Via Facsimile and U.S. Mail
Mail Stop 6010


July 21, 2005


Mr. William R. Schlueter
Senior Vice President and Chief Financial Officer
Security Capital Corporation
Eight Greenwich Office Park
Greenwich, CT 06831

Re:	Security Capital Corporation
	Form 10-K for Fiscal Year Ended December 31, 2004
	Filed June 28, 2005
	File No.  001-07921

Dear Mr. Schlueter:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  In our comments, we ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may 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 10-K for the fiscal year ended December 31, 2004

Notes to Consolidated Financial Statements

Note 4.  Significant Accounting Policies

Assignment Development Costs, page 39

1. We note from your disclosure that you are capitalizing
assignment
development costs that you have incurred on behalf of a franchisee
and recognizing the expense only at the point in time that a
franchisee purchases the property (i.e. when you also recognize
revenue).  Please tell us how your accounting policy for
capitalizing
these costs and recording revenue complies with US GAAP.  In your
response, cite the specific authoritative guidance used and, for
the
costs capitalized, describe more specifically the types of costs
including whether or not they are incurred to independent third
parties.

2. In addition it is unclear why you would record an allowance for
uncollectible development costs.  It would seem that you should
record a receivable related to the reimbursement of the costs
incurred from the franchisee as that is where the credit risk
resides.  Please explain to us why you have not recorded a
franchisee
receivable related to the reimbursement of expenses.

Note 6.  Goodwill and Identified Intangible Assets, page 43

3. We note an increase in the goodwill balance due to a purchase
price adjustment of $364 thousand related to the 2002 acquisition
of
Barron Risk Management Services.  Please tell us how recording
this
adjustment to goodwill complies with paragraphs 40-41 of SFAS 141.


*    *    *    *

      Please provide us the information requested within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter with your supplemental responses that keys
your responses to our comments.  Detailed cover letters greatly
facilitate our review.  Please file your letter on EDGAR under the
form type label CORRSEP.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 filing;
* staff comments or changes to disclosure in response to staff
comments 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.

      You may contact Dana Hartz, Staff Accountant, at (202) 551-
3648
or Joseph Roesler, Review Accountant, at (202) 551-3628 if you
have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,



								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
??

??

??

??

Mr. William R. Schlueter
Security Capital Corporation
July 21, 2005
Page 3