Mail Stop 6010

      October 5, 2005



VIA U.S. MAIL AND FAX (801) 264-8430

Mr. Stephen M. Sill
Vice President, Treasurer and Chief Financial Officer
Security National Financial Corporation
5300 South 360 West
Suite 250
Salt Lake City, Utah 84123

	Re:	Security National Financial Corporation
		Form 10-K for the year ended December 31, 2004
		Filed April 15, 2005
      File No. 0-9341


Dear Mr. Sill:

      We have reviewed your response dated September 1, 2005 and
have
the following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents. In our comments, we asked 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 comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


 Form 10-K for the year ended December 31, 2004

Financial Statements

Note 1. Significant Accounting Principles

Mortgage Operations

1. We note your response to our prior comment 1.  To enhance our
understanding of your mortgage operations, please address the
following:

a) Describe clearly the nature of the $47.1 million mortgage loans
sold to investors receivable presented on your balance sheets at
the
end of each reporting period.

b) Indicate the time period over which you expect to collect these
amounts from investors.

c) Clarify for us whether the company funds the mortgage loans,
through its insurance subsidiaries, and sells the mortgage loans
to
the unrelated financial institutions on the same day and, if so,
explain how a receivable results from this transaction.

d) If the mortgage loans sold to investors receivable represents
sales proceeds due to you from the unrelated financial
institutions,
please clarify the interaction between the receivable and the line
of
credit agreements to which you refer in your response.

e) Tell us where on your balance sheet you present the amounts you
owe under the line of credit agreements.

2. We note your response to our prior comment 5.  Please tell us
whether you had any outstanding commitments to originate mortgage
loans at each balance sheet date and describe how you accounted
for
these commitments pursuant to paragraph 6 of SFAS 133, as amended.
We note from your response to our prior comment 1(a) that you
originate all mortgage loans with the intention to sell them to
the
unrelated financial institutions.

3. Please describe to us your arrangements with the unrelated
financial institutions under which they acquire mortgage loans
from
you.  For example, tell us whether they are obligated to acquire
all
mortgage loans you originate; whether you are committed to supply
them with a stated volume of loans over a particular period; and
the
point in time at which you commit to sell and they in turn commit
to
acquire the loan you intend to originate.



      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR as correspondence.  Please understand
that
we may have additional comments after reviewing your responses to
our
comments.


      You may contact Julie Sherman, Staff Accountant, at (202)
551-
3640, or me at (202) 551-3671 if you have questions regarding
these
comments.


							Sincerely,


							Martin F. James
							Senior Assistant Chief
Accountant

Mr. Stephen M. Sill
Security National Financial Corporation
October 5, 2005
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