NATIONAL HOUSING PARTNERSHIP REALTY FUND TWO
                         55 Beattie Place, P.O. Box 1089
                              Greenville, SC 29602

June 9, 2005

Correspondence Filing Via Edgar and Overnight Delivery

United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 0409
450 Fifth Street, NW
Washington, D.C.  20549
Attn:  Mr. Steven Jacobs

Re:   National Housing Partnership Realty Fund Two
      Form 10-KSB for the year ended December 31, 2004 File No. 0-14458

Ladies and Gentlemen:

This letter responds to the comments of the staff of the Securities and Exchange
Commission (the "Staff")  addressed to National Housing  Partnership Realty Fund
Two, a Maryland limited partnership (the  "Partnership"),  in a letter dated May
25, 2005, which was sent in response to the  Partnership's May 10, 2005 response
to the Staff's original  comment letter dated April 13, 2005. The  Partnership's
response  to the  Staff's  comments  are set  forth  below and are  numbered  to
correspond to the numbering of the Staff's comments in the Staff's letter.

                        *     *     *     *     *

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

Financial Statements and Notes

Note 1 - Summary of  Partnership  Organization  and  Significant  Accounting
Policies

Recent Accounting Pronouncements

1.       Comment:  We do not understand how the Partnership's  ability to remove
         the general partner has significant effect on the success of the entity
         in light of your  response  to comment 1 that the  general  partner has
         operating  control and financial control through various rights and has
         "demonstrated exercise of that control...  over the twenty-year history
         of the local limited partnerships."

      Please  clarify as these  conclusions  appear  inconsistent.  In addition,
      please  tell us how  various  rights and  obligations  held by the general
      partner  documented  in your  response  to prior  comment 1 impacted  your
      analysis under paragraph 5(b).

      Response:  In developing its response to the Staff's  comment letter dated
      April 13, 2005, the Partnership  considered  whether its conclusions under
      SOP 78-9 were consistent  with its conclusions  under FIN 46R with respect
      to "important  rights" held by the Partnership,  as limited partner in the
      local limited partnerships.  These important rights include the ability to
      remove the general  partner and consent to the sale of  substantially  all
      assets  of each  local  limited  partnership.  As  discussed  in its prior
      response,  the Partnership  concluded based on specific  provisions of the
      partnership  agreements and the history of the local limited  partnerships
      that  the  Partnership  was  not  a  "controlling   limited   partner"  as
      contemplated  in  paragraph  10 of  SOP  78-9.  In its  interpretation  of
      paragraph 5.b(1) of FIN 46R, the Partnership  concluded that the important
      rights of the limited  partners do, however,  provide the Partnership with
      the  "indirect  ability ... to make  decisions ... that have a significant
      effect on the  success of the  entity."  The  Partnership  recognized  the
      potential  conflict in its conclusions  under SOP 78-9 and FIN 46R related
      to the  rights  of  limited  partners,  but  ultimately  concluded  that a
      substantially   greater  level  of  influence  over  the  operational  and
      financial  policies of an investee is necessary to achieve "control" under
      paragraph 10 of SOP 78-9 than is necessary to "have a significant  effect"
      under paragraph  5.b(1) of FIN 46R. The  Partnership  continues to believe
      that  the   existence  of   important   rights  does  not  result  in  the
      Partnership's control of the local limited partnerships,  but does provide
      the Partnership with the ability to have a significant effect on the local
      limited partnerships.


      2.  Comment:  It is  unclear  from  your  response  how you  reached  your
      conclusions   under  paragraph  5(c).   Please  explain  why  you  believe
      substantially all the activities of the local limited  partnerships do not
      involve and are not conducted on behalf of you and NHP,  collectively.  In
      addition, please tell us what other parties are involved in the activities
      and for whose benefit they are conducted.

      Response:  An  essential  criterion  for an entity to be  considered a VIE
      under paragraph 5(c) is "substantially all of the entity's  activities ...
      either  involve  or are  conducted  on  behalf  of an  investor  that  has
      proportionately  few voting rights." The Partnership  does not believe and
      did not intend to imply in its prior response that  substantially  all the
      activities  of the local limited  partnerships  do not involve and are not
      conducted  on  behalf  of  the  Partnership  and  NHP,  collectively.  The
      Partnership  believes that all partners in the local limited  partnerships
      benefit from the activities of such partnerships.  The Partnership has not
      identified parties other than the Partnership and NHP that are involved in
      the  activities of the local limited  partnerships  and has not identified
      parties other than the  Partnership and NHP for whom the activities of the
      local limited partnerships are conducted.

                                    * * * * *

As requested by the Staff in its letter  dated April 13, 2005,  the  Partnership
again acknowledges that: (a) the Partnership is responsible for the adequacy and
accuracy of the  disclosure  in the  filings;  (b) Staff  comments or changes to
disclosure in response to Staff  comments do not foreclose the  Commission  from
taking any action with respect to the filings;  and (c) the  Partnership may not
assert Staff comments as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

If you have further questions regarding the information provided, please contact
the undersigned or Stephen Waters.  Mr. Waters can be reached  directly at (864)
239-1554 or by fax at (864) 239-5824.

                                   Sincerely,


                                    /s/ David R. Robertson
                                    David R. Robertson
                                    President and Chief Executive Officer of
                                    National Corporation for Housing
                                    Partnerships, the general partner of The
                                    National Housing Partnership, the general
                                    partner of National Housing Partnership
                                    Realty Fund Two