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Access Anytime BanCorp, Inc.

VIA EDGAR

September 13, 2005

Mr. John P. Nolan

Accounting Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

Mail Stop 4561

Washington, D.C.  20549

RE:      Access Anytime
Bancorp, Inc.

Form 10-KSB for Fiscal Year Ended
December 31, 2004

File No. 000-28894

Dear Mr. Nolan:

This letter is in response to the comments contained in your letter of
August 30, 2005 regarding Access Anytime Bancorp, Inc.’s (the “Company”),
10-KSB for the Fiscal Year Ended December 31, 2004.  Set forth below are the staff’s comments and
the Company’s supplemental responses to those comments.

For your convenience, the Company has provided its response below in a
question and answer format.  Your
original comments are provided below in italics, and are followed by a
response.

Item 6

Management’s Discussion and Analysis or Plan of
Operations

Asset Quality

Allowance for Loan Losses, page 16

1.     Please
tell us how you considered paragraph 37.b of SFAS No. 141 when you recorded the
“acquired allowance” of $170,000 in 2004 shown in your analysis of the
allowance for loan losses.  Your
discussion should include but not be limited to the process used in determining
the present value of the acquired loans, if you recorded the loans at their
fair market value at the date of acquisition, and which loan valuation
methodology is reflected in your purchase price calculation.

In response to your comment, the Company advises the
staff supplementally as follows.  During
2004, the Company recorded an acquired allowance for loan losses in conjunction
with two branch acquisitions that were consummated in 2004.  The branch acquisitions were accounted for
under the purchase method of

ACCESSBANK a
wholly-owned subsidiary of the Company

5210 Eubank NE,
Albuquerque, New Mexico

(505) 299-0900 * Fax
(505) 275-9620

accounting, and accordingly, the acquired assets and
liabilities were recorded at their respective fair values on the date of
acquisition.

In response to your comment, the Company considered
and followed SFAS No. 141, paragraph 37.b, which contains the following
guidance:  “When assigning amounts to
assets acquired and liabilities assumed, except goodwill, receivables should be
recorded at present values of amounts to be received determined at appropriate
current interest rates, less allowances for uncollectibility and collection
costs, if necessary.”  In accordance with
SFAS No. 141, the Company recorded the acquired loans at their fair value on
the date of acquisition.  The fair value
calculation was prepared by a third-party service provider and was estimated by
the present value of estimated cash flows using a discount rate commensurate
with the risks associated with the loans.
Management reviewed the third-party’s valuation and determined it to be
reasonable and appropriate given the portfolio purchased.  The calculations were based on the loan
balances purchased, contracted interest rates, contracted maturities,
prepayment assumptions, and repricing schedules.  The fair value adjustment is being amortized
into interest income over the estimated life of the loans purchased.  The $170,000 acquired allowance for loan
losses was originally estimated by the financial institution that the loans
were acquired from (“Seller”), based on their approved methodology and relevant
facts and circumstances.  During the
course of the Company’s due diligence related to the acquisition of the loans,
management reviewed the loans that were to be acquired and considered the
systematic methodology that we currently employ in estimating allowance for
loan losses.  Based on this review,
management determined that the allowance for loan losses as recorded by the
Seller did not differ materially from the estimate of the needed allowance
calculated under the Company’s methodology.

Item 7

Consolidated Financial Statements

Consolidated Statements of Operations, page F-4

2.     We note non-interest income for gains on sales of loans held-for-sale
of $1.1 million represented 34% of total non-interest income for your year-ended
December 31, 2004.  Please tell us how
you considered this income source when determining your operating
segments.  Please provide details
supporting your current accounting, including relevant qualitative criteria and
quantitative threshold tests for the periods presented or revise your financial
statements if necessary.  Please refer to
paragraphs 10-24 of SFAS 131.

In response to your comments, the Company advises the
staff supplementally as follows.  During
the year ended December 31, 2004, the Company recorded gains on sales of loans
held-for-sale of $1,071,716.  This amount
constitutes approximately 34% of total non-interest income, and is derived from
our

secondary marketing activities.  The Company currently reports at the
enterprise level. We have considered the guidance under SFAS 131 and do not
believe we have any reportable segments.
SFAS 131, paragraph 10 states that an operating segment is a component
of an enterprise:

a.     That
engages in business activities from which it may earn revenues and incur
expenses (including revenues and expenses relating to transactions with other
components of the same enterprise),

b.     Whose
operating results are regularly reviewed by the enterprise’s chief operating
decision maker to make decisions about resources to be allocated to the segment
and assess its performance, and

c.     For
which discrete financial information is available

The Company does not produce discrete financial
information solely attributable to loans held for sale.  Loans are generally produced by branch, using
the same process, whether the loan is held for investment or will be sold into
the secondary market.  Loan officers
receive credit for all loan production, including loans sold and portfolio
loans.  Revenues and expenses related to
loans that are sold are generally recorded at the branch where the loan was
produced.  This is consistent with our
operating structure, where loan producers can be responsible for other banking
activities, and therefore, salaries and other expenses related to the loan
producer are recorded by branch, not by a function such as secondary
marketing.  In conclusion, we do not
produce discrete financial information solely for our secondary marketing
function.  Therefore, we do not believe
that the secondary market function represents a reportable segment.

3.     Please
tell us the type, source and amount of income included in the other income
balance of $1.4 million as of December 31, 2004.  Please review the guidance in Item 5-03.b.7
of Regulation S-X and SAB Topic 1.M.1.
Discuss how and why you believe you have fully complied with the
guidance and continue to believe your presentation is appropriate.

The following table indicates, supplementally, the
type, source and amount of income included in the Other Income balance of $1.4
million as of December 31, 2004:

  Deposit Account
  Service Fees

  $

  880,684

  Credit Card Service Fees

  138,050

  Loan Account Service Fees

  33,984

  REO Income

  89,617

  Rent Income

  108,170

  Other

  177,639

  Total

  $

  1,428,144

The Company reviewed the guidance in Item 5-03.b.7 of
Regulation S-X and SAB Topic 1.M.1, as indicated in your letter.  However, the Company believes

that the guidance in Item 9-04.2.13 is the appropriate
guidance to follow as it applies to bank holding companies.  Item 9-04.2.13 (d) indicates that fees for
other customer services should be disclosed separately, as well and any other
item of other income which exceeds one percent of the aggregate of total interest
income and other income.  The Company’s
threshold for the year ended December 31, 2004 was $171,481.  Based on its review, the Company believes
that Deposit Account Service Fees should be on a separate line on the face of
the income statement, in accordance with Item 9-14.2.13 (d).  There are no other items that meet the
$171,481 threshold.  The individual
accounts included in “Other” in the above table are all under this
threshold.  As resolution to this issue,
the Company will begin to report Deposit Account Service Fees on a separate
line on the face of the income statement, for all periods presented, beginning
with the quarter ending September 30, 2005.

In conjunction with this response to your comments, the Company
acknowledges the following:

The Company is responsible for the adequacy and accuracy of the
disclosure in the filing; Staff comments or changes to disclosure in response
to Staff comments do not foreclose the Commission from taking any action with
respect to the filing; and the Company may not assert Staff comments as a defense
in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

If there are any questions or comments with respect to the foregoing,
please call the undersigned, at (505) 299-0900.
Thank you for your attention to this matter.

  Sincerely,

  /s/ Norman R. Corzine

  Norman R. Corzine

  Chief Executive Officer

cc:   Jacque N.
Westling, Quarles & Brady Streich Lang LLP

Cynthia C. Reinhart, Managing Partner, KPMG LLP

Charles Guthals, Audit Committee Chairman