SecProbe.io

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Mail Stop 3561

      							November 4, 2005

Mr. Ronald Farrell
Tri-S Security Corporation
Chief Executive Officer
Royal Center One
11675 Great Oaks Way, Suite 120
Alpharetta, Georgia  30022

	Re:	Tri-S Security Corporation
		Item 4.02 Form 8-K
      Filed November 2, 2005
		File No.  0-51148

Dear Mr. Farrell:

      We have reviewed your filing 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 more
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.

1. We note your statement which states that APB 18 and SFAS 94
"require that a greater than 5% equity interest in another entity
be
accounted for in accordance with the equity method, rather than
the
cost method of accounting."  In this regard, please explain in
greater detail, citing specific paragraphs used, where in the
accounting literature this is stated and why you think it is
appropriate for your investment in Army Fleet Support, LLC.

2. We also note your statement that "The carrying amount of the
Company`s equity interest in the Joint Venture will also be
reduced
by the amortization of the excess of the cost over the net book
value
of the assets of the Joint Venture. The Company`s equity interest
in
the Joint Venture will be amortized on a straight-line basis over
the
life of the contract, which is approximately 10 years."  In this
regard:
* Provide us with the transaction detail, including the assets of
the
Joint Venture, and your proportionate share of the Joint Venture
and
its assets.
* Tell us your cost and the net book value of the Joint Venture.
* Tell us the fair value asset allocation of your purchase price.
* Tell us why your equity interest in the Joint Venture will be
amortized on a straight-line basis over the life of the contract.
Provide us, in detail, your basis in accounting literature.

       As appropriate, please respond to these comments within
five
business days or tell us when you will respond.  Please file your
response in EDGAR.  Please understand that we may have additional
comments after reviewing your 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.

	If you have any questions, please call Inessa Berenbaum at
(202)
551-3371.

							Sincerely,

							Kyle Moffatt,
							Accountant Branch Chief
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Mr. Farrell
Tri-S Security Corporation
November 4, 2005
Page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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