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<SEC-DOCUMENT>0000318673-05-000021.txt : 20060710
<SEC-HEADER>0000318673-05-000021.hdr.sgml : 20060710

<ACCEPTANCE-DATETIME>20050621191952

<PRIVATE-TO-PUBLIC>

ACCESSION NUMBER:		0000318673-05-000021

CONFORMED SUBMISSION TYPE:	8-K/A

PUBLIC DOCUMENT COUNT:		4

CONFORMED PERIOD OF REPORT:	20050606

ITEM INFORMATION:		Changes in Registrant.s Certifying Accountant

FILED AS OF DATE:		20050622

DATE AS OF CHANGE:		20050706


FILER:


	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:		8-K/A

		SEC ACT:		1934 Act

		SEC FILE NUMBER:	000-09341

		FILM NUMBER:		05908926



	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>8-K/A
<SEQUENCE>1
<FILENAME>snfc8ka.txt
<TEXT>
                       SECURITIES AND EXCHANGE COMMISSION
                             Washington, D.C. 20549




                                   FORM 8-K/A




                                 CURRENT REPORT
                     PURSUANT TO SECTION 13 OR 15(d) OF THE
                         SECURITIES EXCHANGE ACT OF 1934



        Date of Report (Date of Earliest Event Reported): April 26, 2005



                     SECURITY NATIONAL FINANCIAL CORPORATION
             (Exact name of registrant as specified in this Charter)



     Utah                                0-9341             87-0345941
- -----------------                      ----------         -------------
(State or other jurisdiction   (Commission File Number)  (IRS Employer
 of incorporation)                                      Identification No.)



5300 South 360 West,  Salt Lake City, Utah                   84123
- ------------------------------------------                 ---------
(Address of principal executive offices)                  (Zip Code)



Registrant's Telephone Number, Including Area Code:  (801) 264-1060
                                                     --------------





                                 Does Not Apply
          (Former name or former address, if changed since last report)



<PAGE>






ITEM 4.01     Changes in Registrant's Certifying Accountant.

     On April  26,  2005,  Tanner  LC  ("Tanner")  resigned  as the  independent
accountants of Security  National  Financial  Corporation (the  "Company").  The
resignation  by Tanner was due to the  five-year  partner  rotation  requirement
mandated by the  Sarbanes-Oxley  Act and the determination by Tanner that in the
future  it would be unable to  maintain  the  necessary  industry  expertise  to
continue as the independent accountants for the Company (a letter from Tanner is
attached to this filing as an exhibit). Because Tanner resigned as the Company's
independent accountants, the Company's audit committee had no alternative but to
accept such resignation by Tanner.

     During the fiscal years ended December 31, 2004 and 2003 and the subsequent
interim period  preceding the cessation of the relationship  with Tanner,  there
were no disagreements (as defined in Item  304(a)(1)(iv) of Regulation S-K) with
Tanner on any matter of accounting principles or practices,  financial statement
disclosure  or  auditing  scope  or  procedures  or any  reportable  events  (as
described in Item  304(a)(1)(v) of Regulation S-K), which  disagreement,  if not
resolved to the satisfaction of the former accountants,  would have caused it to
make reference to the subject matter of the  disagreement in connection with its
report.  In addition,  the reports by Tanner on the balance sheet as of December
31, 2004, and the related  statements of operations,  stockholders'  equity, and
cash flows for each of the two years in the period ended  December 31, 2004, did
not contain an adverse opinion or a disclaimer of opinion and were not qualified
or modified as to uncertainty, audit scope or accounting principles.

     Pursuant to Item 304 of  Regulation  S-K,  the Company  submitted a copy of
this amended Form 8-K to Tanner prior to filing with the Commission.

ITEM 9.01  Financial Statements and Exhibits

         (c) Exhibits

16.1 Letter  from Tanner LC dated April 26,  2005  confirming  cessation  of the
     independent auditor relationship.

16.2 Letter from Tanner LC dated June 6, 2005  agreeing  with the  statements in
     the amended Form 8-K/A.

                                   SIGNATURES

     Pursuant to the  requirements  of the Securities  Exchange Act of 1934, the
registrant  has duly  caused  this  report  to be  signed  on its  behalf by the
undersigned hereunto duly authorized.


                                 SECURITY NATIONAL FINANCIAL CORPORATION
                                               (Registrant)



Date: June 6, 2005               By: /s/ Scott M. Quist
                                     ------------------
                                     Scott M. Quist
                                     President and Chief Operating Officer
</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-16
<SEQUENCE>2
<FILENAME>snfc161.txt
<TEXT>
                                  Exhibit 16.1

                             [Tanner LC Letterhead]








April 16, 2005

Mr. Scott M. Quist
President and Chief Operating Officer
Security National Financial Corporation
5300 South 360 West, Suite 250
Salt Lake City, UT 84123

Dear Mr. Quist:

This  is to  confirm  that  the  client-auditor  relationship  between  Security
National  Financial  Corporation  (Commission File Number 0-9341) and Tanner LC,
independent registered public accounting firm, has ceased.

Sincerely,


/s/ Tanner LC

cc:      Office of the Chief Accountant
         PCAOB Letter File
         Securities and Exchange Commission
         Mail Stop 9-5
         450 Fifth Street, NW
         Washington, DC 20549
</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>EX-16
<SEQUENCE>3
<FILENAME>snfc162.txt
<TEXT>
                                  Exhibit 16.2

                             [Tanner LC Letterhead]








June 6, 2005

Securities and Exchange Commission
Washington, D.C. 20549

Ladies and Gentlemen:

We have read the  statements  included  under Item 4.01 in the Form 8-K/A  dated
June 6, 2005, of Security  National  Financial  Corporation to be filed with the
Securities  and Exchange  Commission  and are in agreement  with the  statements
therein insofar as they relate to our firm.

Very truly yours,

/s/ Tanner LC

</TEXT>
</DOCUMENT>
<DOCUMENT>
<TYPE>COVER
<SEQUENCE>4
<FILENAME>filename4.txt
<TEXT>
                         MACKEY PRICE THOMPSON & OSTLER
                           A Professional Corporation
                         Attorneys and Counselors at Law

                                American Plaza II
                          57 West 200 South, Suite 350
                          Salt Lake City, UT 84101-3663
                             Telephone 801-575-5000
                                Fax 801-575-5006

Randall A. Mackey
rmackey@mpwlaw.com






                                  June 7, 2005




VIA FEDERAL EXPRESS

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Mail Stop 0408
Judiciary Plaza
Washington, D.C. 20549

Attn: Benjamin Phippen
      Staff Accountant

     Re: Security National Financial Corporation  - Amendment No.1 to Form 8-K,
         as filed on May 3, 2005, File No. 000-09341

Ladies and Gentlemen:

     In  connection  with the  above-captioned  Form 8-K (the  "Form  8-K"),  we
enclose  the  following  with  the  Securities  and  Exchange   Commission  (the
"Commission")  for review on behalf of Security National  Financial  Corporation
(the "Company"):



<PAGE>

A.   Two conformed copies of Amendment No. 1 (the  "Amendment") to the Form 8-K,
     including exhibits; and

B.   Two additional  conformed  copies of Amendment No. 1 to the Form 8-K, which
     have  been  marked to  indicate  changes  from the Form 8-K filed  with the
     Commission on May 3, 2005.

It should be noted that the Company  electronically  filed the  Amendment to the
Form 8-K via the Edgar system on June 7, 2005.

     We are also  enclosing a copy of the  comment  letter  dated May 31,  2005,
which we received from the staff of the Commission.  The following  responses to
the comments are tied to the numbered paragraphs on the enclosed comment letter.



<PAGE>


     1. The Form  8-K has been  revised  to  state  that  Tanner  LC  ("Tanner")
resigned as the  independent  accountants  of the  Company due to the  five-year
partner  rotation  requirement  mandated  by  the  Sarbanes-Oxley  Act  and  the
determination  by Tanner that in the future it would be unable to  maintain  the
necessary   industry   expertise  to  continue  as  the  Company's   independent
accountants.

     2. Because Tanner resigned as the Company's  independent  accountants,  the
Company's  audit  committee  had no choice  but to accept  such  resignation  by
Tanner.  However,  the  Company's  audit  committee  approved the  engagement of
Hansen, Barnett & Maxwell, P.C. ("Hansen") as the new independent accountants to
replace Tanner.

     3. The Company  reported  engagement of Hansen in a Form 8-K that was filed
with the Securities and Exchange  Commission on May 25, 2005. The disclosures in
the May 25, 2005 Form 8-K about  consultations with Hansen were made through the
date of engagement.

     4. In response to this comment,  a letter from Tanner, the Company's former
independent  accountants,  addressing the revised disclosures have been included
as Exhibit 16 to an amended  Form 8-K.  The  amended  Form 8-K,  or Form  8-K/A,
includes the Item 4 designation.

     The Company has  prepared  Amendment  No. 1 to the Form 8-K in an effort to
respond to the comments  from the staff.  Any  additional  comments or questions
should be directed to Randall A. Mackey, Esq, at (801) 575-5000, counsel for the
Company.

                                    Very truly yours,

                                    /s/ Randall A. Mackey
                                    Randall A. Mackey
Enclosures
cc:      Scott M. Quist (w/encls.)
         G. Robert Quist (w/encls.)
         Stephen M. Sill (w/encls.)
         Virgil R. Pugsley (w/encls.)
         Douglas J.  Hansen
</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
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