WALKER FINANCIAL CORPORATION
                         990 Stewart Avenue, Suite 650A
                           Garden City, New York 11530
                                 (516) 832-7000


                                                               February 17, 2006


VIA  ELECTRONIC  SUBMISSION
- ---------------------------
Division  of  Corporation  Finance
Securities  and  Exchange  Commission
100  F  Street,  N.E.
Washington,  D.C.  20549

Re:     Registration  Statement  on  Form  SB-2  (the  "Company")
        Initially  Filed  January  12,  2005
        File  No.  333-130963

Ladies  and  Gentlemen:

The  Company  hereby  respectfully  requests  pursuant  to  Rule  477  under the
Securities  Act of 1933, as amended, that the Securities and Exchange Commission
(the  "Commission") consent to the withdrawal by the Company of its Registrant's
Registration  Statement  on  Form  SB-2 filed with the Commission on January 12,
2006  (File No. 333-130963)  (the "Registration Statement").  No securities were
offered  or  sold  pursuant  to  the  Registration  Statement.

The  Company  requests  this withdrawal because it has elected not to pursue the
registration  of the securities included therein at this time.  Please apply the
Company's  filing  fee  to  its  account  with  the  Commission.

Thank  you  for  your  assistance  in  this  matter.


                          WALKER FINANCIAL CORPORATION


                                   By:  /s/  Mitchell  S.  Segal
                                       -------------------------
                                             Mitchell  S.  Segal
                                       Chief  Executive  Officer