SecProbe.io

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December 15, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (912)754-1398

Mr. Harry Shearhouse
President and Chief Executive Officer
Citizens Effingham Bancshares, Inc.
802 South Laurel Street
Post Office Box 379
Springfield, Georgia 31329

Re:	Citizens Effingham Bancshares, Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2004
Form 10-QSB for the Fiscal Quarters Ended March 31, 2005, June 30,
2005, and September 30, 2005
	File No. 333-07914

Dear Mr. Shearhouse:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB filed March 31, 2005

Statistical Information

Summary of Loan Loss Experience, page 22

1. Please provide us the allocations of the allowance for loan
losses
for both the current and prior fiscal year ends and include this
data
in your 12/31/2005 statistical information disclosures.  Refer to
Industry Guide 3, general instruction (a).

Management`s Discussion and Analysis

Asset Quality, page 27

2. We read your discussion of asset quality and are unable to
ascertain your methodology for determining each element of the
allowance for loan losses. Please provide us with the proposed
discussion you will use in your 12/31/2005 Management`s Discussion
and Analysis to clearly describe the details of your methodology
for
determining the allowance. The description of your methodology
should
be presented to clearly explain your determination of each element
(i.e. specific, general) of the allowance, including, but not
limited
to the following:

* a description of each element of the allowance;
* which loans were evaluated specifically versus as a group;
* how you determine the loss factors applied to groups of loans in
order to develop a general allowance; and
* risk factors considered in establishing each element of the
allowance.

Report of Independent Registered Public Accounting Firm, page 30

3. Please file a Form 10-KSB/A on EDGAR and revise the report to
include the signature of the registered public accounting firm who
opined on the financial statements.  Please refer to the guidance
in
Article 2-02(a)(2) of Regulation S-X.

Note A - Summary of Significant Accounting Policies, page 35 and
36

4. Please remove "possible" from your description of the allowance
for loan losses when you are preparing your 2005 10-KSB, as the
guidance provided by FAS 5 and FAS 114 does not prescribe accruals
for potential, possible, or future losses at the balance sheet
date.

Form 10-KSB filed March 31, 2005
Form 10-QSB filed May 13, 2005, August 15, 2005, and November 14,
2005

Exhibit 31 - Certifications

5. We note your certifications are not stated exactly as set forth
under Item 601(b)(31) of Regulation S-B.  Please revise your
certification(s) in your next periodic filing to comply with all
requirements under Item 601(b)(31) including:
* removing the title of the certifying individual from the first
line
of the certification; and
* refraining from including additional descriptive language in the
third paragraph of the certification.

6. We note that in your annual report on Form 10-KSB, the Chief
Executive Officer provided certification both as the principal
executive officer and as the acting principal financial officer,
however in the quarterly reports on Form 10-QSB filed during 2005,
such certification is not included.  Please explain in your
response
letter the absence of a certification by your principal financial
officer or person performing similar functions in the quarterly
reports on Form 10-QSB filed during 2005.

* * * * *

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 comments, 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.

	You may contact Amanda Roberts, Staff Accountant, at
(202)551-
3417 or me at (202)551-3492 if you have questions.

Sincerely,

      John P. Nolan
Accounting Branch Chief

Mr. Harry Shearhouse
Citizens Effingham Bancshares, Inc.
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