ATM  FINANCIAL  CORP.                               2533  North  Carson  Street
                                                    Carson  City,  Nevada  89706
                                                    tel:  (775)  841-7018
                                                    fax:  (775)  883-2384


                                                                December 4, 2005


VIA  EDGAR

Yolanda  Crittendon
Staff  Accountant
Securities  and  Exchange  Commission
Division  of  Corporation  Finance
450  Fifth  Street,  N.W.
Washington,  D.C.  20549

Re:  ATM  FINANCIAL  CORP.
     FORM  10-KSB  FOR  THE  YEAR  ENDED  DECEMBER  31,  2004
     FORM  10-QSB FOR THE QUARTERS ENDED MARCH 31, 2005, JUNE 30, 2005,
     AND SEPTEMBER 30,  2005
     FILE  NO.  333-103647


Dear  Ms.  Crittendon:

In  connection  with  the  above-captioned  filings our responses to the Staff's
comments  are set forth below in the following paragraphs numbered to correspond
to  the  comments  in  the  Staff's  letter.


FORM  10-QSB  FOR  THE  PERIOD  ENDING  MARCH  31,  2005

ITEM  1  -  FINANCIAL  STATEMENTS

STATEMENT  OF  OPERATIONS

1.     In  response  to  the Staff's comment, we advise that the debt settlement
was  the result of dispute over fees charged by our respective legal counsel and
accountants that ultimately culminated in negotiated settlements.  Statements of
account  were recorded as operational expenses as billed.  Disputed amounts were
not  paid.  As  a  result  of  the negotiated settlements, disputed amounts were
written  off  by the respective service providers.  We therefore recorded a debt
settlement  gain  in  our  financial  statements with no change in cash outflow.


FORM  10-QSB FOR THE QUARTERS ENDED MARCH 31, 2005, JUNE 30, 2005,
AND SEPTEMBER 30,  2005

ITEM  3  -  CONTROLS  AND  PROCEDURES

2.     In  response  to  the Staff's comment, we confirm that we will revise our
disclosure  in  future  filings.

3.     In  response  to  the  Staff's comment, we confirm that our officers have
concluded  that  our  disclosure controls and procedures are effective as at the
end  of the period covered by the quarterly reports.  We further confirm that we
will  revise our disclosure in future filings to clearly set out the conclusions
reached  by  our officers as to the effectiveness of our disclosure controls and
procedures.

Should  the  Staff  need additional information or have questions concerning our
response,  please  do  not  hesitate  to  contact  us.


Yours  very  truly,



/s/ Arthur Davis
Arthur  Davis
President  &  CEO