[letterhead of Luse Gorman Pomerenk & Schick]
(202) 274-2007 nquint@luselaw.com
March 9, 2005
Via EDGAR
Mr. Paul Cline
Senior Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Great Pee Dee Bancorp, Inc.
Form 10-KSB for the year ended June 30, 2004 Form
10-QSB for the period ended December 31, 2004
Commission File No. 000-23521
-----------------------------
Dear Mr. Cline:
On behalf of Great Pee Dee Bancorp, Inc. (the "Company"), we are
writing in response to the letter from the Securities and Exchange Commission
(the "Commission") dated February 24, 2005. Set forth below are the Company's
responses to the letter from the Commission.
1. The Company will revise its future filings in response to the comment.
Please note that the Company does not retain servicing on loans sold,
and does not securitize loans. Accordingly, the Company believes that
the disclosures of paragraphs 10.35 and 10.36 of the AICPA Audit Guide
for Depository and Lending Institutions are not applicable to the
Company's filings with the Commission, but the Company will clarify its
operations with respect to these activities in future filings.
2. The Company will revise its future filings in response to the comment.
3. The Company will revise its future filings in response to the comment.
4. The Company will revise its future filings in response to the comment.
5. The Company will revise its future filings in response to the comment.
6. The Company will revise its future filings in response to the comment.
Mr. Paul Cline
March 9, 2005
Page 2
7. The Company will revise its future filings in response to the comment.
8. The Company will revise its future filings in response to the comment.
9. The Company will revise its future filings in response to the comment.
10. The Company will revise its future filings in response to the comment.
11. The Company will revise its future filings in response to the comment.
12. The Company will revise its future filings in response to the comment.
13. The Company will revise its future filings in response to the comment.
14. The Company will revise its future filings in response to the comment.
15. The Company will revise its future filings in response to the comment.
16. The Company will revise its future filings in response to the comment.
17. The Company will revise its future filings in response to the comment.
In connection with these responses, and as requested by the Commission,
the Company acknowledges that:
o the Company is responsible for the adequacy and accuracy of
the disclosure in the filing;
o 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
o 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.
* * * *
Mr. Paul Cline
March 9, 2005
Page 2
We trust that the above information is responsive to the staff's
comments. Please direct any additional comments or questions to the undersigned
at (202) 274-2007.
Sincerely,
/s/ Ned Quint
Ned Quint
cc: Michael Volley, Securities and Exchange Commission
Herbert W. Watts, President and Chief Executive Officer
John J. Gorman, Esq.