4 November 2005

Mr. Thomas Flinn
Division of Corporate Finance
Securities and Exchange Commission

Dear Mr. Flinn:

I have reviewed your comments of November 3, 2005 concerning
past Central American Equities filings and have attached my
responses.  Please let me know if you need additional information.

Sincerely,




s/ Michael Caggiano

Michael Caggiano
President and CEO
Central American Equities



Form 10-KSB for the Fiscal Year Ended December 31, 2004.

Item 8A Controls and Procedures.

Items 307 and 308 (c) refer to our internal controls
 for financial reporting.  We are a small company and
 I (as CEO) work closely with our management and
particularly our accounting department to make
certain that reporting procedures are checked and
enforced.  I can place the following formal explanation
in an amended 10K for December 31, 2004:

"The Company maintains disclosure controls and procedures
that are designed to ensure that information required to
be disclosed in the Company's Securities Exchange Act
reports is recorded, processed, summarized and reported
within the time periods specified in the Securities and
Exchange Commission's rules and forms, and that such
information is accumulated and communicated to the Company's
management, including its Chief Executive Officer and Chief
Financial Officer, as appropriate, to allow timely decisions
regarding required disclosure.

Under the supervision and with the participation of our management
including the Chief Executive Officer and Chief Financial Office we
evaluated the effectiveness of the design and operation of the
Company's disclosure controls and procedures.  Based upon that
evaluation, the Chief Executive Officer and Chief Financial Officer
concluded that the Company's disclosure controls and procedures were
effective.  There have been no significant changes in the Company's
internal controls or in other factors that could significantly affect
these controls, and no corrective actions taken with regard to significant
deficiencies or material weaknesses in such controls, subsequent
to the date of our most recent evaluation of internal controls."


Form 10-QSB for the Quarterly Periods Ended March 31, 2005 and
June 30, 2005

Item 3 Controls and Procedures.

I did not provide the disclosures required by Items 307
and 308(c) because I was unaware of the requirement to
provide them.  However I believe that the company does
maintain adequate disclosure controls and procedures.
Every three-month period I work closely with my management
to review those procedures as we assemble the financial
information necessary to meet the requirements of 10Q and
10K reports.  However, I can place the following formal
explanation in the 10Q that I will shortly file for the
period ending September 30, 2005:

"The Company maintains disclosure controls and procedures
that are designed to ensure that information required to be
disclosed in the Company's Securities Exchange Act reports
is recorded, processed, summarized and reported within the
time periods specified in the Securities and Exchange Commission's
rules and forms, and that such information is accumulated and
communicated to the Company's management, including its Chief
Executive Officer and Chief Financial Officer, to allow timely
decisions regarding required disclosure.  During the 90-day
period prior to the date of this report, an evaluation was
performed under the supervision and with the participation of
the Company's management, including the Chief Executive Officer
and Chief Financial Officer, of the effectiveness of the design
and operation of the Company's disclosure controls and procedures.
Based upon that evaluation, the Chief Executive Officer and the Chief
Financial Officer concluded that the Company's disclosure
controls and procedures were effective.  There have been
no significant changes in the Company's internal controls
or in other factors that could significantly affect these
controls, and no corrective actions taken with regard to
significant deficiencies or material weaknesses in such
controls, subsequent to the date of our most recent evaluation
of internal controls."