SecProbe.io

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May 20, 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  followup  letter dated May 10, 2005
which requests additional information regarding the methodology used by American
Church Mortgage  Company ("ACMC") to calculate the fair market value of its bond
portfolio. We have prepared the following response to the Commission's follow up
question below.

Bond Portfolio, Page F-8

     In accordance with SFAS 115 we utilize fundamental  analysis in valuing our
bond  portfolio.  Listed below are the current factors we use in our fundamental
analysis.

         We monitor the 10-year Treasury Bond yield as a benchmark in valuing
our bond portfolio. We also consider four other factors in determining our bond
portfolio's fair market value. These factors are:

          1)   Any change in the underlying value of the collateral;
          2)   The average rate of return on the investment;
          3)   The bond issuer's payment status;
          4)   The current average price of any new church bond issues.

     The average rates of return on our bond  portfolio as of December 31, 2002,
2003 and 2004 were 8.89%,  7.93% and 7.53%  respectively.  The 10-year  Treasury
Bond yield as of December  31, 2002,  2003 and 2004 were 4.61%,  4.01% and 4.27%
respectively.  ACMC's bond portfolio has averaged over 300 basis points or 3.00%
above current Treasury Bond yields.

     A graph  representing  the  relationship  between the 10 year Treasury Bond
rate and the Average Rate of Return on ACMC's bond  portfolio is attached.  ACMC
has  determined  that if its church bond portfolio has an Average Rate of Return
above 300 basis points  (3.00%) over the 10- year Treasury Bond yield,  that the
cost of its bond portfolio is its fair market value.

     An analysis of our current  bond  portfolio  as of December  31, 2004 shows
that approximately 72% of our bond portfolio has been purchased since January 1,
2001,  representing  in excess of $7,800,000 in principal bonds purchased at par
value.

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Securities and Exchange Commission
May 20, 2005
Page Two

     Also enclosed is a historical graph between the 10-year Treasury Bond yield
versus the bond rates that American  Investors  Group,  Inc. is using in pricing
any new church bond  issue.  The  average  rate of return on American  Investors
Group,  Inc.'s new bond issues  were 8.35%,  7.08% and 7.55% for the three years
ended December 31, 2002, 2003 and 2004. Historically,  American Investors Group,
Inc. has priced new church bond offerings at  approximately  300 basis points or
3.00% above the 10-year  Treasury  Bond rate.  ACMC buys all of its church bonds
from American Investors Group, Inc..

     The 10-year Treasury Bond yield has remained  relatively flat over the last
three year period.  The Average Rate of Return on ACMC's bond portfolio has been
above American Investors Group Inc.'s average new church bond rates and American
Investors  Group  Inc.'s new church  bond issues  have  historically  been above
Treasury Bond yields.  ACMC has  determined  that the carrying value of the bond
portfolio  approximates fair value because (i) there has been minimal changes in
the 10- year Treasury Bond yield;  and (ii) ACMC's Average Rate of Return on its
bond  portfolio  is higher then the average  rate of return on new Church  Bonds
issued by American  Investors Group,  Inc. In addition we look at the quality of
the  underlying  collateral,  payment  history and interest  rate since  initial
purchase.

     We continue to evaluate our fundamental bond portfolio  pricing analysis on
an ongoing basis. We believe that the 10 year Treasury Bond yield is a benchmark
by which to value our bond portfolio since there is no active  secondary  market
for church bonds.  We have  determined that if our average rate of return on our
bond  portfolio is 300 basis points over the 10 year Treasury  Bond yield,  that
the fair market value our bond portfolio approximates cost.

     In summation,  the Average Rate of Return on our bond  portfolio,  American
Investors Group Inc.'s new church bond issue pricing,  the 10-year Treasury Bond
yield,  and the ongoing payment  performance of a bond issuer,  are factors that
influence  our bond  portfolio  valuation.  Giving  consideration  to all  these
factors,  we maintain our bond  portfolio's  fair market value  approximates its
cost at December 31, 2004.

     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

Encl.(2)
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