SecProbe.io

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Mail Stop 0409

VIA U.S. MAIL AND FAX (952)945-9433

Philip J. Myers
American Church Mortgage Company
10237 Yellow Circle Drive
Minnetonka, MN 55343

Re:	American Church Mortgage Company
	Form 10-K for the year ended December 31, 2004
      File No. 33-87570

Dear Mr. Myers:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  As such, all persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.

      Where indicated, we think you should revise your document in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comments are 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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Management`s Discussion and Analysis or Plan of Operation.

Loan Loss Reserve Policy, page 18

1. We note your disclosure regarding the three troubled loans held
by
the Company as of year end and the related reserve of
approximately
$70,000.  In a supplemental response to us please tell us the
reserve
applied to each loan described in your disclosure and how that
reserve was assessed based on your policy as disclosed on page 19
of
your filing.

Financial Statements

1. Summary of Significant Accounting Policies

Bond Portfolio, page F-8

2. In a supplemental response to us, please explain how you
determined that the fair value of your bond portfolio approximates
cost.  Include in your response a discussion of the methodology
used
by the Company to calculate fair value.  Additionally, we note
your
disclosure in footnote 2 to your financial statements that bonds
receivable are carried at amortized cost.  Please confirm to us
whether you are accounting for your bonds receivable at fair value
in
accordance with the guidance of SFAS 115 related to available for
sale securities, or at amortized cost.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your response to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain 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 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 Robert Telewicz, Staff Accountant, at (202)
824-5356 or the undersigned at (202) 942-1964 if you have
questions.

						Sincerely,

Linda van Doorn
Senior Assistant Chief Accountant

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American Church Mortgage Company
April 13, 2005

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