August 30, 2005
Mail Stop 4561

By: U.S. mail and facsimile to (505) 275-9620

Mr. Norman R. Corzine
Chief Executive Officer and Chairman
Access Anytime Bancorp, Inc.
5210 Eubank, NE
Albuquerque, NM 87111

Re:	Access Anytime Bancorp, Inc.
      Form 10-KSB for Fiscal Year Ended December 31, 2004
	File No.  000-28894

Dear Mr. Corzine:

      We have limited our review of your filing to those issues we
have addressed in our comments. Where indicated, please provide us
with the supplemental documentation we requested in response to
these
comments.  Please be as detailed as necessary in your explanation.
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 6

Management`s Discussion and Analysis or Plan of Operations

Asset Quality

Allowance for Loan Losses, page 16

1. Please tell us how you considered paragraph 37.b of SFAS No.
141
when you recorded the "acquired allowance" of $170,000 in 2004
shown
in your analysis of the allowance for loan losses.  Your
discussion
should include but not be limited to the process used in
determining
the present value of the acquired loans, if you recorded the loans
at
their fair market value at the date of the acquisition and which
loan
valuation methodology is reflected in your purchase price
calculation.

Item 7

Consolidated Financial Statements

Consolidated Statements of Operations, page F-4

2. We note non-interest income for gains on sales of loans held-
for-
sale of $1.1 million represented 34% of total non-interest income
for
your year-ended December 31, 2004.  Please tell us how you
considered
this income sources when determining your operating segments.
Please
provide details supporting your current accounting, including
relevant qualitative criteria and quantitative threshold tests for
the periods presented or revise your financial statements if
necessary.  Please refer to paragraphs 10-24 of SFAS 131.

3. Please tell us the type, source and amount of income included
in
the other income balance of $1.4 million as of December 31, 2004.
Please review the guidance in Item 5-03.b.7 of Regulation S-X and
SAB
Topic 1.M.1.  Discuss how and why you believe you have fully
complied
with the guidance and continue to believe your presentation is
appropriate.

* * * * *

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter 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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided 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 Paula Smith (Staff Accountant) at (202) 551-
3696
or me at (202) 551-3492 if you have any questions regarding
comments
on the financial statements and related matters.


Sincerely,



							John P. Nolan
							Accounting Branch Chief
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Mr. Norman R. Corzine, Chief Executive Officer
Access Anytime Bancorp, Inc.
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