SecProbe.io

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                                 LAW OFFICES OF
                           DERENTHAL & DANNHAUSER LLP
                           ONE POST STREET, SUITE 575
                         SAN FRANCISCO, CALIFORNIA 94104
                                 (415) 981-4844
                            FACSIMILE: (415) 981-4840

                                February 25, 2005

BY EDGAR AND OVERNIGHT DELIVERY

Ms. Pamela Carmody
Special Counsel
Office of Mergers and Acquisitions
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street. N.W.
Washington, D.C. 20549

          Re:      BellaVista Capital, Inc. (the "Company")
                   Preliminary Proxy Statement on Schedule 14A filed
                   February 18, 2005
                   Supplemental Letter dated February 22, 2005
                   SEC File No. 0-30507

Dear Ms. Carmody:

         This letter is in response to comments on the above referenced filings
as set forth in your letter dated February 24, 2005. The numbered responses
below correspond to the numbered comments in your letter. We are concurrently
forwarding to you and Ms. Losert a marked hard copy of this letter to facilitate
your review. We submit proposed changes to the solicitation materials in
response to comments 1 and 2. We would propose to include these changes in
definitive materials should you clear the Company to file definitive materials
based on our responses.

         1. The Maryland statute does require a board resolution declaring the
dissolution advisable and directing that the dissolution be submitted to a
shareholder vote at a regular or special meeting of the shareholders. It may
then be approved by affirmative vote of two-thirds of the outstanding shares.
The Company's board determined to hold the shareholder vote and agree to be
bound by its result. If two thirds of the shares vote to dissolve, the board
will approve an amendment advising dissolution and will submit the resolution to
a vote at the annual meeting to be held after the annual report is published in
the next few months.

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Ms. Pamela Carmody
February 25,  2005
Page 2

         For all of the reasons discussed in prior correspondence, the board has
viewed and continues to view the proposal as one directing the liquidation and
dissolution of the company. If sufficient shares are voted to liquidate and
dissolve, then the board has determined that it will be "advisable" to dissolve.
If fewer than the required number of shares vote for dissolution, then the board
will determine the future course of the company in accordance with the result.

         We would propose to make the following marked change to the proxy
solicitation document under the caption "Shareholder Proposal" to clarify this
point, with added language underlined:

"Shareholder Proposal

The meeting will be held for the sole purpose of voting on the following
proposal (the "Proposal") made by shareholders Jeff Black and Michael Johnson,
record holders of an aggregate of 311,341 of the Company's shares of common
stock (less than 2% of the outstanding shares as of February 7, 2005):

PROPOSAL: That the Corporation cease making new investments, and immediately
reduce its administrative expenses associated with making new investments. The
Board of Directors shall adopt a detailed plan to sell the Company's remaining
assets and distribute cash proceeds to its creditors and shareholders as such
proceeds become available for distribution, after allocating adequate reserves
to meet current and contingent liabilities.

The Board of Directors interprets this proposal as a proposal to liquidate the
company. Under Maryland law, such a proposal requires the affirmative vote of
66.67% of the outstanding shares. If at least 66.67% of the outstanding shares
vote to approve the proposal, the vote will be deemed binding on the Board, the
Board will adopt a resolution declaring the liquidation and dissolution of the
Company to be advisable and will have a formal vote for dissolution at the
annual meeting to be held later this year. Upon further approval of two-thirds
of the outstanding shares at the annual meeting, management and the Company will
proceed with the winding up, liquidation and dissolution of the Company."

         2. The Company did consider discussing historic returns on its
investments, but it has substantially changed its management structure and
business plan during the past year. During some past periods, returns exceeded
projections for current investments, but a substantial downturn in the market
for high end single family homes in the San Francisco Bay Area during recent
years caused the Company to incur significant losses. These losses and the
resulting need to restructure management and the business model have been fully
disclosed to the shareholders in regular correspondence and reports, and they
are well aware of the events affecting the Company's investment returns during
recent years.

<PAGE>

Ms. Pamela Carmody
February 25, 2005
Page 3

         The Company proposes to revise the fifth paragraph of its letter to
shareholders included as Appendix C to the Schedule 14A as follows, with added
language underlined:

With our investment strategy we seek to provide a 15% gross return on our
invested assets with a commensurate level of risk mitigated through an extensive
due diligence process and diversification of our investments in terms of size,
investment type, geographic region and price point. With reduced company
overhead, our continuing operating expenses are estimated to be approximately
2.5% of assets, which when subtracted from the targeted 15% gross return, yields
a net return of 12.5%. Using our new investment strategy and underwriting
procedures we have already made four new investments which are projected to
provide annual returns in excess of 22%. These new investments currently
represent approximately 24% of our realizable assets. Based on the projected
timing for our investment repayments and our current pipeline of investment
opportunities, we project that nearly 90% of our investments will have been made
under our new investment strategy and underwriting criteria by the end of 2005.
While rates of return on future investments may vary with market conditions, our
recent investments made in the current market demonstrate the opportunity to
achieve our targeted net returns on invested assets.

         3. See the attached letter from the Company in which the required
representations are subscribed by on behalf of the Company by its president.

                  Please contact me with any further questions or comments you
may have concerning this filing.

                                        Very truly yours,

                                        Paul J. Derenthal

cc:      Johanna Vega Losert, Esq.
         Mr. Michael Rider

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