Mail Stop 0408

						July 14, 2005


By U.S. Mail and Facsimile to (704) 894-9759

David R. Koran
President, Chief Executive Officer and Chief Financial Officer
Capital Resource Funding, Inc.
2212 Lantern Way Circle
Cornelius, North Carolina 28031

Re:	Capital Resource Funding, Inc.
	Amendment No. 6 to Registration Statement on Form SB-2
      Filed June 30, 2005
	File No. 333-118259

Dear Mr. Koran:

      We have reviewed your amendment and have the following
comments.  Where indicated, we think you should revise your
document
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 information so we may better understand your disclosure.
After
reviewing this information, we may or may not raise additional
comments.

      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 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.

Cover Page

1. Revise the cover page to include the information called for by
Item 501(a)(9)(iii) and (iv).

Risk Factors, page 9

2. Add a risk factor that discusses the risk that since you will
not
have an escrow account, the company will have access to an
investor`s
funds immediately and that a shareholder may be one of only a few
investors in a company which may continue to need capital to begin
and expand its operations.

Plan of Distribution, page 18

3. Revise this section to disclose the information you discussed
in
your response to prior comment 6.


*      *      *

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      You may contact Angela Jackson, Staff Accountant, at (202)
551-
3426 or Kevin Vaughn, Accounting Branch Chief, (202) 551-3494 if
you
have questions regarding comments on the financial statements and
related matters.  Please contact Gregory Dundas at (202) 551-3436
or
me at (202) 551-3419 with any other questions.

						Sincerely,



Christian Windsor
Special Counsel

cc:	Harold Martin, Esq. (by fax)


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David R. Koran
Capital Resource Funding, Inc.
July 14, 2005
Page 2