American Republic Realty Fund I
2800 N Dallas Pkwy #100
Plano, TX  75093

Cicely Luckey
Branch Chief
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C. 20549

Re:	American Republic Realty Fund I
Schedule 14D-9 filed July 8, 2005
SEC File No. 0-11578

Dear Ms. Luckey,

The following information is intended to provide a response to comments of
the Staff of the Securities and Exchange Commission rendered by letter dated
June 23, 2005, with respect to Form 10-K Annual Report to the Securities and
Exchange Commission for the fiscal year ended December 31, 2004 of
American Republic Realty Fund I.  For convenience, each comment of the
Staff is restated below, with our response noted immediately following the
comment.

Financial Statements and Notes

Comment/Observation No. 1.  Advise us how your presentation of
financial statements on a combined basis complies with Rules 3-01 and 3-02
of Regulation S-X which requires presentation of primary financial statements
on a consolidated basis.

Response to Comment/Observation No. 1.  The presentation of the
financial statements of American Republic Realty Fund I ("the Company") is
on a consolidated basis.  The terminology used throughout the financial
statements, but most specifically in the "Summary of Significant Accounting
Policies" footnote, indicating that the financial statements are presented on a
combined basis is incorrect.  In 1992 as a result of the requirements of a
refinancing of one of the mortgage notes, a new partnership was formed, with
the Company as a 99% owner, to hold one of the apartment properties.  At the
time of the formation of the partnership in 1992, the "combination"
terminology was used in the financial statements instead of the more
appropriate "consolidation" for the method of presentation of the two
partnerships.  The financial statements of the Company have been prepared on
a consolidated basis since then, but have been incorrectly termed as
"combined".  The Company will correct the terminology in all future filings to
properly reflect the nature of the consolidation.

In addition, while researching the above issue the Company discovered that
upon the formation of the new partnership there was a 1% partner that should
represent a minority interest.  The footnote in previous filings has
incorrectly stated "The financial statements include the accounts of the
Partnership and a wholly owned entity."  This should have read "The financial
statements include the accounts of the Partnership and a 99% owned subsidiary."
The Company has considered materiality as discussed in Staff Accounting
Bulletin 99 and reviewed the amounts that would have been assigned to the
minority interest each year in a quantitative and qualitative nature.  The
Company has concluded that those amounts would not be material to any of the
years individually and would not require any restatements of any previously
filed financial statements.  Also, the Company, has concluded that the
cumulative total of these amounts would not be material to the balance sheet
and sees no need to reclass the amount from partners' capital to a minority
interest.  The Company, on a go forward basis will evaluate the amounts
needed to be included in the minority interest piece and record them as
deemed necessary.

The partnership acknowledges that:
	The partnership is responsible for the adequacy and accuracy of the
disclosure in the filings;
	Staff comments or changes to disclosure in response to staff comments
in the filing reviewed by the staff do not foreclose the Commission
from taking any action with respect to the filing;
	The partnership may not assert staff comments as a defense in any
proceedings initiated by the Commission or any person under the
federal securities laws of the United States.

If you should have any questions or comments, please contact the undersigned
at 972 836 8010.

Thank you for your assistance.

Sincerely,


Paul Ivanoff
Treasurer Univesco, Inc.
Management Agent