SecProbe.io

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Mail Stop 4561
                                                August 23, 2005

Mr. Edward C. Ashby, III
President and Chief Executive Officer
Surrey Bancorp
145 North Renfro Street
P.O. Box 1227
Mount Airy, NC 27030

Re:	Surrey Bancorp
	Form 10-KSB for the Fiscal Year Ended December 31, 2004
	Forms 10-QSB for the Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
	File Number: 000-50313

Dear Mr. Ashby, III:

      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 comments are inapplicable or a revision
is
unnecessary.  Please be as detailed as necessary in your
explanation.
In 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 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 on March 24, 2005

Exhibit 13.1

Consolidated Statements of Income, page 4

1. We note that your "fees on mortgage loans delivered to
correspondents" increased to $298,000 as of December 31, 2004.
Please
explain to us in further detail how you were able to receive
higher
fees on loans delivered to mortgage
correspondents in 2004 as a result of your "exit from mortgage
loan
servicing," as stated on page 42 of your filing.

Note 1. Organization and Summary of Significant Accounting
Policies

Servicing, page 12

2. We note from your consolidated statement of income on page 4
that
you recognized a $501,000 gain as a result of a sale of your loan
servicing rights. We also note on page 12 that during the year
ended
December 31, 2004 you sold your mortgage servicing rights to
another
bank. Please tell us the following:

* How you were able to conclude that based on their "immateriality
and complex nature" you did not capitalize your servicing assets
in
existence on December 31, 2003 was in accordance with paragraphs
61 -
62 of SFAS 140;

* Quantify the amount of loans you have serviced for others since
you
commenced your servicing operations. We note only these amounts as
of
December 31, 2003 and 2002 as included in your Note 6 on page 20;

* Explain whether you capitalized servicing assets prior to
December
31, 2003. If so, separately tell us these amounts differentiating
between those that were purchased directly by you and those that
were
retained as a result of sales of your mortgage loans, if
applicable;

* How you were able to recognize a gain of $501,000 for the sale
of
these servicing assets. Specifically address how amortization and
the
potential for impairment of your servicing assets, if applicable,
may
have impacted your gain determination. Also, provide us with the
journal entries you used to record this gain in your financial
statements for the year ended December 31, 2004; and

* Please provide us a detailed response specifically citing the
relevant literature prescribed by SFAS 140 in addition to any
other
authoritative guidance you may have used to support your
accounting.

Independent Auditor`s Report - page 36

3. We note inclusion of the opinion of your Independent Auditor`s
dual-dated January 14, 2005 and February 22, 2005 in your filing.
Please amend the filing to include the auditor signature block in
the
opinion and an updated consent as an exhibit. Refer to Item 2-
02(a)(2) of Regulation S-X. As a related matter, please include
the
certifications required by the Sarbanes-Oxley Act of 2002.

       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 supplemental 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 John Spitz at (202) 551-3484 or me at (202)
551-3492 if you have questions.

      Sincerely,

      John P. Nolan
      Accounting Branch Chief

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Mr. Edward C. Ashby, III
Surrey Bancorp
August 23, 2005
Page 1

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