-----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, JbeNdSIILEBtXN7vQgmqj3I4tHbPyIrpiTIZefWbk4h57uFkrGuxLk9HCVXkUxQa EUZiXc0ZEgz08f/qiqEPXg== 0000939057-09-000238.txt : 20091023 0000939057-09-000238.hdr.sgml : 20091023 20090902143658 ACCESSION NUMBER: 0000939057-09-000238 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090902 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SECURITY FEDERAL CORP CENTRAL INDEX KEY: 0000818677 STANDARD INDUSTRIAL CLASSIFICATION: SAVINGS INSTITUTION, FEDERALLY CHARTERED [6035] IRS NUMBER: 570858504 STATE OF INCORPORATION: SC FISCAL YEAR END: 0331 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 238 RICHLAND AVENUE WEST CITY: AIKEN STATE: SC ZIP: 29801 BUSINESS PHONE: 8036413000 MAIL ADDRESS: STREET 1: 238 RICHLAND AVENUE WEST CITY: AIKEN STATE: SC ZIP: 29801 FORMER COMPANY: FORMER CONFORMED NAME: SECURITY FEDERAL CORPORATION DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm Unassociated Document



[Breyer & Associates PC Letterhead]


September 2, 2009



Via EDGAR and Messenger

Michael R. Clampitt, Senior Attorney
Financial Services Group
Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 4561
Washington, D.C.  20549
 
Re: 
 Security Federal Corporation Registration Statement on Form S-1/A  
  File Number 333-160553 

Dear Mr. Clampitt:

Pursuant to the Securities Act of 1933, as amended (the “Act”), and the rules and regulations thereunder, on behalf of our client Security Federal Corporation (the “Holding Company”), we enclose herewith for filing Pre-Effective Amendment No. Two (the “Amendment”) to the Holding Company’s Registration Statement on Form S-1 relating to the Holding Company’s proposed offering.

The Amendment responds to comments raised by the Staff of the Securities and Exchange Commission in its letter dated August 31, 2009 (the “Comment Letter”).  The Holding Company’s responses to the Staff’s comments are numbered to correspond to the numbered comments in the Comment Letter.

  The Amendment is marked to show all revisions to the original submission made on August 27, 2009.

Where You Can Find More Information, page 1
 
1.  
In response to this comment, additional disclosure to incorporate by reference the Form 10-K/A filed August 26, 2009 has been provided on page 1 of the prospectus.
 
Exhibit 5.1
 
2.  
The first paragraph on page 2 of the opinion has been revised as requested.
 
* * * * *

 
 
 
 
Michael R. Clampitt, Senior Attorney
Securities and Exchange Commission
September 2, 2009
Page 2 
 
 
 
We will provide requests from the Holding Company for acceleration of the effective date of the registration statement as soon as the Staff is prepared to receive them.

We appreciate the Staff’s assistance in reviewing Amendment No. 2, and request that the Staff direct any questions with respect to these responses to the undersigned.
 
 
  Very truly yours, 
   
  /s/ John F. Breyer, Jr. 
   
  John F. Breyer, Jr. 
 
 
cc:  (Hard copy by messenger) 
  Michael R. Clampitt, Senior Attorney, Mail Stop 4561 
  Matt McNair, Staff Attorney, Mail Stop 4561 
 
           
 
 
 



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