Mail Stop 4-9


								April 18, 2005


By mail and fax to:

Byron Webb
President
Webb Mortgage Depot, Inc.
155 Wilson Lake Road
Mooresville, NC 28117

Re: Webb Mortgage Depot, Inc

      Form 8-K filed April 14, 2005
      File No. 333-72376


Dear Mr. Webb,

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your documents in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


Form 8-K

1. Amend Item 4(a) of Form 8-K to clearly state the period through
which there were no disagreements with the predecessor auditors.
Include the interim period from the date of the last audited
financial statements to April 8, 2005, the date of resignation in
your disclosure.  See Item 304(a)(1)(IV) of Regulation S-B.
Include
a letter from the former accountants addressing the revised
disclosures in the amendment.

2. In a supplemental response to us, please confirm that your new
accountants meet the independence requirements of Article 2 of
Regulation S-X.

File an amendment under cover of Form 8-K/A and include the ITEM
4.01
designation, including the letter from the former accountant filed
as
an Exhibit 16.  Please note that your former accountants should
make
it clear within the Exhibit 16 letter that it is in reference to
your
amended Form 8-K.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require.  Since
the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.


Please provide the supplemental information requested above within
10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested should be filed as promptly as possible and
should be reviewed by the former accountants.  The letter required
by
Exhibit 16 should cover any revised disclosures.

Any questions regarding the above should be directed to me at
(202)
824-5356.

						Sincerely,



						Robert Telewicz
						Staff Accountant


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Webb Mortgage Depot, Inc.
April 18, 2005


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