January 6,
2006


Mail Stop 4561

Peter Russo
111 North Branch Street
Sellersville, PA  18960

      Re:	Delta Mutual, Inc.
		Form 10-KSB for the year ended December 31, 2004
	Forms 10-QSB for the quarters ended March 31, 2005 and June
30,
2005
		File No. 000-30563

Dear Mr. Russo:

      We have reviewed your response letter dated September 16,
2005
and have the following additional comments.

Form 10-KSB

Balance Sheet, page F-2

1. We have read and considered your response to comment one.  We
noted that the pre-acquisition costs of $170K is in connection
with
the acquisition and proposed development of approximately 270 low
income homes that are designated as Section 124 eligible in the
city
of Aguadilla, Puerto Rico.  In capitalizing these pre-acquisition
costs, tell us how you determined that the acquisition and
development of the property was probable given the fact that on
June
28, 2005 and September 2005 the Planning Board of Puerto Rico did
not
approve the Section 124 project in Aguadilla, Puerto Rico.  Refer
to
SFAS 67 paragraph 4 and 5.

Note 1 - Description of Business and Summary of Significant
Accounting Policies

Evaluation of Long-Lived Assets, page F-11

2. We have read and considered your response to comment two.  You
indicate in your letter that you test long-lived assets for
impairment based on the estimated undiscounted cash flows.
However,
note1 indicates that an impairment loss would be charged if the
carrying value of the long-lived assets exceeds the present value
of
the related estimated future cash flows.  In future filings,
please
indicate that, as we assume, you test long-lived assets for
impairment based on the undiscounted cash flows as oppose to the
present value.  Advise us if you plan to expand your disclosure in
future filings.


Note 5 Investment In Joint Ventures, pages F-18 - F-19

3. We have read and considered your response to comment three.
Please
explain to us how Delta-Envirotech, Inc. meets the definition of
VIE
in paragraph 5 of FIN(R). In addition, please explain to us how
you
concluded you were the primary beneficiary of this entity in
accordance with paragraph 14.

Note 6 - Convertible Debt, pages F-19 - F-20

4. We have read and considered your response to comment four.  We
noted that you determined the beneficial conversion feature to be
the
fair value of the convertible debt.  Tell us how you considered
EITF
00-27 as it stipulates that the EITF 98-5 model should be applied
to
the amount allocated to the convertible instrument to determine if
the embedded conversion option has an intrinsic value.  EITF 98-5
defines intrinsic value as the difference between the conversion
price and the fair value of the stock into which the security is
convertible, multiplied by the number of shares into which the
security is convertible.  Also, disclose the amortization period
of
the intrinsic value of the beneficial conversion feature and refer
us
to the GAAP literature that supports this policy.

5. Please provide a detailed analysis of how you evaluated the
embedded conversion option of the 6% Convertible Note, related
warrants and additional investment rights under EITF 00-19.
6. Please explain to us and quantify the effect that would result
from your revision of your financial statements and why you have
not
filed a Form 8-K regarding this error.
7. In light of the above error, please tell us if your certifying
officers have reconsidered its effect on the adequacy of your
disclosure controls and procedures as of the end of the periods
covered by your Forms 10-QSB Form 10-KSB for the periods affected
by
the above transactions.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your responses to our
comments.


      You may contact Yolanda Crittendon, Staff Accountant, at
(202)
551-3472 or the undersigned at (202) 551-3414 if you have
questions.




							Sincerely,



            Jorge Bonilla
      Senior Staff Accountant




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Peter Russo
Delta Mutual, Inc.
January 6, 2006
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