EXHIBIT 11

                                  [LETTERHEAD]

                                 June   , 1999

SFG Mortgage and Investment Company, Inc.
923 Powell Avenue SW
Renton, WA 98057
Dear Sirs:

    The undersigned serves as your counsel in connection with the filing of the
Registration Statement on Form SB-2 under the Securities Act of 1933, as
amended, filed by you with the United States Securities and Exchange Commission
on January 29, 1999. Pursuant to such Registration Statement, you propose to
register $25,000,000 of Investment Debentures, Series I of SFG Mortgage and
Investment Company, Inc. (the 'Company') to be offered and sold to the investing
public.

    We have reviewed the Articles of Incorporation, Bylaws and Minutes of the
meetings and records of action of the Board of Directors of the Company and such
other documents and representations as we deemed necessary.

    Based upon the foregoing, we are of the opinion that:

    1.  The Company is a validly existing corporation in good standing under the
laws of the State of Washington; and

    2.  Upon issuance of the aforementioned investment debentures in conformity
with the Registration Statement, such debentures will be validly issued and
outstanding and the repayment of all amounts due under such debentures will be a
legal and binding obligation upon the Company.

                                          LAW OFFICES OF JACK G. ORR, P.S.

JGO/st