SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

      October 14, 2005

Donald R. Head
President and Chief Executive Officer
Capital Title Group, Inc.
14648 N. Scottsdale Rd., Ste. 125
Scottsdale, AZ   85254

Re:	Capital Title Group, Inc.
	Form 10-K for Fiscal Year Ended December 31, 2004
	Filed March 17, 2005
	File No. 000-21417

Dear Mr. Head:

      We have reviewed your August 31, 2005, October 3, 2005, and
October 3, 2005 responses to our August 22, 2005 comment letter
and
have the following comment.  In our comment, we have asked you to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 8.  Financial Statements, page 32

Notes to Consolidated Financial Statements, page 37

1.  Organization and Summary of Significant Accounting Policies,
page
37

Significant Accounting Policies, page 38

Revenue Recognition, page 39

1. In order for us to evaluate your conclusion that net reporting
is
appropriate, please clarify for us what is meant in your October
11,
2005 response to comment two by underwriting fees are compensation
for accepting "the risk," which appears inconsistent with your
October 3, 2005 response that these fees are compensation for
accepting a "portion of the risk."  In addition, since you assert
in
your response that these transactions are not within the scope of
EITF Issue 99-19 because that issue excludes insurance and
reinsurance premiums, please tell us why underwriting fees are an
insurance or reinsurance premium within the scope of FAS 60 or FAS
113.  Further tell us your accounting policy for recording and
classifying in your financial statements any recoveries under
these
contracts.

*    *    *    *

      Please respond to the comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your response to our comment and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

      You may contact Ibolya Ignat, Staff Accountant at (202) 551-
3656, or Oscar M. Young, Senior Accountant at (202) 551-3622 if
you
have questions regarding the comments.  In this regard, do not
hesitate to contact me, at (202) 551-3679.

	Sincerely,

	Jim B. Rosenberg
	Senior Assistant Chief
	Accountant

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Donald R. Head
Capital Title Group, Inc
October 14, 2005
Page 3

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