates for uncertainty in estimating the loan losses. Nonperforming
commercial loans (both  real estate and non real estate) are reviewed for
impairment. Impairment is measured in accordance with  SFAS 114, “Accounting
by Creditors for Impairment of a Loan” and loans are either assigned a specific
allocation or charged-off if deemed uncollectible. Substantially all loans historically
identified as  impaired have been collateral dependent and the fair value of the
underlying collateral has been used to  determine the amount of impairment.

The
statement that the provision of $245,000 maintained the allowance within management’s
desired levels  was made to reinforce that this was the estimated provision to
maintain the allowance at the appropriate  level based on management’s
analysis of estimated losses inherent in the portfolio.

In addition, the reference to the ratio of the allowance to loan loss relates to historical
percentages  rather than a specific target.

The Company has access to all of the GAAP and supervisory guidance referred to in paragraph
9.19 of  AICPA Audit and Accounting Guide for Depository and Lending
Institutions. Management has and will  continue to:

•

Maintain adequate controls to ensure ALLL is consistent in accordance with GAAP, stated
policies and  procedures, and relevant supervisory guidance.

•

Develop, maintain and document a comprehensive, and consistently applied process to
determine the  amounts of the ALLL and provision for loan losses.

•

Maintain the ALLL at a level that is appropriate to absorb estimated credit losses
inherent in the loan  portfolio, consistent with long-standing supervisory
guidance.

•

Utilize prudent, conservative, but not excessive, judgment to determine that the ALLL
represents  management’s best estimate from within an acceptable range of
estimated losses.

Provided below is a revised supplemental disclosure that describes the process management uses to
 determine its loan loss allowance. The required tables were included in the 10-KSB
and have not been  included. The process described has been included in the 10-Q
filed for September 30, 2005. Future  filings will clearly reflect the methodology
that management uses to determine the adequacy of the  allowance for loan losses,
considering the requirements of SFAS 5 and SFAS 114. The reference to “fund
the allowance at approximately 1.1% to 1.5% of total loans” has been deleted from
the discussion.

At December 31, 2004, the allowance for loan losses amounted to $2.8 million, or 1.48% of
total  loans, as compared to $1.7 million, or 1.41% of total loans, at December 31,
2003. Included in  the allowance for loan losses at December 31, 2004 is the amount
of $995,000 purchased in the  merger, with DutchFork. The company’s provision
for loan loss was $245,000 for the year ended  December 31, 2004 as compared to
$167,000 and $677,000 for the years ended December 31, 2003  and 2002. Due to
declining economic conditions and increased charge-offs the in 2001 and 2002  the
allowance was funded at higher amounts for these periods. During the first six months of
 2003, the company experienced a recovery on a loan charged off in a prior period
which resulted  in the allowance being funded at a lower amount during this period.

Management has established loan policies and review processes to ensure that its loan loss
allowance is adequate. The provision is made based on management’s assessment of
general loan  loss risk and asset quality. The allowance for loan losses represents
an amount which we  believe will be adequate to absorb probable losses on existing
loans that may become  uncollectible. Our judgment as to the adequacy of the
allowance for loan losses is based on a  number of assumptions about future events,
which we believe to be reasonable, but which may or  may not prove to be accurate.
Our determination of the allowance for loan losses is based on  evaluations of the
collectibility of loans, including consideration of factors such as the  balance of
impaired loans, the quality, mix, and size of our overall loan portfolio, economic
conditions that may affect the borrower’s ability to repay, the amount and quality
of  collateral securing the loans, our historical loan loss experience, and a
review of specific  problem loans. All loan relationships with aggregate credit of
$500,000 or more are reviewed  annually and loans regardless of amount criticized
or classified by management in accordance  with regulatory guidelines are reviewed
quarterly. We also consider subjective issues such as  changes in the lending
policies and procedures, changes in the local/national economy, changes  in volume
or type of credits, changes in volume/severity of problem loans, quality of loan
review, board of director oversight, and concentrations of credit. Periodically, we
adjust the  amount of the allowance based on changing circumstances. We charge
recognized losses to the  allowance and add subsequent recoveries back to the
allowance for loan losses.

Management performs an analysis quarterly to assess the risk within the loan portfolio. The
portfolio is segregated into similar risk components for which historical loss ratios
are  calculated and adjusted for identified changes in current portfolio
characteristics.  Historical loss ratios are calculated by product type and by
regulatory credit risk  classification. The allowance consists of an allocated and
unallocated allowance. The  allocated portion is determined by types and ratings of
loans within the portfolio. The  unallocated portion of the allowance is
established for losses that exist in the remainder of  the portfolio and
compensates for uncertainty in estimating the loan losses.

There
can be no assurance that charge-offs of loans in future periods will not exceed the
allowance for loan losses as estimated at any point in time or that provisions for loan
losses  will not be significant to a particular accounting period. The allowance is
also subject to  examination and testing for adequacy by regulatory agencies, which
may consider such factors as  the methodology used to determine adequacy and the
size of the allowance relative to that of  peer institutions. Such regulatory
agencies could require us to adjust our allowance based on  information available
to them at the time of their examination.

At December 31, 2004, 2003 and 2002 the company had $19,000 in loans delinquent more than 90
 days and still accruing interest. There were loans totaling $411,000, $96,000 and
$340,000 in  loans that were delinquent 30 days to 89 days at December 31, 2004,
2003 and 2002,  respectively. The company had no loans in a nonaccrual status at
December 31, 2004 and $80,000  and $144,000 at December 31, 2003 and 2002,
respectively. Loans are generally placed in a  non-accrual status when they become
90 day delinquent. The charge-offs experienced in 2004 and  2003 related to loans
that were identified and charged-off within those respective periods.  Management
continuously monitors non-performing, classified and past due loans to identify
deterioration regarding the condition of these loans. Management has not identified any
 classified loans that are not included in non-performing assets that could are
considered to be  potential problem loans as of December 31, 2004.

          4.

          We refer to the statement that the Company as of December 31, 2004 had no
          loans on a non-accrual  status. Please tell and revise to explain the basis
          for this statement considering the following factors:

•

The Company recorded write-offs of $294,000 in 2004 and $235,000 in 2003 that appear to
relate to non-performing loans that developed in 2004 considering you only had $80,000 on
non-performing loans in 2003.

•

The large loan recovery in 2003 was due to a loan charged off prior to 2003 that
was recovered during that year. Refer to the “Results of Operations” section of
MD&A on page 18.

•

The apparent acquisition of $550,000 of non-performing loans as part of the purchase of
DutchFork in 2004. Refer in your response to the status of the non-accrual loans described
in Note 4, “Loans Receivable” of the financial statements of DutchFork as of
September 30, 2003 in the Form S-4 filed on July 7, 2004.

The Company had no nonaccrual loans at December 31, 2004. As stated in the MD&A, a loan is
generally  placed in nonaccrual status when it becomes 90 days or more past due.

The $80,000 in non-accrual loans at December 31, 2003 relates to two credits that were
subsequently  collected in full during 2004. The $294,000 in write-offs in 2004
relate to loans that became a problem  in 2004 and were timely charged-off. The
Company has continually maintained a policy to recognize  charge-offs timely. If a
loan is recognized as uncollectible prior to becoming 90 days delinquent, it  is
charged-off prior to the 90 day period.

Similar to the circumstances in 2004, subsequent to December 31, 2004, the Company had total
charge-offs  of approximately $280,000 of which approximately $270,000 represented
two credits that were identified  as problems in the first quarter of 2005. The
circumstances underlying these credits are discussed in  response to your comment
number 6.

The recovery referred to in your comment above related to an insurance settlement on a loan
charged off  in 2001. The charge off in 2001 was made and it was not anticipated
that the Compan