November 20, 2019

Gregg E. Zahn
Chief Executive Officer
First Trinity Financial Corporation
7633 E. 63rd Place, Suite 730
Tulsa, OK 74133

       Re: First Trinity Financial Corporation
           Registration Statement on Form S-4
           Filed October 25, 2019
           File No. 333-234331

Dear Mr. Zahn:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-4

General

1.     We note your disclosure on the top of page 2 under "Questions and
Answers"
       that pursuant to the dissolution, holders of K-TENN Capital, Inc. common
stock will
       receive a pro rata distribution of the 168,866 shares of FTFC Class A
Common Stock
       received as a result of First Trinity Financial Corporation's
acquisition of K-TENN
       Insurance Company. We further note that cash may be paid for fractional
shares at the
       rate of $10.94 per whole share of FTFC Class A Common Stock. In order
for holders
       of K-TENN Capital, Inc.'s shares to properly assess what they will
receive from the
       proposed dissolution, please provide the following:

           the estimated net assets of K-TENN Capital, Inc. following the sale
of its subsidiary
           K-TENN Insurance Company to First Trinity Financial Corporation;
 Gregg E. Zahn
First Trinity Financial Corporation
November 20, 2019
Page 2
           the number of holders of K-TENN Capital, Inc. stock and the number
of holders
           owning more than 45 shares;
           what K-TENN Capital, Inc. will do if it does not have cash available
to pay for
           fractional shares upon dissolution and how it will dispose of the
remainder of FTFC
           Class A Common Stock not distributed in fractional amounts; and
           summary balance sheet information for K-TENN Capital, Inc. covering
the same time
           periods represented by the financial statements presented for K-TENN
Insurance
           Company.
Proposal 1: The Share Exchange
Determination of the Exchange Ratio, page 29

2.     We note you rely on ValueScope's May 2019 valuation as a partial basis
for your
       valuation of FTFC Class A Common Stock at $10.94 per share. Please
obtain and file as
       an exhibit ValueScope's consent to the use of its name in this
registration statement.
       Alternately, you may retain the description of the circumstances under
which the valuation
       was obtained, but should remove the references to ValueScope's name. In
addition, please
       remove the reference to ValueScope's fairness opinion on page 29, since
you have not
       obtained one for this transaction.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact David Gessert at 202-551-2326 or Erin Purnell at
202-551-3454 with any
questions.



                                                           Sincerely,
FirstName LastNameGregg E. Zahn
                                                           Division of
Corporation Finance
Comapany NameFirst Trinity Financial Corporation
                                                           Office of Finance
November 20, 2019 Page 2
cc:       Reid A. Godbolt, Esq.
FirstName LastName