-----BEGIN PRIVACY-ENHANCED MESSAGE-----
Proc-Type: 2001,MIC-CLEAR
Originator-Name: webmaster@www.sec.gov
Originator-Key-Asymmetric:
 MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen
 TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB
MIC-Info: RSA-MD5,RSA,
 RKcAxspFtqAeSvQ8Ao309IRHY+CkMIZ+j2okIBwRBeTf9GH+nYIapxDVepWCngDw
 /lApyCSNN2klxvHOlky+TQ==

<SEC-DOCUMENT>0000000000-05-026498.txt : 20060710
<SEC-HEADER>0000000000-05-026498.hdr.sgml : 20060710
<ACCEPTANCE-DATETIME>20050531102743
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-05-026498
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20050531

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			SECURITY NATIONAL FINANCIAL CORP
		CENTRAL INDEX KEY:			0000318673
		STANDARD INDUSTRIAL CLASSIFICATION:	FINANCE SERVICES [6199]
		IRS NUMBER:				870345941
		STATE OF INCORPORATION:			UT
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		PO BOX 57220
		CITY:			SALT LAKE CITY
		STATE:			UT
		ZIP:			84157
		BUSINESS PHONE:		8012641060

	MAIL ADDRESS:	
		STREET 1:		PO BOX 57220
		CITY:			SALT LAKE CITY
		STATE:			UT
		ZIP:			84157

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	SNL FINANCIAL CORP
		DATE OF NAME CHANGE:	19910401
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>





		May 31, 2005



Mail Stop 0408


Security National Financial Corporation
5300 South 360 West, Suite 250
Salt Lake City, Utah 84123
Attn:  Mr. Scott M. Quist

Re:	Item 4.01 Form 8-K
	Filed May 3, 2005
	File No. 000-09341

Dear Mr. Quist:

	We have reviewed your Item 4.01 Form 8-K for compliance with
the
form requirements and have the following comments:

Form 8-K - General compliance comments:
1. Please revise to state whether the former accountant resigned,
declined to stand for re-election or was dismissed as required by
Item 304(a)(1)(i) of Regulation S-K.  It is not sufficient to
state
that the company "ceased its independent auditor relationship", as
that wording is unclear to a reader.
2. Please revise to indicate whether the audit committee, similar
committee of the board of directors or the board of directors
itself
approved the decision to change accountants.  Refer to Item
304(a)(iii).

Engagement of new accountant:
3. When you engage a new accountant, please report the engagement
in
a new Form 8-K and comply with the requirements of Regulation S-K
Item 304 (a)(2).  In making any disclosures about consultations
with
your new accountants, please ensure you disclose any consultations
up
through the date of engagement.




General
4. Include a letter from the former accountants addressing the
revised disclosures.   File the amendment under cover of Form 8-
K/A
and include the ITEM 4 designation, including the letter from the
former accountant filed as an Exhibit 16.
Please file your supplemental response and amendment via EDGAR in
response to these comments within 5 business days of the date of
this
letter.  Please note that if you require longer than 5 business
days
to respond, you should contact the staff immediately to request
additional time.  Direct any questions regarding the above to Ben
Phippen at (202) 551-3697.


							Sincerely,



							Benjamin Phippen, Staff
Accountant




</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
-----END PRIVACY-ENHANCED MESSAGE-----
