SecProbe.io

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<FILENAME>filename1.txt
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January 18, 2005

Mr. Terrence Riely
Chairman of the Board
Paramco Financial Group, Inc.
2391 N.E. Loop 410, Suite 1230
San Antonio, Texas  78217

RE:  	Form 8-K Item 4.01 filed January 14, 2005
	File # 3-2495

Dear Mr. Riely:

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 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 supplemental
information so we may better understand your disclosure.  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 number
listed
at the end of this letter.

1. Item 304(a)(1)(ii) of Regulation S-B requires you to state
"whether the principal accountant`s report on the financial
statements for either of the past two years contained an adverse
opinion or disclaimer of opinion, or was modified as to
uncertainty,
audit scope, or accounting principles, and also describe the
nature
of each such adverse opinion, disclaimer of opinion or
modification."
Your current disclosure only meets this requirement for one year
("The report of Kabani & Company, Inc., CPAs for the fiscal year
ended December 31, 2003).  Please amend your Item 4.01 Form 8-K to
disclose the information required by Item304(a)(1)(ii) for the
fiscal
years ended December 31, 2003 and December 31, 2002.

2. We note that your Form 8-K filed on January 14, 2005 still did
not
include an Exhibit 16 letter from your former accountant.  Please
provide us with a status as to when you think you will receive
this
letter from your former accountant.  Please refer to Item
304(a)(3)
of Regulation S-B.  When you file an amended Form 8-K to comply
with
our comments, please obtain and file an Exhibit 16 letter from
your
former accountant stating whether the accountant agrees with the
statements made in your amended Form 8-K.  File the amendment
under
cover of Form 8-KA and include the ITEM 4.01 designation.  File
the
letter from the former accountant as an Exhibit 16.

*****

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require.  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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

Please file your supplemental response via EDGAR in response to
these
comments within 5 business days of the date of this letter.
Please
note that if you require longer than 5 business days to respond,
you
should contact the staff immediately to request additional time.
You
may wish to provide us with marked copies of each amended filing
to
expedite our review.  Direct any questions regarding the above to
the
undersigned at (202) 824-5685.

Sincerely,

Jeffrey Gordon
Staff Accountant
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Mr. Riely
January 18, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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