SecProbe.io

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Mail Stop 04-06

      February 15, 2005

Mr. John Hartman
President
Silverado Financial Inc.
5976 W. Las Positas Blvd., Suite 116
Pleasanton, CA 94588
(925) 227-1500

Re:   	Silverado Financial Inc.
      Form 8-K filed February 3, 2005
      File No. 000-28375

Dear Mr. Hartman:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your documents in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comments are inapplicable or a revision
is
unnecessary. Please be as detailed as necessary in your
explanation.
After reviewing this information, we may or may not 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.

Form 8-K, filed February 3, 2005
1. The disclosure in your first paragraph indicates that the
Company
terminated its principal accountant.  Revise your report to state
whether the former accountant resigned, declined to stand for re-
election or was dismissed.  Refer to Item 304(a)(1)(i) of
Regulation
S-B.
2. Revise your report to indicate whether your former accountant`s
reports for either of the last two years contained an adverse
opinion
or a disclaimer of opinion or was qualified or modified as to
uncertainty, audit scope, or accounting principles and describe
the
nature of each such adverse opinion, disclaimer of opinion,
modification, or qualification.  Refer to Item 304(a)(1)(ii) of
Regulation S-B.
3. Revise your report to disclose whether your audit committee or
board of directors recommended or approved the decision to change
accountants.  Refer to Item 304(a)(1)(iii) of Regulation S-B.
4. The disclosure in the first paragraph indicates that you had no
disagreements with your former accountants through the years ended
December 31, 2004.  Revise the disclosure regarding disagreements
to
specifically refer to the two most recent fiscal years and
subsequent
interim period through the date your relationship with your former
accountants terminated, January 25, 2005.  Refer to Item
304(a)(1)(iv) of Regulation S-B.
5. Revise your disclosure with respect to the engagement of a new
accountant to specifically indicate whether the new accountant was
consulted during the two most recent fiscal years or subsequent
interim period through the date of engagement.  Provide
disclosures
to comply with Item 304(a)(2) of Regulation S-B.
6. Since your Form 8-K was filed on February 3, 2005, the letter
from
your former accountant is due by February 17, 2005.  Amend the
report
to include the required letter from the former accountant
indicating
whether or not they agree with your disclosures in this Form 8-K
and
any revised statements made in your Form 8-K to the extent that
you
make changes to comply with our comments.  Refer to Item 304(a)(3)
of
Regulation S-B.

General

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that:

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Regarding your Form 8-K, please file your supplemental
response
and amendment via EDGAR in response to the comments within 10 days
of
the date of this letter.  Please note that if you require longer
than
10 days to respond, you should contact the staff immediately to
request additional time.  Any questions regarding the Form 8-K
should
be directed to the undersigned at (202) 942-2806, or in my
absence,
to Robert Benton at (202) 942-1811.

Sincerely,

David Edgar
      Staff Accountant
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Silverado Financial Inc.
February 15, 2005
Page 3 of 3

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