Room 4561

								March 6, 2006

Harold F. Schultz
President and Chief Executive Officer
Moneyflow Systems International Inc.
Suite N, 7003 Fifth Street SE
Calgary, Alberta T2H 2G2
Canada

Re:	Moneyflow Systems International Inc.
Form 8-K filed on March 3, 2006
      File 3-74928

Dear Mr. Schultz:

      We have reviewed the above referenced filing and have the
following comment.  Where indicated, we think you should revise
your
filing in response to this comment.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
revisions unnecessary.  Please be as detailed as necessary in your
explanation.

	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.

Form 8-K filed on March 3, 2006
1. Revise the disclosure regarding disagreements with your former
accountants to specifically include the subsequent interim period
through the date the former accountants declined to stand for re-
election.

      As appropriate, please amend your filing and respond to this
comment within five business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.
Please
understand that we may have additional comments after reviewing
any
amendments and 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 comment, 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 comment on your filings.

	You may contact Tamara Tangen at (202) 551-3443 or me at
(202)
551-3488 with any questions.

      Sincerely,



      Stephen G. Krikorian
      Branch Chief - Accounting


Harold F. Schultz
Moneyflow Systems International Inc.
March 6, 2006
Page 2