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SEC Company Response from AMERICAN CHURCH MORTGAGE CO (CIK 0000934543) — Jun 21, 2005

AMERICAN CHURCH MORTGAGE CO (CIK 0000934543)
Date: June 21, 2005 · CIK: 0000934543 · Accession: 0000934543-05-000012

AI Filing Summary & Sentiment

Referenced dates: June 13, 2005

Date
June 21, 2005
Author
/s/ Philip J. Myers
Form
CORRESP
Company
AMERICAN CHURCH MORTGAGE CO (CIK 0000934543)

Letter

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

June 21, 2005

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

Attention: Robert Telewicz, Staff Accountant

Mr. Telewicz:

We are in receipt of the Commission's followup letter dated June 13, 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

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.

<TABLE> <CAPTION>

Period 10 Year Bond Spread Bond Portfolio Bond Portfolio Ending Treasury Bond Portfolio (Basis Points) Cost Value Yield Yield <C> <C> <C> <C> <C> <C> <C> 12/31/2002 4.61% 8.89% 428 $ 4,356,637 $ 4,356,637 12/31/2003 4.01% 7.93% 392 $ 5,485,286 $ 5,485,286 12/31/2004 4.27% 7.53% 326 $ 8,498,001 $ 8,498,001 </TABLE>

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

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
June 21, 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 June 13, 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

     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.

<TABLE>
<CAPTION>

     Period              10 Year                Bond                Spread           Bond Portfolio          Bond Portfolio
     Ending           Treasury Bond          Portfolio          (Basis Points)             Cost                   Value
                          Yield                 Yield
<C>   <C>                 <C>                  <C>                   <C>               <C>                     <C>
12/31/2002                4.61%                8.89%                 428               $ 4,356,637             $ 4,356,637
12/31/2003                4.01%                7.93%                 392               $ 5,485,286             $ 5,485,286
12/31/2004                4.27%                7.53%                 326               $ 8,498,001             $ 8,498,001
</TABLE>

     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
</TEXT>
</DOCUMENT>