LETTER 1 filename1.txt December 9, 2005 Mail Stop 3561 Via U.S. Mail and Fax (254-761-2957) Mr. Bryan Baker Senior Vice President and Chief Financial Officer FirstCity Financial Corporation 6400 Imperial Drive Waco, TX 76712 RE: FirstCity Financial Corporation Form 10-K for the Year ended December 31, 2004 Filed March 21, 2005 File No. 033-19694 Dear Mr. Baker: We have completed our review of your Form 10-K and related filings and do not, at this time, have any further comments. Sincerely, Larry Spirgel Assistant Director ?? ?? ?? ??