Mail Stop 0408

      October 14, 2005


By U.S. Mail and Facsimile to (404) 806-3801

Vance R. Martin
President
The Money Tree Inc.
114 South Broad Street
Bainbridge, Georgia 39817

Re:	The Money Tree Inc.
	Amendment No. 4 to Registration Statement on Form S-1
      Filed September 21, 2005
	File No. 333-122531

	Amendment No. 4 to Registration Statement on Form S-1
      Filed September 21, 2005
	Form No. 333-122533

Dear Mr. Martin:

      This letter supplements our comment letter dated October 7,
2005. 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.

Prospectus Summary, page 6

1. Please include a recent developments section in the forepart of
your document discussing the impact of the recent hurricanes in
the
Gulf of Mexico region on the company.

Risk Factors, page 11

2. Please include a risk factor discussing the impact of the
recent
hurricanes on the company.

Management`s Discussion and Analysis, page 20

3. Please include a recent developments section detailing
significant
changes or events which have impacted the company`s results of
operations, financial condition and liquidity.

*      *      *

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 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 direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

	You may contact Benjamin Phippen, Staff Accountant, at (202)
551-3697 or Joyce Sweeney, Accounting Branch Chief at (202) 551-
3449
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) 551-3698 with any other questions.

								Sincerely,



Mark Webb
Legal Branch Chief

cc:	Michael K. Rafter, Esq.
	Schiff Hardin LLP
	1230 Peachtree Street, 18th  Floor
	Atlanta, Georgia 30309

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Vance R. Martin
The Money Tree
October 14, 2005
Page 3