Walker Financial Corporation
990 Stewart Avenue, Suite 60A
Garden City, New York 11530
(516) 832-7000
December 7, 2005
VIA FACSIMILE (202-772-9203) AND EDGAR
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Derek Swanson, Esq.
Re: Walker Financial Corporation
Registration Statement on Form SB-2
File No. 333-122776
Ladies and Gentlemen:
Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), Walker Financial Corporation
(the "Company") respectfully requests that the effective date of the
registration statement referred to above be accelerated so that it will become
effective at 10.00 a.m., Eastern Time, on Friday, December 9, 2005, or as soon
thereafter as possible.
We hereby acknowledge the following:
o that should the Commission or the staff, acting pursuant to
delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the
filing;
o the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and
o the Company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.
Walker Financial Corporation
By: /s/ Mitchell Segal
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Name: Mitchell Segal
Title: President and Chief Executive Officer