SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
September 2, 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:

     Per our phone  conversation on Tuesday August 30, 2005 we have prepared the
following  response to your request for  additional  information  regarding  the
valuation of our bond portfolio.  We have reviewed SFAS 115 regarding Accounting
for Certain  Investments in Debt and Equity  Securities and have  determined the
following paragraph of SFAS 115 applies to our bond portfolio valuation.

SFAS 115 Paragraph 9:

     Although we plan to hold our portfolio  until  maturity,  we do not account
for our bond portfolio as "held-to-maturity"  securities since paragraph nine of
SFAS 115 states although it is our intention to hold the bonds until maturity, a
debt security  should not be classified as "held-to-  maturity" if we anticipate
that the bonds would be available to be sold in response to needs for liquidity.
American Church Mortgage Company ("ACMC")  provides first mortgage  financing to
churches and other not-for-profit religious organizations.  ACMC may also invest
in  mortgage  backed  debt  securities   issued  by   not-for-profit   religious
organizations. These mortgage backed debt securities have maturities which range
from less than one year to 25 years.  We may sell our portfolio of bonds to: (i)
fund  additional  mortgage  loans or; (ii) provide a source of funding to re-pay
our secured investor certificates.  We do not anticipate having to sell bonds to
provide  for these  events.  However,  we reserve the right to be able to do so.
Therefore, we define our bond portfolio as "available-for-sale."

     We have historically  viewed the prevailing  treasury bond yields to be the
best  benchmark by which to value our bond  portfolio,  since there is no active
secondary  market for church bonds. As we have  discussed,  historically we have
determined that if the rate of return on the existing bond portfolio maintains a
combined  yield that is 300 basis  points  (3.00%) over the  prevailing  10 year
treasury bond yield, that the fair value of the bond portfolio is above our cost
of the portfolio.  Despite this premium,  we have historically  carried the fair
value of the portfolio at the lesser of cost or par.

     In light of your concerns and the absence of a secondary  market for church
bonds that would  otherwise  make pricing  data  reasonably  available,  we have
determined to refine our portfolio pricing mechanism to ensure that each bond in
the portfolio is evaluated quarterly. Our new mechanism,  which incorporates the
standard  formula set out below,  identifies for each maturity a spread over the
corresponding treasury security having the same period to maturity.

<PAGE>
Securities and Exchange Commission
September 2, 2005
Page Two

     If the portfolio bond yield is above the  corresponding  treasury  security
yield plus the spread, the bond is a "premium yielding" bond, and its value will
be  carried at the lesser of cost or par.  We have  determined  to use a sliding
scale for the spread based on the length of maturity of the bond.  The spread is
.75% for bonds  maturing  in less than one year up to a 3.25%  spread  for bonds
maturing in twenty-five  (25) years. If the bond yield is less than the treasury
security  yield plus the spread,  it is a "discount  yielding"  bond and we have
determined to value it at the lesser of the discount  yielding value, par or our
cost pursuant to the formula applied below.

         The formula we use to determine fair value is:

                               (Nominal rate)  = X
                              --------------  ---------
                              (Current rate )  1,000

     Nominal  rate is the current  coupon rate of the church bond which does not
change. But the interest rate in the general economy will change constantly.  In
our calculation, the current rate is the prevailing treasury security yield with
the same maturity as the church bond.

         Example 1:

          A $1,000 Greater Open Door  Community  Church Bond with a coupon yield
          of:  9.80% due  05/01/2017:  The current  rate on a treasury  security
          maturing in May of 2017 is 4.21%.  The Nominal  rate is reduced by 300
          basis points. (9.80 - 3.00) = 6.80%.

                          ( .068 )   = X
                          --------  ---------
                          ( .0421)   1,000             X = $1,615.20

     The bond we  purchased  at par or $1,000 with an adjusted  nominal  rate of
6.80% has a theoretical value of $1,615.20.

         Example 2:

          A $1,000 St. Agnes Missionary  Baptist Church Bond with a coupon yield
          of:  5.35% due  05/15/10:  The  current  rate on a  treasury  security
          maturing in May of 2010 is 3.96%.  The Nominal  rate is reduced by 300
          basis points. (5.35 - 1.50) = 3.85%

                         ( .0385)  =      X
                         --------     ---------
                         ( .0396)      1,000        X = $972.22

     The bond we  purchased  at par or $1,000  with a adjusted  nominal  rate of
3.82% has a theoretical value of $972.22.

<PAGE>
Securities and Exchange Commission
September 2, 2005
Page Three

     As of  December  31,  2004  the  fair  value  of  our  bond  portfolio  was
$10,323,126  by applying the formula  shown above to each bond in the  portfolio
along  with the  appropriate  spread.  Our cost for our  portfolio  of bonds was
$8,498,001 as of December 31, 2004. In light of the  Commission's  concerns,  we
have  determined to state the fair value of our portfolio to be either a premium
yielding bond portfolio or a discount  yielding bond portfolio.  However,  since
there is no active secondary market for these bonds, we have determined to value
a  premium  yielding  portfolio  at the  lesser of cost or par.  For a  discount
yielding  portfolio we have determined to value it at the lesser of the discount
yielding  value,  par or our cost. We will footnote these  valuations by stating
there can be no assurance  we will  receive a premium  (profit) for our bonds if
sold prior to maturity  nor do we expect to sell our bonds at a discount  (loss)
since we are prepared to hold the bonds until maturity.

     If the Commission  has any questions or needs any  additional  information,
please contact me at (952) 252-0909.

                                             Sincerely,

                                              /s/ Scott J. Marquis
                                              Scott J. Marquis
                                              Vice-President
                                              American Church Mortgage Company

<PAGE>

</TEXT>
</DOCUMENT>