September 21, 2005

Kate Tillian
Assistant Chief Accountant
Securities and Exchange Commission
Washington, D.C. 20549

Re: University Bancorp, Inc.
    Form 10-K for the year ended December 31, 2004
    Forms 10-Q for the periods ended March 31, and June 30, 2005
    File No. 000-16023

Dear Ms. Tillian:

Pursuant to your request, the following is our formal response to the issues
noted in your letter dated August 19, 2005.

Report of Independent Registered Public Accounting Firm
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   o     The report of other auditors in Exhibit 23.1 was modified to express
         an opinion for the three years ended December 31, 2004.
   o     Richard C. Woodbury, CPA is registered with the PCAOB.  He is listed
         as a registrant under the name of "Richard C. Woodbury PC CPA."
   o     The report of Richard C. Woodbury, CPA was modified to conform to the
         PCAOB standard.

Item 9A. Controls and Procedures
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   o     The conclusion regarding the disclosure controls and procedures was
         modified to clearly indicate that they are effective. This change was
         made for the Form 10-K and the two Form 10-Qs noted above.
   o     The definition of disclosure controls and procedures was modified to
         conform to the definition set forth in Rule 13a-15e. This change was
         made for the Form 10-K and the two Form 10-Qs noted above.

The amended Form 10-K and Form 10-Qs for the periods indicated above will be
submitted to the SEC.

Sincerely,

/s/Nicholas K.  Fortson
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Nicholas K. Fortson
Chief Financial Officer
University Bancorp, Inc.