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                                                     October 5, 2005

Mr. Robert Telewicz Staff Accountant
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, DC 20549

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

Dear Mr. Telewicz:

Following  up to our  telephone  conference  on  October  3,  2005 we  have  the
following comments and information for you to consider.

As was stated in the  conference  call,  our client treats their  investments in
debt  securities  as  available-for-sale  securities as defined in SFAS 115. The
securities  are not bought and held with the  intention  of selling  them in the
near term, nor is it management's intention to hold - to - maturity, but to sell
them as required to meet their liquidity needs.

As stated in SFAS 115,  (Current  Text  I80.403,  and I80.860) the fair value of
such investments is the amount they "...could be bought or sold for in a current
transaction  between willing  parties..." In their situation,  the willing party
has been and is expected  to be, a related  party  which has  purchased  them at
their cost to the Company.  As further discussed below, due to the call feature,
any  willing  buyer would also  purchase  them at cost.  Secondly,  "If a quoted
market price is not available, the estimate of fair value should be based on the
best information available in the circumstances." Further, "The estimate of fair
value should consider prices for similar  assets..." Their history of buying and
selling  the  bonds  at par or cost is the  best  information  available  in the
circumstances with similar assets.  Since the inception of the Company the bonds
have been bought at par and sold at par.

Valuation  techniques  have been  applied by the  Company to the  portfolio  for
consideration; however by their unique nature, there is a very limited secondary
market for such  investments.  Most  importantly,  as we discussed,  the lack of
marketability  and  limitations  of  the  valuation  of  the  bonds  is  further
influenced by the callable  feature of these bonds. It is very important to note
that the bonds are callable at par anytime  without  penalty.  Hence, "a willing
buyer" in the  marketplace  would only pay par for an investment  which could be
called at anytime at face value.  It is  unfortunate  that this call feature was
not brought to your attention earlier,  as it is a key part of the determination
of fair value.
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As you requested,  we did review SFAC Statement #7. However, in view of the fact
that the bonds are  callable  at their face  value,  application  of a valuation
methodology   arriving  at  a  different   amount   other  than  face  value  is
inappropriate.  Any computed  differences in hypothetical versus stated interest
rates on  these  bonds  would  be  ignored  in the  marketplace  due to the call
feature.

Please  consider  this new  information  and the  above  discussion  of facts in
formulating a conclusion. Call us with any questions you may have.

Sincerely,

/s/ Steven J. Behrns
Steven J. Behrns

Cc:  American Church Mortgage Company
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