SecProbe.io

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April 22, 2005

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC   20549

Attention: Robert Telewicz, Staff Accountant

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

Mr. Telewicz:

     We are in receipt of the  Commission's  letter  dated  April 13, 2005 which
requests  additional  information  regarding  American Church Mortgage Company's
("ACMC") Loan Loss Reserve Policy and valuation of our Bond  Portfolio.  We have
prepared the following responses to the Commission's questions below.

Loan Loss Reserve Policy, Page 18

     We disclosed in our Form 10-KSB that we currently have three loans that are
three or more payments in arrears. Listed below are the details to each of these
loans and the loan loss reserve amount applied to each loan.

Loan #1:   Name:                              Unity of Faith Christian Center
           Original Loan:                     $426,000
           Funding Date:                      05/31/2002
           Collateral Appraised Value:        $1,065,000
           Current Balance Outstanding:       $403,378
           Loan to Value:                     40.00%

     On May 31, 2002, a Deed of Trust and Assignment of Rents was filed with the
County  of  Edgecome,  in the  State of North  Carolina  between  Unity of Faith
Christian  Center  ("Unity")  and ACMC.  The Deed of Trust  secures  ACMC with a
mortgage on the Church's real property representing  collateral for a promissory
note in the principal sum of FOUR HUNDRED TWENTY SIX THOUSAND and 00/100 Dollars
($426,000)  made  to the  Church  by  ACMC.  Unity's  current  mortgage  balance
outstanding as of December 31, 2004 was $403,378.

     Unity has missed a total of five mortgage payments in 2003 and one mortgage
payment in 2004. The total amount in arrears as of December 31, 2004 is $20,128.
Unity owns two church properties valued at $1,065,000.  The first property known
as the  Cokey  Road  property  is  currently  being  rented  by  another  church
congregation.  This  congregation  has entered into an  agreement  with Unity to
purchase this property for $389,000.  This is a lease to own purchase agreement.
All proceeds from the sale of the property  will be used to  "pay-down"  Unity's
mortgage  indebtedness  with ACMC.  The  purchasing  congregation  is working on
obtaining  financing  to purchase  the Cokey Road  property.  Unity's  remaining
property valued at  approximately  $670,000 will continue to serve as collateral
for the  remaining  balance of the loan once the sale of the Cokey Road property
is

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Securities and Exchange Commission
April 22, 2005
Page Two

completed. The closing of the sale of the Cokey Road property is to occur within
the next 60 to 90 days. There is no assurance that the  congregation  purchasing
the  Cokey  Road  property  will be able to  obtain  financing.  We have been in
contact with Unity's  Senior  Pastor as well as the Church's  Treasurer and with
their  cooperation  are monitoring the sale of the Cokey Road property.  We have
reserved $8,520 toward Unity's missed  mortgage  payments as defined in our loan
loss reserve  policy.  It is the opinion of ACMC's loan committee that $8,520 is
an adequate loan loss reserve  amount since the  collateral  against our loan is
only 40% of the appraised value of all of Unity's properties.

Loan #2:      Name:                                       Abundant Faith Ohio
              Original Loan:                              $400,000
              Funding Date:                               08/06/2002
              Collateral Appraised Value:                 $634,000
              Current Balance Outstanding:                $390,161
              Loan to Value:                              63.00%

     On August 6, 2002, a Mortgage  Security  Agreement and  Assignment of Rents
and Revenues was filed with the County of Cuyahoga, in the State of Ohio between
Abundant Faith Apostolic  Church  ("Abundant")  and ACMC. The Mortgage  Security
Agreement   secures  ACMC  with  a  mortgage  on  the  Church's   real  property
representing  collateral  for a  promissory  note in the  principal  sum of FOUR
HUNDRED  THOUSAND  and  00/100  Dollars  ($400,000)  made to the Church by ACMC.
Abundant's  current  mortgage  balance  outstanding  as of December 31, 2004 was
$390,161.

     Abundant  borrowed funds from ACMC to purchase and renovate its new worship
facility  located at 504 E. 149th Street in Cleveland,  Ohio. The renovations of
the new church  facility  have not been  completed and Abundant  stopped  making
mortgage  payments in October 2003.  The  congregation  is no longer meeting and
Abundant has not made any mortgage  payments  since  September of 2003.  We have
engaged legal  counsel and have began  foreclosure  against the Church.  We have
filed  complaints  against the Church,  the Church's Senior Pastor,  the Project
Manager  and the  General  Contractor.  We  began  foreclosure  on the  Church's
property in April of 2004 and expect to take  possession of the property  within
the next 60 to 90 days.  We will  list the  property  for sale  through  a local
real-estate   agent.   The  building  is  secure  and  our   collateral  is  not
deteriorating.  We have  applied our loan reserve  policy  against this loan and
have reserved  $20,000  against the balance of the loan as well as an additional
$15,000 for attorney and court costs. It is the opinion of ACMC's loan committee
that $35,000 is an adequate loan loss reserve  amount  against this loan at this
time.

Loan #3:    Name:                                 Ark Ministries of Tyler, Inc.
            Original Loan:                        $347,000
            Funding Date:                         08/06/2002
            Collateral Appraised Value:           $487,000
            Current Balance Outstanding:          $339,095
            Loan to Value:                        71.00%

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Securities and Exchange Commission
April 22, 2005
Page Three

     On August 6, 2002, a Deed of Trust and  Assignment  of Rents was filed with
the County of Smith, in the State of Texas between Ark Ministries of Tyler, Inc.
("Ark  Ministries")  and ACMC. The Deed of Trust secures ACMC with a mortgage on
the Church's real property representing  collateral for a promissory note in the
principal sum of THREE HUNDRED  THOUSAND and 00/100 Dollars  ($300,000)  made to
the Church by ACMC.

     On April 29, 2003, a Supplemental Deed of Trust and Assignment of Rents was
filed with the County of Smith,  in the State of Texas between Ark Ministries of
Tyler, Inc. ("Ark  Ministries") and ACMC. The Deed of Trust secures ACMC with an
additional mortgage on the Church's real property representing  collateral for a
promissory  note in the principal sum of FORTY SEVEN THOUSAND and 00/100 Dollars
($47,000) made to the Church by ACMC. In addition to the First Mortgage provided
to ACMC by Ark Ministries,  we also obtained $40,000 in personal guarantees from
the Church's former Senior Pastor, current president and two other board members
of Ark Ministries.

     Ark  Ministries  borrowed  funds from ACMC to renovate their current church
facility.  All  renovation  proceeds  were  dispersed  to  the  Church  and  the
renovations  were  completed.  The city of Tyler,  Texas  required the Church to
install  an  elevator.  The  proceeds  from  the  supplemental  loan was used to
purchase and install an elevator in their current facility.  Ark Ministries last
full mortgage  payment was October of 2003. Since October of 2003 Ark Ministries
has sent payments  totaling  $1,500 to ACMC.  Ark  Ministries  monthly  mortgage
obligation   is:   $3,159.95   per  month.   ACMC  learned  their  was  a  split
(disagreement)  among the  congregation  and the Senior Pastor and over half the
congregation left to start their own church. Since the split, the Church has not
been able to make its monthly mortgage payments to ACMC.

     Soon after the split,  Ark  Ministries  began  renting  their  facility  to
another  congregation for minimal monthly rent. This  congregation has requested
information  regarding purchasing the church from Ark Ministries.  In discussion
with the potential buyer, it was agreed to delay  foreclosure  beginning January
1,  2005 for a period  of 45 days to allow  the  buyer to  obtain  financing  to
purchase the church.  The 45 day period has elapsed and the potential  buyer has
not  obtain  financing.  On  March  25,  2005,  ACMC  engaged  counsel  to begin
foreclosure on Ark  Ministries.  We have applied our loan reserve policy against
this loan and have reserved  $13,561  against the balance of the loan. It is the
opinion of ACMC's  loan  committee  that as of  December  31, 2004 the loan loss
reserve amount of $13,561 was adequate reserve for this loan at this time.

     These three loans account for 82% or $57,000 of the total $70,000 loan loss
reserve  amount as of  December  31,  2004.  The  remaining  loan loss amount of
$13,000 is for four other loans in our portfolio which have one or two months of
payments  that are in arrears.  We review and update our loan loss  reserve on a
quarterly basis

     We strive to  continually  work with our  problem  loans to  rectify  their
payment  history  problems by offering  incentives such as waiving late interest
fees if the Church can make up their payment  arrearage  through a payment plan.
Some problem  loans have  switched to interest only payments for a period of six
to twelve months to help reduce their  expenses  since they are  experiencing  a
temporary shortfall in their tithes and offerings.  In most instances,  this has
rectified  the  Church  payment  problem  and the  Church  is  grateful  for our
understanding and acceptance of an alternate payment plan.

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Securities and Exchange Commission
April 22, 2005
Page Four

     However,  foreclosure is inevitable as discussed above.  Foreclosure brings
on additional costs including attorney fees, court costs,  realtor fees and cost
to secure and maintain the integrity of the collateral and protect it from arson
and vandalism. In addition, when ACMC obtains property through foreclosure,  the
local city and county government immediately revoke the tax exempt status of the
property  as a  not-for-profit  religious  organization  and  ACMC  must now pay
real-estate taxes on the acquired property.

     We will continue to perform our duties in a diligent and fiduciary  manner.
We will  enforce  our loan loss  reserve  policy,  avoid  foreclosure  if at all
possible,  and  openly  discuss  our  loan  loss  reserve  policy  with our loan
committee,  our  auditors  and our  board of  directors  and keep our  investors
properly informed.

Bond Portfolio, Page F-8

     As stated in our loan  lending  guidelines,  ACMC may  purchase  securities
issued  by  not-for-  profit  religious  organizations.  Churches,  schools  and
day-care centers are typical not-for-profit  religious  organizations that issue
debt securities,  commonly  referred to as "Church Bonds." ACMC purchases Church
Bonds from American  Investors Group, Inc.  ("American") who primary business is
underwriting Church Bonds. ACMC also purchases bonds from client's of American's
who need to sell their bonds prior to maturity.

     Investors understand that there is no formally established secondary market
for  Church  Bonds.  ACMC along  with  American's  other  retail  investors  are
primarily  interested in the income they receive from the investment and not its
liquidity.  ACMC is  prepared  to hold bonds  until they  mature or are  called,
whichever occurs first. Since there is no formally established  secondary market
for Church Bonds the  interest  paid on these  investments  is higher than other
fixed income investments that trade actively in the secondary market.

     ACMC  has  determined  that  the  carrying  value  of  the  bond  portfolio
approximates fair value because of minimal changes in interest rates and quality
of the underlying collateral since initial purchase. Bonds owned by ACMC are not
held for trading  purposes.  However,  ACMC  classifies  its bond  portfolio  as
"available-for-sale."  ACMC may sell bonds at its discretion to raise additional
capital to fund loans. ACMC is under no obligation to sell its bonds but may due
so to reduce  exposure to one particular  issuer and/or to continue to diversify
its portfolio of bonds and loans.  ACMC believes as long as a bond is paying out
its full quarterly  interest payment to its  bondholders,  there is no reason to
value them at anything less than at cost plus amortized  interest income. If for
any reason we do not receive our quarterly interest payments,  we will determine
the reason why payment was either  delayed or not received and  determine if the
carrying  value  of the  bond at cost is  appropriate.  All  bonds  in our  bond
portfolio  are current in their  payments  and no delays or  interruptions  have
occurred.

     Finally,  American Church Mortgage  Company and its officers and management
understand  the Company is  responsible  for the  adequacy  and  accuracy of the
disclosure  in our filings and that 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 American Church Mortgage Company may not
assert  staff  comments  as a  defense  in  any  proceedings  initiated  by  the
Commission or any person under the federal securities laws of the United States.

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Securities and Exchange Commission
April 22, 2005
Page Five

     If the Commission  has any questions or needs any  additional  information,
please  contact  Scott  J.  Marquis,  Vice-President  at (952)  252-0909  or the
undersigned at (952) 952-0911.

                                            Sincerely,

                                            /s/ Philip J. Myers
                                            Philip J. Myers
                                            President
                                            American Church Mortgage Company
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