[1^st Franklin Financial Corporation Letterhead]

April 2, 2008

VIA EDGAR

Mr. Michael Clampitt

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C.  20549

Re:

1^st Franklin Financial Corporation
Form S-1
Filed December 26, 2007
File No. 333-148331

Dear Mr. Clampitt:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, 1^st Franklin Financial Corporation (the "Company") hereby requests that the effectiveness of its registration statement on Form S-1 (File No. 333-148331) be accelerated so that it becomes effective at 2:00 p.m. Eastern time on April 4, 2008 or as soon thereafter as is practicable.

In connection with the foregoing request, the Company acknowledges the following:

·

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·

the Company may not assert staff comments and this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please confirm that the Registration Statement has been declared effective by telephoning Neil M. Simon of Jones Day at (404) 581-8592.

Thank you for your attention to this matter.

Very truly yours,

1^st FRANKLIN FINANCIAL CORPORATION

By:   /s/ A. Roger Guimond

         A. Roger Guimond

         Vice President and Chief Financial Officer

cc:

Mark L. Hanson, Esq.

Neil M. Simon, Esq.

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