SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

December 22, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (770)614-7573

Mr. J. Michael Allen
President and Chief Executive Officer
Georgia Trust Bancshares, Inc.
3570 Financial Center Way, Suite 2
Buford, Georgia 30519

Re:	Georgia Trust Bancshares, Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2004
Form 10-QSB for the Fiscal Quarter Ended September 30, 2005
	File No. 333-116852

Dear Mr. Allen:

      We have reviewed your filings and have limited our review to
those issues we have addressed in 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 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 information so we
may
better understand your disclosure.  After reviewing this
information,
we may 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-QSB filed November 15, 2005

Financial Statements for the Quarter Ended September 30, 2005

Note 1 - Summary of Significant Accounting Policies

1. We note you have included the allowance for loan losses as a
critical accounting policy in your Management`s Discussion and
Analysis or Plan of Operations.  Please provide us with the
proposed
disclosures of the accounting policies for the allowance for loan
losses you will use in your 12/31/2005 financial statements, as
well
as the policies for other significant accounts such as loans and
interest income.  Refer to the guidance provided by paragraphs 8-
12
of APB 22.

Form 10-KSB filed March 31, 2005, and Form 10-QSB filed November
14,
2005

Exhibit 31 - Certifications

2. We note your certifications are not stated exactly as set forth
under Item 601(b)(31) of Regulation S-B.  Please revise your
certification(s) in your next periodic filing to comply with all
requirements under Item 601(b)(31), specifically, removing the
title
of the certifying individual from the first line of the
certification.

* * * * *

 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 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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 Amanda Roberts, Staff Accountant, at
(202)551-
3417 or me at (202)551-3492 if you have questions.

Sincerely,

      John P. Nolan
Accounting Branch Chief

Mr. J. Michael Allen
Georgia Trust Bancshares, Inc.
Page 1 of 3

</TEXT>
</DOCUMENT>