N-CSR

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT

INVESTMENT COMPANIES

Investment Company Act file number 811-08228

The Timothy Plan

(Exact name of registrant as specified in charter)

1304 West Fairbanks Avenue Winter Park, FL	32789
(Address of principal executive offices)	(Zip code)

Citco Mutual Fund Services

83 General Warren Blvd., Suite 200

Malvern, PA 19355

(Name and address of agent for service)

Registrant’s telephone number, including area code: 1-800-846-7526

Date of fiscal year end: 12/31/2004

Date of reporting period: 12/31/2004

Form N-CSR is to be used by management investment companies to file reports with the Commission not later than 10 days after the transmission to stockholders of any report that is required to be transmitted to stockholders under Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1). The Commission may use the information provided on Form N-CSR in its regulatory, disclosure review, inspection, and policymaking roles.

A registrant is required to disclose the information specified by Form N-CSR, and the Commission will make this information public. A registrant is not required to respond to the collection of information contained in Form N-CSR unless the Form displays a currently valid Office of Management and Budget (“OMB”) control number. Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission, 450 Fifth Street, NW, Washington, DC 20549-0609. The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.

ITEM 1. The Annual Report to Shareholders for the period ended December 31, 2004 pursuant to Rule 30e-1 under the Investment Company Act of 1940, as amended, (the “1940 Act”) C17 CFR 270.30e-1 is filed herewith.

THE TIMOTHY PLAN

small-cap variable series

Annual Report

December 31, 2004

LETTER FROM THE PRESIDENT

December 31, 2004

ARTHUR D. ALLY

Dear Timothy Plan Small Cap Variable Series Shareholder:

I remember my dad once telling me that, as you get older, time speeds up. Although logic would explain that there are still 24 hours in a day and 365 days in a year, I’m beginning to think that dad was right. Even though the year 2004 was a leap year with 366 days, it seemed a lot shorter than 2003 which seemed a lot shorter than 2002, etc.

As usual, I will leave specific market comments to our sub-advisor, Jim Awad. However, from my perspective, our overall performance in 2004 was respectable. Although not as good as 2003, it was a whole lot better than 2002 – the year the market experienced some serious correction. And, for what it’s worth, I have a feeling that 2005 – even with its rough start – will prove to be mildly positive. Of course, in this industry, we cannot (and must not) ever make any guarantees of that fact.

We continue to have confidence in our sub-advisor. While performance will vary from year to year, we believe that good money managers will produce competitive returns over full market cycles. Our commitment to our shareholders continues to be that we take our role as managers of our managers very seriously.

In another vein, I am pleased to report that our mission continues to be on track. The Biblical Stewardship Seminar Series that we launched last year is beginning to have an impact. We have trained nearly 200 Christian financial planners and 50 ministry leaders to date and have certified them to teach this program in the churches and ministries in their respective communities or circles of influence. Once again, if any of you have an interest in having this seminar series presented to your church or ministry, please call us at 1-800-846-7526 or email us at info@timothyplan.com.

Thanks again for being part of the Timothy Plan family.

Sincerely,

Arthur D. Ally,

President

LETTER FROM THE MANAGER

December 31, 2004

JAMES D. AWAD

For the year ending December 31, 2004, the Timothy Plan Small Cap Variable Series returned 11.46% versus 18.33% for the Russell 2000. The Fund trailed the Russell because of the quality and valuation standards maintained by Awad; if we had relaxed these constraints we might have done better but this would not have been the right long-term decision. Awad’s focus is on risk-adjusted returns.

The stocks that had a positive effect on returns were: Brinks, Swift Energy, Champion Enterprises, InfoUSA and Stage Stores. The stocks that had a negative effect on returns were: Startek, Sourcecorp, Axcelis, K-V Pharmaceutical and MCG Capital.

All is well that ends well! After a frustrating start, 2004 ended with a sprint, creating the possibility that 2005 will get off to a good start. The markets are being supported by economic growth, profit growth, takeovers and tolerable levels of inflation and interest rates.

Conversely, some resistance is being applied by volatile energy prices, dollar instability, geopolitical tension and slight cyclical upticks in interest rates. Balancing out these facts leaves investors with a “glass-is-half-full” mindset, leading to a reasonable upward bias for equity prices as we close out 2004 and begin 2005. The momentum of growth in profits is likely to lead to continued gains in prices in early 2005. Lurking in the background, though, are the structural issues regarding the trade deficit, the federal deficit and the demographic issues surrounding Social Security and Medicare. Any remedy to these issues require a combination of tax increases and spending cuts, both of which are concretionary to the economy.

The financial markets will be watching closely to see if the Administration is willing to take credible action to address these issues and the report card will be the dollar. If the Administration acts credibly, we could have a mutli-year bull market. If the Administration does not act credibly, financial assets will react with skepticism. We will be reporting to you on these issues during 2005.

Meanwhile, we believe reasonably priced small cap equities with good growth prospects should provide good absolute and relative returns in 2005, just as they have for the past several years. In our view, investors will continue to gravitate towards securities which show earnings growth and are selling at reasonable valuations – characteristics which have been more often found in the small cap arena in recent years. Examples of new positions we have established which we believe meet these criteria are URS Corp. (design engineering), Dendrite International (cost saving software for the pharmaceutical industry and Sirva (relocation services). All are solid growing companies selling at attractive valuations and not well followed by Wall Street.

When investors hold strategically attractive companies, sometimes they are rewarded by having the companies taken over, as happened with Awad’s holdings in Barra, Allstream, Inversek and Sola during 2004. This is a distinctive plus for those who invest intelligently in the small cap arena.

Awad Asset Management finished 2004 with record assets under management. We will return your confidence with greater than ever effort. We look forward to doing well for the Timothy Plan in 2005.

/s/    JAMES D. AWAD        

James D. Awad

Chairman, Awad Asset Management

OFFICERS AND TRUSTEES OF THE TRUST

As of December 31, 2004

TIMOTHY PLAN FAMILY OF FUNDS

Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Arthur D. Ally* 1304 W Fairbanks Avenue Winter Park, FL	Chairman and President	Indefinite; Trustee and President since 1994	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1942	President and controlling shareholder of Covenant Funds, Inc. (“CFI”), a holding company. President and general partner of Timothy Partners, Ltd. (“TPL”), the investment adviser and principal underwriter to each Fund. CFI is also the managing general partner of TPL.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Joseph E. Boatwright** 1410 Hyde Park Drive Winter Park, FL	Trustee, Secretary	Indefinite; Trustee and Secretary since 1995	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1930	Retired Minister. Currently serves as a consultant to the Greater Orlando Baptist Association. Served as Senior Pastor to Aloma Baptist Church from 1970-1996.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Jock M. Sneddon** 6001 Vineland Drive Orlando, FL	Trustee	Indefinite; Trustee since 1997	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
	Physician, Florida Hospital Centra Care.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Mathew D. Staver** 210 East Palmetto Avenue Longwood, FL 32750	Trustee	Indefinite; Trustee since 2000	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1956	Attorney specializing in free speech, appellate practice and religious liberty constitutional law. Founder of Liberty Counsel, a religious civil liberties education and legal defense organization. Host of two radio programs devoted to religious freedom issues. Editor of a monthly newsletter devoted to religious liberty topics. Mr. Staver has argued before the United States Supreme Court and has published numerous legal articles.		None

OFFICERS AND TRUSTEES OF THE TRUST

As of December 31, 2004

TIMOTHY PLAN FAMILY OF FUNDS

Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Bill Dodson 7120 N Whitney Avenue Fresno, CA 93720	Trustee	Trustee from 2001 - 12/01/03	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1960	Vice President – Sales, CPCF, Inc. a registered broker-dealer and a subsidiary of the California Baptist Foundation and the California Southern Baptist Convention. Mr. Dodson is a General Securities Principal (Series 24) and licensed minister. Mr. Dodson has previous experience as a General Securities Representative (Series 7) with two national brokerage firms.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
W. Thomas Fyler, Jr. 640 Ft. Washington Avenue Suite 6C New York, NY 10040	Trustee	Trustee from 1998 - 12/01/03	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1957	President, controlling shareholder of W.T. Fyler, Jr./Ephesus, Inc., a New York State registered investment advisory firm. Founding member of the National Association of Christian Financial Consultants.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Mark A. Minnella 1215 Fern Ridge Parkway Suite 110 Creve Coeur, MO 63141	Trustee	Trustee from 2000 - 12/01/03	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1955	Principal and co-founder of Integrity Investors, LLC., a registered investment advisory firm. Co-founder, President and director of the National Association of Christian Financial Consultants. Mr. Minnella is a Registered Investment Principal (NASD Series 24), and a registered investment adviser (NASD Series 65).		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Charles E. Nelson 1145 Cross Creek Circle Altamonte Springs, FL	Trustee	Indefinite; Trustee since 2000	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1934	Certified Public Accountant. Director of Operations, National Multiple Sclerosis Society Mid Florida Chapter. Formerly Director of Finance, Hospice of the Comforter, Inc. Formerly Comptroller, Florida United Methodist Children’s Home, Inc. Formerly Credit Specialist with the Resolution Trust Corporation and Senior Executive Vice President, Barnett Bank of Central Florida, N.A. Formerly managing partner, Arthur Andersen, CPA firm, Orlando, Florida branch.		None

OFFICERS AND TRUSTEES OF THE TRUST

As of December 31, 2004

TIMOTHY PLAN FAMILY OF FUNDS

Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Wesley W. Pennington 442 Raymond Avenue Longwood, FL	Trustee	Indefinite; Trustee and Treasurer since 1994	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1930	Retired Air Force Officer. Past President, Westwind Holdings, Inc., a development company, since 1997. Past President and controlling shareholder, Weston, Inc., a fabric treatment company, form 1979-1997. President, Designer Services Group 1980-1988.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Scott Preissler, Ph.D. P O Box 50434 Indianapolis, IN 46250	Trustee	Indefinite; New as of 1/1/04	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1960	President and CEO of Christian Stewardship Association where he has been affiliated for the past 14 years.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Alan M. Ross 11210 West Road Roswell, Ga 30075	Trustee	Indefinite; New as of 1/1/04	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1951	Founder and CEO of Corporate Development Institute which he founded five years ago. Previously he served as President and CEO of Fellowship of Companies for Christ and has authored three books: Beyond World Class, Unconditional Excellence, Breaking Through to Prosperity.		None
Name, Age and Address	Position(s) Held With Trust	Term of Office and Length of Time Served	Number of Portfolios in Fund Complex Overseen by Trustee
Robert Scraper P O Box 1315 Houston, Tx 77251	Trustee	Indefinite; New as of 1/1/04	11
	Principal Occupation During Past 5 Years		Other Directorships Held by Trustee
Born: 1946	Senior Vice President - Investments for Frost National Bank of Texas since 1987.		None

RETURNS FOR THE YEAR ENDED

December 31, 2004

TIMOTHY PLAN SMALL CAP VARIABLE SERIES

Fund/Index	1 Year Total Return		5 Year Average Annual Return		Average Annual Total Return Since Inception May 22, 1998
Timothy Plan Small Cap Variable Series (a)	11.46	%	9.40	%	10.46	%
Russell 2000 Index (a)	18.33	%	6.60	%	6.93	%

(a) For the period May 22, 1998 (commencement of investment in accordance with objective) to December 31, 2004.

Timothy Small Cap Variable

vs Russell 2000 Index

The chart shows the value of a hypothetical initial investment of $10,000 in the Fund, and the Russell 2000 Index on May 22, 1998 and held through December 31, 2004. The Russell 2000 Index is widely recognized, unmanaged index of common stock prices. Performance figures include the change in value of the stocks in the index and the reinvestment of dividends. The index returns do not reflect expenses, which have been deducted from the Fund’s return. The returns shown do not reflect deduction of taxes that a shareholder would pay on fund distributions or the redemption of fund shares. THE FUND’S RETURN REPRESENTS PAST PERFORMANCE AND IS NOT PREDICTIVE OF FUTURE RESULTS.

TOP TEN HOLDINGS/INDUSTRIES/EXPENSE EXAMPLE

December 31, 2004

TIMOTHY PLAN SMALL CAP VARIABLE SERIES

FUND PROFILE:

Top Ten Holdings

(% of Net Assets)

Spartech Corp.	3.90	%
CommScope, Inc.	3.67	%
Stage Stores, Inc.	3.66	%
infoUSA, Inc.	3.52	%
KV Pharmaceutical Co.	3.27	%
Brink’s Co.	3.20	%
UNOVA, Inc.	3.18	%
Interactive Data Corp.	3.13	%
Champion Enterprises, Inc.	3.06	%
CBRL Group	3.01	%
	33.60	%

Industries

(% of Net Assets)

Consumer, Cyclical	17.97	%
Consumer, Non-cyclical	17.59	%
Industrial	16.39	%
Technology	9.08	%
Financial	8.41	%
Communications	7.27	%
Energy	7.14	%
Basic Materials	3.90	%
Other Assets less Liabilities, Net	12.25	%
	100.00	%

EXPENSE EXAMPLE:

As a shareholder of the Fund, you incur two types of costs: direct costs, such as wire fees and low balance fees; and indirect costs, including management fees, and other Fund operating expenses. This example is intended to help you understand your indirect costs, also referred to as “ongoing costs,” (in dollars) of investing in the Fund, and to compare these costs with the ongoing costs of investing in other mutual funds.

This example is based on an investment of $1,000 invested at the beginning of the period and held for the entire six-month period of July 1, 2004, through December 31, 2004.

Actual Expenses

The first line of the table below provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested at the beginning of the period, to estimate the expenses that you paid over the period. Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number in the first line under the heading “Expenses Paid During Period” to estimate the expenses you paid on your account during this period.

TOP TEN HOLDINGS/INDUSTRIES/EXPENSE EXAMPLE

December 31, 2004

TIMOTHY PLAN SMALL CAP VARIABLE SERIES

Hypothetical example for comparison purposes

The second line of the table provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Fund’s actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare ongoing costs of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of other funds.

Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any direct costs, such as wire fees or low balance fees. Therefore, the second line of the table is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds. In addition, if these direct costs were included, your costs would be higher.

	Beginning Account Value 7/1/04		Ending Account Value 12/31/04		During Period* July 1, 2004 Through 12/31/04
Actual - Class A	$	1,000.00	$	1,024.40	$	6.11
Hypothetical - Class A (5% return before expenses)		1,000.00		1,019.00		6.09

* Expenses are equal to the Fund’s annualized expense ratio of 1.20%, which is net of any expenses paid indirectly, multiplied by the average account value over the period, multiplied by 184 days/366 days (to reflect the one-half year period). The Fund’s ending account value on the first line in the table is based on its actual total return of 2.44% for the six-month period of July 1, 2004, to December 31, 2004.

SMALL CAP VARIABLE SERIES

SCHEDULE OF INVESTMENTS

As of December 31, 2004

COMMON STOCKS - 87.75%

number of shares		market value
	AUTOMOBILE & TRUCK PARTS - 2.29%
6,000	Adesa, Inc.	$	127,320
	BALL & ROLLER BEARINGS - 2.97%
5,000	Kaydon Corp.		165,100
	BUILDING - MOBILE HOME MANUFACTURED HOUSING - 3.06%
14,400	Champion Enterprises, Inc.*		170,208
	CONSUMER CREDIT REPORTING, COLLECTION AGENCIES - 1.58%
3,400	NCO Group, Inc.*		87,890
	DIVERSIFIED HOLDINGS - 2.49%
1	Allete		37
15,000	Quanta Capital Holdings, Ltd.*		138,300
			138,337
	DIVERSIFIED MANUFACTURING - 2.86%
9,000	Federal Signal Corp.		158,940
	FINANCIAL SERVICES - 1.14%
3,000	MoneyGram International, Inc.		63,420
	INDUSTRIAL AUTOMATION/ROBOTICS - 3.18%
7,000	UNOVA, Inc.*		177,030
	INVESTMENT COMPANIES - 2.93%
9,500	MCG Capital Corp.		162,735
	MISCELLANEOUS CAPITAL GOODS - 0.73%
2,000	Lennox International, Inc.		40,700
	MISCELLANEOUS PLASTIC PRODUCTS - 3.89%
8,000	Spartech Corp.		216,720
	OIL & GAS OPERATIONS - 7.14%
7,000	Comstock Resources, Inc.*		154,350
5,000	Energy Partners, Ltd.*		101,350
4,900	Swift Energy Co.*		141,806
			397,506
	PHARMACEUTICAL PREPARATIONS - 3.27%
8,250	K-V Pharmaceutical Co. - Class A*		181,912
	PUBLISHING - 5.63%
8,000	Interactive Data Corp.*		173,920
4,000	John Wiley & Sons, Inc. - Class A		139,360
			313,280

The accompanying notes are an integral part of these financial statements.

SMALL CAP VARIABLE SERIES

SCHEDULE OF INVESTMENTS

As of December 31, 2004

COMMON STOCKS - 87.75% (cont.)

number of shares		market value
	REAL ESTATE - OPERATIONS - 0.63%
2,500	Sunterra Corp.*	$	35,100
	RETAIL - FAMILY CLOTHING STORES - 3.66%
4,900	Stage Stores, Inc.*		203,448
	RETAIL - RESTAURANTS - 3.01%
4,000	CBRL Group, Inc.		167,400
	SERVICES - BUSINESS SERVICES - 7.32%
3,360	Charles River Laboratories, Inc.*		154,594
5,120	Sourcecorp, Inc.*		97,843
5,450	Startek, Inc.		155,052
			407,489
	SERVICES - DATA PROCESSING - 3.52%
17,500	infoUSA, Inc.*		195,825
	SERVICES - DIVERSIFIED/COMMERCIAL - 3.20%
4,500	The Brink’s Co.		177,840
	SERVICES - ENGINEERING - 1.73%
3,000	URS Corp.*		96,300
	SOFTWARE & PROGRAMMING - 2.23%
6,400	Dendrite International, Inc.*		124,160
	SPECIAL INDUSTRY MACHINERY - 2.19%
15,000	Axcelis Technologies, Inc.*		121,950
	SPECIALTY STORES - 5.16%
4,900	Sonic Automotive, Inc.		121,520
5,600	United Auto Group, Inc.		165,704
			287,224
	TECHNOLOGY DISTRIBUTION - 2.45%
3,000	Tech Data Corp.*		136,200
	TELECOMMUNICATIONS EQUIPMENT - 3.67%
10,800	CommScope, Inc.*		204,120

The accompanying notes are an integral part of these financial statements.

SMALL CAP VARIABLE SERIES

SCHEDULE OF INVESTMENTS

As of December 31, 2004

COMMON STOCKS - 87.75% (cont.)

number of shares		market value
	TELECOMMUNICATIONS SERVICES - 1.09%
1,481	Manitoba Telecome Services, Inc.	$	60,724
	THRIFTS & MORTGAGE FINANCE - 3.00%
4,000	The PMI Group, Inc.		167,000
	TRANSPORTATION - TRUCKING - 1.73%
5,000	Sirva, Inc.*		96,100
	Total Common Stocks (cost $3,896,667)		4,881,978
SHORT-TERM INVESTMENTS - 9.42%
number of shares		market value
262,000	Federated Cash Trust Series II Treasury		262,000
262,000	First American Treasury Obligations Fund, Class A		262,000
	Total Short-Term Investments (cost $524,000)		524,000
	TOTAL INVESTMENTS - 97.17% (identified cost $4,420,667)		5,405,978
	OTHER ASSETS AND LIABILITIES, NET - 2.83%		157,442
	NET ASSETS - 100.00%	$	5,563,420

* Non-income producing secruity

The accompanying notes are an integral part of these financial statements.

SMALL CAP VARIABLE SERIES

STATEMENT OF ASSETS AND LIABILITIES

As of December 31, 2004

ASSETS
	amount
Investments in Securities at Value (identified cost $4,420,667) [NOTE 1]	$	5,405,978
Cash		153,216
Receivables:
Interest		318
Dividends		8,711
Due from Advisor		5,214
Total Assets	$	5,573,437
LIABILITIES
	amount
Payable for Fund Shares Redeemed	$	3,524
Accrued Expenses		6,493
Total Liabilities	$	10,017
NET ASSETS
	amount
Net Assets	$	5,563,420
SOURCES OF NET ASSETS
	amount
At December 31, 2004, Net Assets Consisted of:
Paid-in Capital	$	4,204,401
Accumulated Net Realized Gain on Investments		373,708
Net Unrealized Appreciation in Value of Investments		985,311
Net Assets	$	5,563,420
Shares of Capital Stock Outstanding (No Par Value, Unlimited Shares Authorized)		330,661
Net Asset Value, Offering and Redemption Price Per Share ($5,563,420 / 330,661 Shares)	$	16.83

The accompanying notes are an integral part of these financial statements.

SMALL CAP VARIABLE SERIES

STATEMENT OF OPERATIONS

For the Year Ended December 31, 2004

INVESTMENT INCOME

	amount
Interest	$	2,057
Dividends (Net of Foreign Tax of $ 3,163)		58,012
Total Investment Income		60,069
EXPENSES
	amount
Investment Advisory Fees [Note 3]		53,974
Fund Accounting, Transfer Agency, & Administration Fees		12,024
Custodian Fees		2,934
Printing Fees		777
Auditing Fees		3,233
Insurance Expense		533
Participation Fees		10,795
Legal Expense		1,009
Miscellaneous Expense		2,595
Total Expenses		87,874
Expenses Waived by Advisor [Note 3]		(23,105	)
Total Net Expenses		64,769
Net Investment Loss		(4,700	)
REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS
	amount
Net Realized Gain on Investments		793,735
Change in Unrealized Appreciation of Investments		(210,033	)
Net Realized and Unrealized Gain on Investments		583,702
Increase in Net Assets Resulting from Operations	$	579,002

The accompanying notes are an integral part of these financial statements.

SMALL CAP VARIABLE SERIES

STATEMENTS OF CHANGES IN NET ASSETS

INCREASE (DECREASE) IN NET ASSETS

	year ended 12/31/2004			year ended 12/31/2003
Operations:
Net Investment Loss	$	(4,700	)	$	(8,868	)
Net Realized Gain (Loss) on Investments		793,735			(405,169	)
Net Change in Unrealized Appreciation of Investments		(210,033	)		2,068,297
Increase in Net Assets (resulting from operations)		579,002			1,654,260
Distributions to Shareholders:
Net Investment Income		—			—
Realized Gains		—			—
Total Distributions to Shareholders		—			—
Capital Share Transactions:
Proceeds from Shares Sold		227,902			259,399
Dividends Reinvested		—			—
Cost of Shares Redeemed		(543,700	)		(1,452,354	)
Decrease in Net Assets (resulting from capital share transactions)		(315,798	)		(1,192,955	)
Total Increase in Net Assets		263,204			461,305
Net Assets:
Beginning of Year		5,300,216			4,838,911
End of Year	$	5,563,420		$	5,300,216
Shares of Capital Stock of the Fund Sold and Redeemed:
Shares Sold		14,509			22,825
Shares Reinvested		—			—
Shares Redeemed		(34,941	)		(124,115	)
Net Decrease in Number of Shares Outstanding		(20,432	)		(101,290	)

The accompanying notes are an integral part of these financial statements.

SMALL CAP VARIABLE SERIES

FINANCIAL HIGHLIGHTS

The table below sets forth financial data for one share of capital stock outstanding throughout each year presented.

	year ended 12/31/04			year ended 12/31/03			year ended 12/31/02			year ended 12/31/01			year ended 12/31/00
Per Share Operating Performance:
Net Asset Value, Beginning of Year	$	15.10		$	10.70		$	13.05		$	12.29		$	12.37
Income from Investment Operations:
Net Investment Income (Loss)		(0.01	)		(0.03	)		(0.01	)		(0.02	)		0.07
Net Realized and Unrealized Gain (Loss) on Investments		1.74			4.43			(2.26	)		1.42			0.94
Total from Investment Operations		1.73			4.40			(2.27	)		1.40			1.01
Less Distributions:
Dividends from Net Investment Income		—			—			—			—			(0.08	)
Dividends from Realized Gains		—			—			—			(0.64	)		(1.01	)
Return of Capital Distribution		—			—			(0.08	)		—			—
Total Distributions		—			—			(0.08	)		(0.64	)		(1.09	)
Net Asset Value at End of Year	$	16.83		$	15.10		$	10.70		$	13.05		$	12.29
Total Return (a)		11.46	%		41.12	%		(17.38	%)		11.48	%		8.16	%
Ratios/Supplemental Data:
Net Assets, End of Year (in 000s)	$	5,563		$	5,300		$	4,839		$	5,114		$	3,326
Ratio of Expenses to Average Net Assets:
Before Reimbursement and Waiver of Expenses by Advisor		1.63	%		1.56	%		1.82	%		2.00	%		1.83	%
After Reimbursement and Waiver of Expenses by Advisor		1.20	%		1.20	%		1.20	%		1.20	%		1.20	%
Ratio of Net Investment Income (Loss) to Average Net Assets:
Before Reimbursement and Waiver of Expenses by Advisor		(0.52	)%		(0.55	)%		(0.73	)%		(0.94	%)		0.11	%
After Reimbursement and Waiver of Expenses by Advisor		(0.09	)%		(0.19	)%		(0.11	)%		(0.14	%)		0.74	%
Portfolio Turnover		63.35	%		51.95	%		69.14	%		67.40	%		85.82	%

(a) For Periods of Less Than One Full Year, Total Returns Are Not Annualized.

The accompanying notes are an integral part of these financial statements.

NOTES TO FINANCIAL STATEMENTS

December 31, 2004

SMALL CAP VARIABLE SERIES

Note 1 – Significant Accounting Policies

The Timothy Plan Small-Cap Variable Series (the “Fund”) was organized as a diversified series of The Timothy Plan (the “Trust”). The Trust is an open-ended investment company established under the laws of Delaware by an Agreement and Declaration of Trust dated December 16, 1993 (the “Trust Agreement”). The Fund’s primary objective is long-term capital growth, with a secondary objective of current income. The Fund seeks to achieve its investment objective by investing primarily in common stocks and American Depositary Receipts (ADRs) while abiding by ethical standards established for investments by the Fund. The Fund is one of a series of funds currently authorized by the Board of Trustees. The following is a summary of significant accounting policies consistently followed by the Fund in the preparation of its financial statements. The policies are in conformity with accounting principles generally accepted in the United States of America for investment companies.

A. Security Valuation.

Investments in securities traded on a national securities exchange are valued at the NASDAQ official closing price on the last business day of the period. Securities for which quotations are not available are valued at fair market value as determined in good faith by each Fund’s investment manager, in conformity with guidelines adopted by and subject to the review and supervision of the Board of Trustees. Unlisted securities, or listed securities in which there were no sales, are valued at the closing bid. Short-term obligations with remaining maturities of 60 days or less are valued at cost plus accrued interest, which approximates market value.

B. Investment Income and Securities Transactions.

Security transactions are accounted for on the date the securities are purchased or sold (trade date). Cost is determined and gains and losses are based on the identified cost basis for both financial statement and federal income tax purposes. Dividend income and distributions to shareholders are reported on the ex-dividend date. Interest income and expenses are accrued daily.

C. Net Asset Value Per Share.

Net asset value per share of the capital stock of the Fund is determined daily as of the close of trading on the New York Stock Exchange by dividing the value of its net assets by the number of Fund shares outstanding.

D. Federal Income Taxes.

It is the policy of the Fund to comply with all requirements of the Internal Revenue Code applicable to regulated investment companies and to distribute substantially all of its taxable income to its shareholders. Therefore, no federal income tax provision is required.

E. Use of Estimates.

In preparing financial statements in conformity with accounting principles generally accepted in the United States of America, management makes estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements, as well as the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.

F. Reclassifications.

Accounting principles generally accepted in the United States of America require that certain components of net assets be reclassified between financial and tax reporting. These reclassifications have no effect on the net assets or net asset value per share. For the year ended December 31, 2004, the Fund increased accumulated net investment loss and decreased paid-in-capital by $4,700.

Note 2 – Purchases and Sales of Securities

Purchases and sales of securities, other than short-term investments, aggregated $3,112,219 and $3,748,851 respectively, for the year ended December 31, 2004.

Note 3 – Investment Management Fee and Other Transactions with Affiliates

Timothy Partners, LTD., (“TPL”) is the investment Advisor for the Fund pursuant to an investment Advisory Agreement (the “Agreement”) effective February 27, 2004. Under the terms of the Agreement, TPL receives a fee, accrued daily and paid monthly, at an annual rate of 1.00% of the average daily net assets of the Fund. The Advisor has voluntarily agreed to reduce fees payable to it by the Fund and reimburse other expenses to the extent necessary to limit the Fund’s aggregate annual operating expenses, excluding brokerage commissions and other portfolio transaction expenses, interest, taxes, capital

NOTES TO FINANCIAL STATEMENTS

December 31, 2004

SMALL CAP VARIABLE SERIES

expenditures and extraordinary expenses, to 1.20% of average daily net assets through December 31, 2004. As a result, the Advisor has waived a portion of their fee and reimbursed the Fund for expenses in excess of the limit in the amount of $23,105 for the year ended April 30, 2005. There is no guarantee that the Advisor will waive fees and/or reimburse expenses in the future.

At December 31, 2004, the cumulative amounts available for reimbursement that has been paid and/or waived by the Advisor on behalf of the Fund are as follows:

funds
Small-Cap Variable Series	$	75,003

At December 31, 2004, the Advisor may recapture a portion of the above amounts no later than the dates as stated below:

funds	12/31/05		12/31/06		12/31/07
Small-Cap Variable Series	$	34,673	$	17,225	$	23,105

Note 4 – Unrealized Appreciation (Depreciation)

At December 31, 2004, the cost for federal income tax purposes is $4,420,667. At December 31, 2004, the composition of gross unrealized appreciation (depreciation) of investment securities for tax purposes is as follows:

	Appreciation		Depreciation		Net Appreciation
The Timothy Plan Small-Cap Variable Series	$	1,044,478	($59,167	)	$	985,311

Note 5 – Distributions to Shareholders

There were no distributions paid during the years ended December 31, 2004 and 2003.

	Small-Cap Variable Fund
As of December 31, 2004, the components of distributable earnings on a tax basis were as follows:
Undistributed Ordinary Income	$	—
Accumulated Long-term Capital Gains		373,708
Unrealized Appreciation		985,311
	$	1,359,019

Note 6 – N-Q Disclosure & Proxy Procedures

The SEC has adopted the requirement that all Funds file a complete schedule of investments with the SEC for their first and third fiscal quarters on Form N-Q for fiscal quarters ending after July 9, 2004. For the Timothy Plan Funds this would be for the fiscal quarters ending March 31 and September 30. The Form N-Q filing must be made within 60 days of the end of the quarter. The Timothy Plan Funds’ Forms N-Q will be available on the SEC’s website at http://sec.gov, or they may be reviewed and copied at the SEC’s Public Reference Room in Washington, DC (call 1-800-732-0330 for information on the operation of the Public Reference Room).

The Trust has adopted Portfolio Proxy Voting Policies and Procedures under which the Portfolio’s vote proxies related to securities (“portfolio proxies”) held by the Portfolios. A description of the Trust’s Portfolio Proxy Voting Policies and Procedures is available (i) without charge, upon request, by calling the Company toll-free at 800-846-7526 and (ii) on the SEC’s website at www.sec.gov n addition, the fund will be required to file new Form N-PX, with its complete voting record for the 12 months ended June 30th, no later than August 31st of each year. The first such filing was due August 31, 2004. Once filed, the Trusts’s Form N-PX will be available (i) without charge, upon request, by calling the Company toll-free at 800-846-7526 and (ii) on the SEC’s website at www.sec.gov.

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

SMALL CAP VARIABLE SERIES

To the Shareholders and Board of Trustees

The Timothy Plan

Winter Park, Florida

We have audited the accompanying statement of assets and liabilities of The Timothy Plan Small-Cap Variable Series (“the Fund”), a series of shares of The Timothy Plan, including the portfolio of investments, as of December 31, 2004, and the related statements of operations for the year then ended, the changes in net assets for each of the two years in the period then ended and the financial highlights for each of the five years in the period then ended. These financial statements and financial highlights are the responsibility of the Fund’s management. Our responsibility is to express an opinion on these financial statements and financial highlights based on our audits.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (US). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements and financial highlights are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of December 31, 2004, by correspondence with the custodian. An audit also includes assessing the accounting principles used and significant estimates made by management, as well as evaluating the overall financial statement presentation. We believe that our audits provide a reasonable basis for our opinion.

In our opinion, the financial statements and financial highlights referred to above present fairly, in all material respects, the financial position of The Timothy Plan Small-Cap Variable Series as of December 31, 2004, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period then ended and the financial highlights for each of the five years in the period then ended in conformity with accounting principles generally accepted in the United States of America.

TAIT, WELLER & BAKER

Philadelphia, Pennsylvania

February 18, 2005

1304 West Fairbanks Avenue

Winter Park, FL 32789

(800) TIM-PLAN

(800) 846-7526

Visit the Timothy Plan web site on the internet at:

www.timothyplan.com

This report is submitted for the general information of the shareholders of the Fund. It is not authorized for distribution to prospective investors in the Fund unless preceded or accompanied by an effective Prospectus which includes details regarding the Fund’s objectives, policies, expenses and other information. Distributed by Timothy Partners, Ltd.

ITEM 2. CODE OF ETHICS.

(a) The registrant has, as of the end of the period covered by this report, adopted a code of ethics that applies to the registrant’s principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party.

(b) During the period covered by this report, there were no amendments to any provision of the code of ethics.

(c) During the period covered by this report, there were no waivers or implicit waivers of a provision of the code of ethics.

(d) The registrant’s code of ethics is filed herewith.

ITEM 3. AUDIT COMMITTEE FINANCIAL EXPERT.

The registrant’s Board of Trustees has determined that Charles Nelson, a member of the registrant’s Board of Trustees and Audit Committee, qualifies as an audit committee financial expert. Mr. Nelson is “independent” as that term is defined in paragraph (a)(2) of this item’s instructions.

ITEM 4. PRINCIPAL ACCOUNTANT FEES AND SERVICES.

The aggregate audit fees billed to The Timothy Plan. for the last two fiscal years by the principal accountant were $79,500. and $73,000, respectively.

Audit-Related Fees. There were no audit related fees, other than those noted under “Audit Fees” Disclosure, billed to The Timothy Plan for the last two fiscal years by the principal accountant.

Tax Fees. The aggregate fees billed in each of the last two fiscal years for professional services rendered by the principal accountant for tax compliance were $24,000. and $22,000., respectively.

All Other Fees. There were no aggregate fees billed in the last two fiscal years for products and services provided by the registrant’s principal accountant, other than the services reported in paragraphs (a) through (c) of this Item.

ITEM 5. AUDIT COMMITTEE OF LISTED REGISTRANTS.

Not applicable.

ITEM 6. SCHEDULE OF INVESTMENTS

Included in the Annual Report to Shareholders filed under Item 1 of this form.

ITEM 7. DISCLOSURE OF PROXY VOTING POLICIES AND PROCEDURES FOR CLOSED-END MANAGEMENT INVESTMENT COMPANIES.

Not applicable.

ITEM 8. PORTFOLIO MANAGERS OF CLOSED-END MANAGEMENT INVESTMENT COMPANY

Not Applicable

ITEM 9. PURCHASE OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND AFFILIATED PURCHASERS.

Not applicable.

ITEM 10. SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS

There has been no material changes to the procedures by which shareholders may recommend nominees to the registrant’s board of trustees.

ITEM 11. CONTROLS AND PROCEDURES

a. The registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the registrant’s disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940, as amended (the “1940 Act”) are effective, as of a date within 90 days of the filing date of the report that includes the disclosure required by this paragraph, based on their evaluation of these controls and procedures required by Rule 30a-3(b) under the 1940 Act and Rule 15d-15(b) under the Securities Exchange Act of 1934, as amended.

b. There were no changes in the registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the 1940 Act) that occurred during the registrant’s last fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.

ITEM 12. EXHIBITS.

(a	)(1)	Code of Ethics required to be disclosed under item 2 is attached hereto.
(a	)(2)	Certifications pursuant to Section 302 of the Sarbanes-Oxley Act of 2002 are attached hereto.
(b	)	Certification pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 is attached hereto.

SIGNATURES

[See General Instruction F]

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

(Registrant) The Timothy Plan.
By	/s/    ARTHUR D. ALLY
	Arthur D. Ally, PRESIDENT

Date 3/7/2005

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By	/s/    ARTHUR D. ALLY
	Arthur D. Ally, PRESIDENT

Date 3/7/2005

By	/s/    ARTHUR D. ALLY
	Arthur D. Ally, TREASURER

Date 3/7/2005

* Print the name and title of each signing officer under his or her signature.

EX-99.CODE ETH

Code of Ethics

Of The Timothy Plan

I. Introduction

This Code of Ethics, as amended, has been adopted by The Timothy Plan (the “Trust”) in compliance with Rule 17j-1 (the “Rule”) under the Investment Trust Act of 1940, as amended, and Section 406 of the Sarbanes-Oxley Act of 2002 (the “Acts”) to establish standards and procedures for the detection and prevention of activities by which persons having knowledge of the investments and investment intentions of the Trust may abuse their fiduciary duties to the Trust, to deal with other types of conflict-of-interest situations to which the Rule is addressed, and to establish certain standards, policies, and procedures, designed specifically, but not exclusively to address the conduct of the principal executive officer, the principal financial officer, accounting officer, controller, and any other persons acting in any such capacity:

A. To promote honest and ethical conduct, including the ethical handling of actual or perceived conflicts of interest between personal and professional relationships;

B. To effect full, fair, accurate, timely, and understandable disclosures in reports and documents that a company files with, or submits to, the Securities and Exchange Commission, state securities oversight agency(ies), and in other public communications made by the Trust;

C. To comply with applicable federal and state government laws, rules, and regulations;

D. To provide for accountability for the policies and procedures set forth herein, and strict adherence thereto, and regulatory compliance by the principal executive officer, the principal financial officer, accounting officer or controller, and any other persons acting in any such capacity.

E. To establish accountability and encourage reporting of known or perceived transgressions of the Code.

The Rule makes it “unlawful” for certain persons who have affiliations with the Trust to engage in conduct which is deceitful, fraudulent or manipulative, or which involves false or misleading statements, in connection with the purchase or sale of securities by the Trust. This Code of Ethics is intended to establish policies and procedures designed to insure that persons subject to this Code of Ethics and the Rule do not use any information concerning the investments or investment intentions of the Trust, or his or her ability to influence such investment related information, for personal gain or in a manner detrimental to the interests of the Trust.

II. Principles

This Code of Ethics acknowledges the general principles that persons affiliated with the Trust:

A. owe a fiduciary obligation to the Trust;

B. have the duty at all times to place the interests of Trust shareholders first;

C. must conduct all of their personal securities transactions in such a manner as to avoid any actual or potential conflict of interest or abuse of such person’s position of trust and responsibility; and

D. should not take inappropriate advantage of their positions in relation to the Trust.

III. Definitions (as used herein)

A. “Access Person” means:

Any Trustee, officer, including but not limited to the principal executive officer, the principal financial officer, accounting officer or controller of the Trust and any person acting in any such capacity, general partner or Advisory Person of the Trust or any Adviser to the Trust.

(1) If an Adviser to the Trust is primarily engaged in a business or businesses other than advising Funds or other advisory clients, the term Access Person means any Trustee, officer, general partner or Advisory Person of the Adviser who, with respect to any Fund, makes any recommendation, participates in the determination of which recommendation will be made, or whose principal function or duties relate to the determination of which recommendation will be made, or who, in connection with his or her duties, obtains any information concerning recommendations on Covered Securities being made by the Adviser to any Fund.

1. An Adviser is “primarily engaged in a business or businesses other than advising Funds or other advisory clients” if, for each of its most recent three fiscal years or for the period of time since its organization, whichever is less, the Adviser derived, on an unconsolidated basis, more than 50% of its income (or loss), before taxes and extraordinary items, from the other business or businesses.

2. Any Trustee, officer or general partner of a principal underwriter who, in the ordinary course of business, makes, participates in or obtains information regarding, the purchase or sale of Covered Securities by the Trust for which the principal underwriter acts, or whose functions or duties in the ordinary course of business relate to the making of any recommendation to the Trust, regarding the purchase or sale of Covered Securities.

B. “Advisory Person” means:

1. Any employee of the Trust or an Adviser to the Trust (or of any Trust in a control relationship to the Trust or an investment adviser to the Trust) who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of Covered Securities by the Trust, or whose functions relate to the making of any recommendations with respect to such purchases or sales; and

2. Any natural person in a control relationship to the Trust or an Adviser to the Trust who obtains information concerning recommendations made to the Trust with regard to the purchase or sale of Covered Securities by the Trust

C. “Affiliated Person” means:

1. Any officer, including but not limited to the principal executive officer, the principal financial officer, accounting or controller of the Trust and any person acting in any such capacity, Trustee, copartner or employee of the Trust, Adviser and/or Underwriter;

2. any person directly or indirectly owning, controlling or holding with power to vote, 5% or more of the outstanding voting securities of the Trust, Adviser and/or Underwriter;

3. any person 5% or more of whose outstanding voting securities are directly or indirectly owned, controlled or held with power to vote, by the Trust, Adviser and/or Underwriter; and

4. any person directly or indirectly controlling, controlled by, or under common control with the Trust, Adviser and/or Underwriter.

D. “Beneficial Interest” means:

1. Any interest by which an Access Person or any member of his or her immediate family (relative by blood or marriage living in the same household), can directly or indirectly derive a monetary benefit from the purchase, sale (or other

acquisition or disposition) or ownership of a security, except such interests as Clearing Officers shall determine to be too remote for the purpose of this Code of Ethics. (A transaction in which an Access Person acquires or disposes of a security in which he or she has or thereby acquires a direct or indirect Beneficial Interest will be referred to in this Code of Ethics as a “personal securities” transaction or as a transaction for the person’s “own account”). At the written request of a person subject to this Code of Ethics, the Clearing Officers, in their sole discretion or with the advice of counsel, may from time to time issue written interpretations as to whether an Access Person has a “Beneficial Interest” in a security or a transaction, and whether a transaction is or would be considered to be a “personal securities” transaction or a transaction “for the person’s own” account for purposes of the reporting requirements under this Code. Any such written interpretations shall be included in Appendix A attached to and incorporated by reference into this Code of Ethics, and may be relied upon solely by the person(s) seeking such interpretations.

E. “Clearing Officers” means:

1. any two officers of the Trust who are not:

a. parties to the transaction;

b. related by blood or marriage to a party to the transaction; and

c. interested in or affiliated persons of the issuer of the securities at issue.

F. “Control” means:

The power to exercise a controlling influence over the management or policies of a Trust (unless such power is solely the result of an official position with such Trust). Any person who owns beneficially, directly or through one or more controlled companies, more than 25% of the voting securities of a Trust shall be presumed to control such Trust.

G. “Covered Security” means:

All stock, debt obligations and other instruments comprising the investments of the Trust, including any warrant or option to acquire or sell a security, and financial futures contracts, except that it does not include:

a. Direct obligations of the Government of the United States;

b. Banker’s acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements, and

c. Shares issued by open-end Funds.

References to a “Security” in this Code of Ethics shall include any warrant for, option in, or security immediately convertible into that “Security.”

H. “Fund” means:

0. An investment company registered under the Act, and includes the Trust.

I. A “security held or to be acquired” by the Trust means:

0. any Covered Security which, within the most recent 15 calendar days: (i) is or has been held by the Trust; or (ii) is being or has been considered by an Adviser for purchase by the Trust.

J. A security is “being considered for purchase or sale”;

from the time an order is given by or on behalf of the Trust to the order room of the Adviser until all orders with respect to that security are completed or withdrawn.

IV. The principal executive officer, the principal financial officer, accounting officer or controller any person acting in any such capacity for the Trust as applicable:

A. shall prepare and submit, or cause to be prepared and submitted, all documents, reports, and other items requested from time to time, to the appropriate regulatory authority(ies) and agency(ies) including federal, state, and self-regulatory organizations, and the public if so required by law or rule. All such reports shall be prepared fairly and accurately, fully disclosing all applicable information in a format that shall be understandable and easily read.

B. shall maintain the books, records, and documents, and shall at all times conduct the Trust’s business in such a manner so as to fully comply with all applicable government laws, and regulations promulgated thereunder, including all federal, state, and local laws and ordinances.

C. shall make the Code of Ethics of the Trust available to all parties upon receipt of a request. Requests may be made by calling the Trust at 1-800-846-7526, or by writing the Trust at 1304 West Fairbanks Avenue, Winter Park, FL 32789. Disclosure of the Code’s availability shall be announced on the Trust’s website (www.timothyplan.com) and in its prospectus, semi-annual and annual reports.

V. General Prohibitions

In addition to the officers set forth hereinabove, the provisions and reporting requirements of the Rule and this Code of Ethics are applicable to those investment activities of Access Persons who are associated with the Trust and who thus may benefit from or interfere with the purchase or sale of portfolio securities by the Trust. The Rule and this Code of Ethics shall also apply to all Affiliated Persons of the Trust, the Adviser(s), SubAdviser(s) and the Underwriter (“Covered Persons”), unless specifically stated otherwise.

The Rule makes it “unlawful” for Covered Persons to engage in conduct which is deceitful, fraudulent, or manipulative, or which involves false or misleading statements, in connection with the purchase or sale of securities by the Trust. Accordingly, under the Rule and this Code of Ethics, no Covered Person shall use any information concerning the investments or investment intentions of the Trust, or his or her ability to influence such investment intentions, for personal gain or in a manner detrimental to the interests of the Trust.

In addition, no Covered Person shall, directly or indirectly in connection with the purchase or sale of a “security held or to be acquired” by the Trust:

A. employ any device, scheme or artifice to defraud the Trust; or

B. make to the Trust or an Adviser any untrue statement of material fact or omit to state to any of the foregoing a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading; or

C. engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon the Trust; or

D. engage in any manipulative practice with respect to the Trust.

This Code of Ethics, as amended, has been adopted to establish standards and procedures for the detection and prevention of activities by which Officers of the Trust, and other persons having knowledge of the investments and investment intentions of the Trust, may abuse their fiduciary duties to the Trust, the investors, or both, to deal with other types of conflict-of-interest situations, and to establish certain standards, policies, and procedures, designed specifically, but not exclusively to address the conduct of the principal executive officer, the principal financial officer, accounting officer, controller, and any other officers or persons acting in any such capacity:

i. To promote honest and ethical conduct, including the ethical handling of actual or perceived conflicts of interest between personal and professional relationships;

ii. To effect full, fair, accurate, timely, and understandable disclosures in reports and documents that a company files with, or submits to, the Securities and Exchange Commission, state securities oversight agency(ies), and in other public communications made by the Trust;

iii. To comply with applicable federal and state government laws, rules, and regulations;

iv. To provide for accountability for the policies and procedures set forth herein, and strict adherence thereto, and regulatory compliance by the principal executive officer, the principal financial officer, accounting officer or controller, and any other persons acting in any such capacity.

v. To establish accountability and encourage reporting of known or perceived transgressions of the Code.

It is “unlawful” for certain persons who have affiliations with the Trust to engage in conduct which is deceitful, fraudulent or manipulative, or which involves false or misleading statements, in connection with the purchase or sale of securities by the Trust. This Code of

Ethics is intended to establish policies and procedures designed to insure that persons subject to this Code of Ethics and the Rules do not use any information concerning the investments or investment intentions of the Trust, or his or her ability to influence such investment related information, for personal gain or in a manner detrimental to the interests of the Trust, or the investors, or both.

VI. Prohibited Transactions

A. Blackout Periods

Subject to any additional limiting requirements that may be set forth below, an Advisory Person may not effect a personal securities transaction in a “security held or to be acquired” by the Trust unless such person:

1. executes such transaction at a price equal to or less advantageous than the price obtained for such security by the Trust; and

2. reports to the Trust the information described in Paragraph VI of this Code of Ethics.

Any profits realized on personal securities transactions in violation of this Section V shall be disgorged.

B. Initial Public Offerings

An Advisory Person may not acquire any security in an initial public offering, unless such Advisory Person (1) obtains advance written clearance of such transaction by two Clearing Officers and (2) reports to the Trust the information described in Paragraph VI of this Code of Ethics.

C. Private Placements

An Advisory Person may not acquire any security in a private placement, unless such Advisory Person (1) obtains advance written clearance of such transaction by two Clearing Officers and (2) reports to the Trust the information described in Paragraph VI of this Code of Ethics.

1. When considering whether to grant approval to the Advisory Person to engage in these transactions, the Clearing Officers shall consider, among other factors, whether the investment opportunity should be reserved for the Trust, and whether the opportunity is being offered to the Advisory Person by virtue of his or her position with the Trust. If the Clearing Officers find that the investment opportunity should be reserved to the Trust or that the opportunity is being offered to the Advisory Person by virtue of his or her position with the Trust, the Clearing Officers shall refuse permission for the Advisory Person to enter into the transaction.

2. An Advisory Person who has been authorized to acquire securities in a private placement or an initial public offering shall be required to disclose that investment to the Trust and the appropriate Adviser whenever such Advisory Person participates, either directly or indirectly, in subsequent consideration of an investment in the issuer by any portfolio in the Trust complex. In the event that an Advisory Person has been given approval to acquire securities in a private placement or an initial public offering, any decision of the Trust to purchase securities of the issuer of such private placement or initial public offering shall be subject to prior review by the Trust’s independent Trustees who have no personal interest in the issuer.

D. Ban On Short-Term Trading Profits

An Advisory Person may not profit from the purchase and sale, or sale and purchase, of the same (or equivalent) securities within 60 calendar days, unless such transactions fully comply with the restrictions of Section V(A) of this Code of Ethics. Any profits realized on non-complying short-term trades shall be disgorged.

E. Gifts

Advisory Persons may not accept any gift or other thing of more than de minimis value from any person or entity that does business with or on behalf of the Trust.

F. Service as a Trustee to Other Public Companies

Advisory Persons may not serve on the board of directors of any publicly traded company, without prior authorization of a majority of the Trust’s Board of Trustees, which authorization shall be specifically based upon a determination that the board service would be consistent with the interests of the Trust and its shareholders. If and when such board service is authorized, the Advisory Person serving as a director will be isolated from other Advisory Persons who make investment decisions involving that company through “Chinese Wall” or other procedures.

VII. Advance Clearance Requirement

A. Procedures

1. From Whom Obtained: Persons who desire to enter into personal securities transactions in transactions requiring prior approval under paragraph V above, must obtain the written approval of any two Clearing Officers prior to entering into such transactions.

2. Time of Clearance: Transaction clearances must be obtained not more than three (3) days prior to the transaction. If the trade is not made within three (3) days of the date of clearance, a new clearance must be obtained.

3. Form: Persons seeking authorization to enter into transactions requiring prior clearance shall complete and sign a form approved for that purpose by the Trust, which form shall set forth the details of the proposed transaction. An example of such form is annexed hereto as Schedule A (“Clearance Forms”). Upon obtaining authorization to enter into the subject transaction, the Clearing Officers authorizing the transaction shall affix their signatures to the Clearance Form to indicate such approval.

4. Filing: Copies of all completed Clearance Forms, with all required signatures, shall be provided to the Board of Trustees, and shall retained in accordance with the record keeping requirements set forth in Section XIII of this Code of Ethics.

B. Factors Considered in Clearance of Personal Transactions

Clearing Officers may refuse to grant clearance of a personal transaction in their sole discretion without being required to specify any reason for the refusal. Generally, Clearing Officers will consider the following factors in determining whether or not to authorize a proposed transaction:

1. Whether the amount or nature of the transaction, or person entering into the transaction, is likely to affect the price or market for the Security;

2. Whether the individual making the proposed purchase or sale is likely to benefit from purchases or sales in the same or similar security being made or being considered by the Trust; and

3. Whether the security proposed to be purchased or sold is one that would qualify for purchase or sale by the Trust.

VIII. Exempt Transactions

A. Purchases, sales or other acquisitions or dispositions of Securities for an account over which the person has no direct influence or control and does not exercise indirect influence or control;

B. Purchases, sales or other acquisitions or dispositions of securities which are not eligible for purchase or sale by any portfolio of the Trust;

C. Involuntary purchases or sales;

D. Purchases which are part of an automatic dividend reinvestment plan; and

E. Purchases or other acquisitions or dispositions resulting from the exercise of rights required from an issuer as part of a pro rata distribution to all holders of a class of securities of such issuer and the sale of such rights.

IX. Reporting of Securities Transactions

A. Reporting Requirements of Access Persons

1. Reports Required: Unless specifically excepted by other provisions of this Code of Ethics, every Access Person of the Trust, Adviser, Sub-Adviser(s) and Underwriter must provide to the Administrator of this Code of Ethics and the Adviser(s) or Underwriter, as applicable, the following reports:

a. Initial Holdings Reports: Not later than ten (10) days after a person becomes an Access Person, such person shall complete, sign and deliver to the Trust, and the Adviser(s) or Underwriter, as applicable, an Initial Holdings Report, a form of which is attached to this Code of Ethics as Schedule B; except that

i. Any person who qualified as an Access Person prior to March 1, 2000 shall be exempt from filing an Initial Holdings Report.

b. Quarterly Transaction Reports: Not later than ten (10) days after the end of each calendar quarter, each Access Person shall make a written report (“Quarterly Transaction Report’), a form of which is attached to this Code of Ethics as Schedule C, to the Administrator of this Code of Ethics and the Adviser(s) or Underwriter, as applicable, which with respect to any transaction during the previous calendar quarter in a Covered Security in which the Access Person had any direct or indirect Beneficial Ownership, contains the following information:

i. The date of the transaction, the title, the interest rate and maturity date (if applicable), the number of shares and the principal amount of each Covered Security involved:

ii. The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

iii. The price of the Covered Security at which the transaction was effected;

iv. The name of the broker, dealer or bank with or through which the transaction was effected; and

v. The date that the report is submitted by the Access Person.

2. With respect to any account established by the Access Person in which any securities were held during the previous quarter for the direct or indirect benefit or the Access Person, contains the following information:

a. The name of the broker, dealer or bank with whom the Access Person established the account;

b. The date the account was established; and

c. The date that the report is submitted by the Access Person.

3. Annual Holding Reports: Not later than thirty (30) days after the end of the Trust’s fiscal year end, each Access Person shall make a written report, a form of which is attached to this Code of Ethics as Schedule D (“Annual Holdings Report”), to the Administrator of this Code of Ethics and the Adviser(s) or Underwriter, as applicable, which:

a. Sets forth the title, number of shares and principal amount of each Covered Security in which the Access Person had any direct or indirect beneficial ownership;

b. Sets forth the name of any broker, dealer or bank with whom the Access Person maintains an account in which any securities are held for the direct or indirect benefit of the Access Person;

c. Contains the date that the report is submitted by the Access Person; and

4. States that the information contained in the Annual Holdings Report is current as of a date not greater than thirty (30) days prior to the date the report was submitted.

B. Exemptions from Reporting

1. A person need not make an Initial Holdings Report with respect to transactions effected for, and Covered Securities held in, any account over which the person has no direct or indirect influence or control.

2. A Trustee of the Trust who is not an “interested person” of the Trust, as such term is defined in Section 2(a)(19) of the Act, and who would otherwise be required to make a report solely by reason of being a Trustee of the Trust, need not make:

a. An Initial Holdings Report or an Annual Holdings Report; and

b. A Quarterly Transaction Report, unless the Trustee knew, or in the ordinary course of fulfilling his or her official duties as a Trustee should have known, that during the fifteen (15) day period immediately before or after the Trustee’s transaction in a Covered Security, the Trust purchased or sold the Covered Security, or the Trust or an Adviser considered purchasing or selling the Covered Security.

3. An Access Person of the Trust’s Underwriter need not make a report to the Underwriter, if such person makes a report to the Trust and:

a. The Underwriter is not an affiliated person of the Trust or any Adviser to the Trust; and

b. The Underwriter has no officer, Trustee or general partner who serves as an officer, Trustee or general partner of the Trust or an Adviser to the Trust.

4. An Access Person of an Adviser need not make a report to the Adviser, if such person makes a report to the Trust and all of the information contained in such report would duplicate information required to be recorded under §§ 275.204-2(a)(12) or 275.204(a)(13) of the Investment Advisers Act of 1940, as amended.

5. An Access Person need not make a Quarterly Transaction Report if the Report would duplicate information contained in broker trade confirmations or account statements received by the Trust with respect to the Access Person for the applicable quarterly reporting period, but only if such broker trade confirmations or account statements contain ALL of the information required to be reported in the Quarterly Transaction Reports.

C. Responsibility to Report

The responsibility for taking the initiative to report is imposed on each individual required to make a report. Any effort by the Trust to facilitate the reporting process does not change or alter that responsibility.

D. Where to File Report

All reports must be filed with the principal executive officer, in-house counsel of the Trust, or to such person designated by the principal executive officer as Administrator of the Code.

X. Confidentiality of Trust Transactions

Until disclosed in a public report to shareholders or to the SEC in the normal course of the Trust’s business, all information concerning Securities “being considered for purchase or sale” by the Trust shall be kept confidential by all Access Persons and disclosed by them only on a “need to know” basis. It shall be the responsibility of the Administrator of this Code of Ethics to report any inadequacy found by him or her to the Board of Trustees of the Trust or any committee appointed by the Board to deal with such information.

XI. Accountability and Sanctions

Failure to report, or the failure to promptly report, a violation of this Code by any person in possession of the knowledge of a violation or who has reasonable grounds to suspect a violation has occurred, shall itself be a violation of the Code, and will result the imposition of sanctions as set forth below.

Any violation of this Code of Ethics shall be subject to the imposition of such sanctions by the Trust as may be deemed appropriate under the circumstances to achieve the purposes of the Rules and this Code of Ethics, which may include suspension or termination of employment, a letter of censure and when applicable, possible restitution of an amount equal to the difference between the price paid or received by the Trust and the more advantageous price paid or received by the offending person. Sanctions for violation of this Code of Ethics by a Trustee of the Trust will be determined by a majority vote of its independent Trustees.

XII. Administration and Construction

A. The administration of this Code of Ethics shall be the responsibility of the President of the Trust who shall serve as the “Administrator” of this Code of Ethics.

B. The duties of such Administrator shall include:

1. Continuous maintenance of a current list of the names of all Access Persons with an appropriate description of their title or employment;

2. Providing each Covered Person a copy of this Code of Ethics and informing them of their duties and obligations thereunder, and assuring that Covered Persons who are not Access Persons are familiar with applicable requirements of this Code of Ethics;

3. upervising the implementation of this Code of Ethics by the Adviser(s) and Underwriter and the enforcement of the terms hereof by the Adviser(s) and Underwriter;

4. Maintaining or supervising the maintenance of all records and reports required by this Code of Ethics;

5. Preparing listings of all transactions effected by any Access Person within fifteen (15) days of the date on which the same security was held, purchased or sold by the Trust;

6. Determining whether any particular securities transaction should be exempted pursuant to the provisions of this Code of Ethics;

7. Issuing either personally, or with the assistance of counsel as may be appropriate, an interpretation of this Code of Ethics which may appear consistent with the objectives of the Rule of this Code of Ethics;

8. Conducting of such inspections or investigations, including scrutiny of the listings referred to in the preceding subparagraph, as shall reasonably be required to detect and report, with his or her recommendations, any apparent violations of this Code of Ethics to the Board of Trustees of the Trust or any Committee appointed by them to deal with such information;

9. Submitting a quarterly report to the Trustees of the Trust containing a description of any violation and the sanction imposed; transactions which suggest a possibility of a violation, and any exemptions or waivers found appropriate by the Administrator; and any other significant information concerning the appropriateness of this Code of Ethics.

The Trust shall maintain or cause to be maintained in an easily accessible place, the following records:

a. A copy of this and any other Code of Ethics adopted pursuant to the Rule which has been in effect during the past five (5) years;

b. A record of any violation of such Codes of Ethics and of any action taken as a result of such violation;

c. A copy of each report made by the Trust within two (2) years from the end of the fiscal year of the Trust in which such report and interpretation is made or issued and for an additional three (3) years in a place which need not be easily accessible;

d. A list of all persons who are, or within the past five (5) years have been, required to make reports pursuant to the Rule and this Code of Ethics; and

e. A copy of all Initial Holdings Reports, Quarterly Transactions Reports, and Annual Holdings Reports submitted within the last five (5) years, the first two (2) years in an easily accessible place.

XIII. Amendments and Modifications

This Code of Ethics may not be amended or modified except in a written form which is specifically approved by majority vote of the Independent Trustees of the Trust. Modifications or amendments, including waivers to any provision set forth herein, that relate to the principal executive officer, the principal financial officer, accounting officer or controller and any person acting in any such capacity for the Trust,, shall be disclosed on the Timothy Plan website within five (5) days of the modification, amendment or waiver.

This Code of Ethics was first adopted by the Trust’s Board of Trustees, including a majority of the Trust’s “Independent Trustees”, at a meeting held on November 3, 2000, and amended at a meeting held on the 20th day of August, 2003, subject to and receiving final ratification at the meeting held the 21st day of November, 2003.

Witness my Signature:

Joseph Boatwright Secretary to the Trust

EX-99.CERT

I, Arthur D. Ally, certify that:

1. I have reviewed this report on Form N-CSR of the Timothy Plan.

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

Date: March 7, 2005

/s/    ARTHUR D. ALLY        

Arthur D. Ally

President

I, Arthur D. Ally, certify that:

1. I have reviewed this report on Form N-CSR of the Timothy Plan.

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

Date: March 7, 2005

/s/    ARTHUR D. ALLY        

Arthur D. Ally

Treasurer

EX-99.906CERT

This certification is provided pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, 18 U.S.C. 1350, and accompanies the report on Form N-CSR for the period ended December 31, 2004 of The Timothy Plan (the “trust”).

I Arthur D. Ally, the President of the trust, certify that:

(i) the form N-CSR fully complies with the requirements of Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934 (15 U.S.C 78m(a) or 78o(d)); and

(ii) the information contained in the Form N-CSR fairly represents, in all material respects, the financial condition and results of operations of the Issuer.

Date: March 7, 2005	/s/    ARTHUR D. ALLY
	Arthur D. Ally
	President

This certification is provided pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, 18 U.S.C. 1350, and accompanies the report on Form N-CSR for the period ended December 31, 2004 of The Timothy Plan (the “trust”).

I Arthur D. Ally, the Treasurer of the trust, certify that:

(i) the form N-CSR fully complies with the requirements of Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934 (15 U.S.C 78m(a) or 78o(d)); and

(ii) the information contained in the Form N-CSR fairly represents, in all material respects, the financial condition and results of operations of the Issuer.

Date: March 7, 2005	/s/    ARTHUR D. ALLY
	Arthur D. Ally
	Treasurer