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CORRESP
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TIML Form Corresp 9/29/05

TIME
LENDING, CALIFORNIA, INC.

1040
E. Katella Ave., Suite B1

Orange, California 92867

(714) 288-5901

September 29, 2005

Larry
Spirgel

Assistant
Director

Securities
and Exchange Commission

450
Fifth Street, N.W.

Washington,
DC 20549

Re:
TIME LENDING, CALIFORNIA, INC. (THE "COMPANY")

FORM
10-KSB FOR THE FISCAL YEAR ENDED JUNE 30, 2004

FILED
OCTOBER 13, 2004

FORM
10-QSB FOR THE PERIOD ENDED MARCH 31, 2005

FILED
ON MAY 16, 2005

FILE
NO. 333-59114

-------------------------------------------------------------

Dear
Mr. Spirgel:

The
Company responds to the Staff's comment letter dated September 13,

2005.
The Staff's comments are addressed by their corresponding numbers and
are

accompanied
by the Company's responses thereto.

Form
10-KSBfor the year ended June 30, 2004

-------------------------------------------

Consolidated
Statement of Stockholders’ Equity (Deficit), page F-6

------------------------------------------------------------------

1.
The
shares of stock issued for cash were at the amount that was
received in cash for the stock.

The stocks issued to the employees
for compensation were set at $.04 by management
as estimated fair value of the services.

Notes
to Consolidated Financial Statements

------------------------------------------

Note
1. Organization and Presentation

Revenue
Recognition, Page F-7

-------------------------------------------

2.
We
have corrected the wording for Revenue Recognition.

“Revenue
Recognition

Marketing
Income is from direct mail marketing projects and is recorded when the project
is completed and shipped. Prices are agreed between the Company and its customer
at the time of the order. Shipment is usually within 3-5 days from
ordering.

Loan
Fees are primarily mortgage origination fees for loans processed by the Company
for its clients and various mortgage lenders. Revenue is recorded at the time of
mortgage closing.

Real
Estate Sales of income is fees for Company receiving fees as a Real Estate Agent
and are recorded at the time the sale is closed.”

Net
Earnings (Loss) per share, page F-8

---------------------------------------

3.
We have corrected the wording in the Net Earnings (Loss) statement.

“There are no outstanding options, warrants or securities convertible into
common equity.”

Form
10-QSB for the quarter ended March 31, 2005

------------------------------------------------

    4.

      We
      have added the additional note to the quarterly report regarding the Note
      Receivable.

“Time
Lending wrote a mortgage on February 3, 2005 for $26,000 secured by real
property with the trustor being Gary La Puma, brother of Philip La Puma. The
interest rate is 7.4% annual with monthly payments of $162.50 per month. Total
loan to value is under 80% based on fee appraisal of the property.”

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 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.

Very
truly yours,

Michael
Pope, President