July 27, 2006


Mr. Donald A. Walker
Securities and Exchange Commission
Mail Stop 4561
Washington DC 20549



Dear Mr. Walker:

Thank you for your letter of June 23, 2006, concerning our Form 10-K filed
March 31, 2006. Below are our responses to your request for additional
information.

Form 10-K, filed March 31, 2006

Item 7. Management's Discussion and Analysis of Financial Condition of
	the Company

Provision for Loan Losses, Page 22.

1.	We note your disclosure in which you state that you will reserve 2% of
each new loan funded during 2006.  In footnote B you state that you have
projected a default rate of 7.75% of the unpaid principal balance of foreclosed
residential mortgages and contracts for deed and reserved 42% of that amount
and that you have projected a default rate of 1.55% of the remaining
outstanding principle balance of your interim mortgages and reserved 26% of
that amount.  Please tell us the following:

- -	how you determined these default rates and reserve percentages for 2005;
- -	how you determined a 2% reserve is more representative of the losses
	incurred in your portfolio during 2006; and
- -	the procedures you perform for reviewing and revising your loan loss
	reserve as of each balance sheet date to ensure your reserve is your best
	estimate of the losses incurred in your portfolio.

How you determined these default rates and reserves percentages for 2005:

UMT Response:

We track each loan we acquire separately (including loans that were securi-
tized into a pool) from the purchase date of the note. When a loan is
foreclosed, we accumulate all cash transactions relating to the property
during the liquidation process. Once the real estate is sold, we calculate
the loss on foreclosure.  This information is constantly accumulated and
provides an accurate loss rate on foreclosed properties. Maintaining this
information provides us with historical trends used as a key indicator in
determining future losses related to current loans. Approximately three
years ago, when we changed our policy relating to disposition of real
estate owned ("REO"), we narrowed our analysis to more current trends
resulting from our newly implemented rapid liquidation policy. The reserve
rates of 42% and 26%, respectively, of residential mortgages and interim
mortgages foreclosed is a three year average of losses realized from the
sale of the foreclosed properties. The foreclosure rate was also determined
on a three year average resulting in 7.75% and 1.55%, respectively, for
residential mortgages and interim mortgages. Management believes that the
past three years is a reliable basis for our 2006 reserve estimates based
on the current market environment. We will continue to use a rolling three
year average unless indicators during 2006 are substantially different from
2005 or our expectations of market trends change.


How you determined a 2% reserve is more representative of the losses incurred
in your portfolio during 2006.

UMT Response:

2% is a product of the percentages above for foreclosure and loss rates.  The
actual amount reserved quarterly is dependent on our portfolio mix and based
on a rolling three year average of actual experience for foreclosures and
losses incurred and current market trends that are evaluated by management to
ensure there are no known trends that should impact our reserves recorded.


The procedures you perform for reviewing and revising your loan loss reserve
as of each balance sheet date to ensure your reserve is your best estimate of
the losses incurred in your portfolio

UMT Response:

The actual amount reserved quarterly is dependent on our portfolio mix and
based on a rolling three year average of actual experience for foreclosures
and losses incurred and current market trends that are evaluated by management
to ensure there are no known trends that should impact our reserves recorded.


Interest Income Accrual, Page 43

Please tell us the specific methods you use to accrue interest income for both
your recourse and non-recourse loans.  For instance, if you use the interest
method in accordance with SFAS 91, please tell us and revise your future
filing to specifically disclose this fact.

UMT Response:

We do not accrue or collect non-refundable fees, nor do we have direct external
or internal costs associated with entering into mortgages, and hence no such
amounts are capitalized and amortized using the interest method prescribed by
SFAS 91.


Sincerely,


/s/Christine Griffin
Christine Griffin
President