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S.E.C.LETTER

WGNB Corp.

201 Maple Street

P.O. Box 280

Carrollton, Georgia 30117

November 30, 2005

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mail Stop 4561

Washington, D.C. 20549

Attn:     Angela Jackson

               Margaret Fitzgerald

Re:          WGNB Corp. (the “Company”)

               Form 10-K for the fiscal year ended December 31, 2004

               File No. 000-30805

Dear Ms. Jackson and Ms. Fitzgerald:

We are in receipt of the Staff’s follow-up comments to the Company’s Form 10-K for the fiscal year
ended December 31, 2004 (“2004 10-K”), conveyed to us by letter dated November 4, 2005. Set forth
below are the Company’s responses to each of the Staff’s comments. For your convenience, the
Staff’s comments are reproduced in their entirety in bold below, and the Company’s responses
thereto are set forth after each comment.

Summary of Significant Accounting Policies

Derivative Instruments and Hedging Activities, page F-11

    1.

    We note your response to comment 2 of our letter dated September 25, 2005. Your
response did not fully address the items requested in our comment. You have asserted that
your hedge of FHLB convertible advances was designed to remain effective through out its
term, but you have not clearly explained the method you use to assess effectiveness. As
previously requested, please provide us with the following with respect to your hedges of
FHLB convertible advances:

    •

    Clearly identify whether you use the long haul method, the short-cut method or
matched terms to assess the effectiveness of this hedging strategy.

Response: We use the long haul method to assess the effectiveness of this hedging strategy.

    •

    Describe the methods used to assess the effectiveness and measure hedge ineffectiveness.

Response: The Bank has $35 million of fixed rate debt with varying maturities. When we
entered into the swap, the Bank’s balance sheet was (and remains) asset sensitive. We were
susceptible to interest rate risk in a downward rate environment that was outside the risk
tolerance of the Bank. We looked at hedging that risk by putting on a pay floating, receive fixed
swap to hedge our fixed rate quarterly interest payments due on $30 million of our FHLB advances
for a period of 36 months. At inception, the fair value of the swap was zero. It was our intent
to hedge fluctuations in the fair value of the fixed rate coupon payments for the next 12 quarterly
interest payments. Additionally, the change associated with interest rate movements should have an
equal and offsetting effect on the fixed rate coupon payments (the hedged item) and the fixed rate
component of the interest rate swap (hedge instrument). We verified the correlation at inception
of the swap and continually thereafter through December 31, 2004.

    •

    If you apply the short cut method of assessing hedge effectiveness, tell us how
you determined that this hedge met the conditions of paragraph 68 of SFAS 133 to
qualify for such treatment.

Response: We do not use the short-cut method of assessing hedge effectiveness.

    2.

    It is our understanding, based on your disclosure on page F-16, that the FHLB advances
which you are hedging with an interest rate swap contain an early conversion option that
allows the FHLB to convert the advances to a variable interest rate. Please provide us
with the following information with respect to this conversion feature:

    •

    Clearly explain what will happen to your advance in the event the conversion
option is exercised by the FHLB. For example, explain whether your advance
automatically converts to a variable rate advance or whether you can prepay the
advance with out penalty.

Response: The conversion options on our FHLB advances occur after the period that is
contemplated by our hedging strategy. Therefore, the conversion option does not influence our
hedge.

    •

    Tell us whether the interest rate swap contains a call option that allows you to
terminate the swap upon exercise of the conversion option by the FHLB.

Response: Again, the interest rate swap will expire prior to the conversion options
becoming available on our FHLB advances.

In addition, the Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure
in its filings;

    •

    Staff comments or changes to disclosure in response to Staff comments do not
foreclose the Securities and Exchange Commission (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 you have any questions or comments regarding the Company’s responses to the Staff’s comments set
forth above, please do not hesitate to contact the undersigned at (770) 830-2945.

    Very truly yours,

WGNB CORP.

    By:
    /s/ Steven J. Haack

    Steven J. Haack

    Treasurer

(Principal Accounting Officer)