SecProbe.io

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Mail Stop 0408

						July 29, 2005

By U.S. Mail and Facsimile to (704) 894-9759

David R. Koran
President, Chief Executive Officer and Chief Financial Officer
Capital Resource Funding, Inc.
2212 Lantern Way Circle
Cornelius, North Carolina 28031

Re:	Capital Resource Funding, Inc.
	Amendment No. 7 to Registration Statement on Form SB-2
      Filed July 21, 2005
	File No. 333-118259

Dear Mr. Koran:

      We have reviewed your amendment 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 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 or may not raise additional
comments.

      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 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 numbers listed at the end of
this letter.

Cover Page

1. We note your response to our prior comment no. 1.  However, the
cover page does not include all the disclosure required under Item
501(a)(9)(iv).  Please revise to clearly disclose the underwriting
comissions and proceeds to the selling shareholder based on the
total
amounts of the offering.  While it is true that a tabular format
is
not specifically required, the information needs to be presented
in a
clear format so that the per share and total amounts can be easily
understood and compared.

*      *      *

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  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 will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      You may contact Angela Jackson, Staff Accountant, at (202)
551-
3426 or Kevin Vaughn, Accounting Branch Chief, (202) 551-3494 if
you
have questions regarding comments on the financial statements and
related matters.  Please contact Gregory Dundas at (202) 551-3436
or
me at (202) 551-3419 with any other questions.

						Sincerely,

Christian Windsor
Special Counsel

cc:	Harold Martin, Esq. (by fax)

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David R. Koran
Capital Resource Funding, Inc.
July 14, 2005
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