ANDREWS KURTH LLP


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                                                                February 5, 2007



United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20539
Attention:  Kate McHale, Mail Stop 4561

         Re:      Terra Nova Financial Group, Inc. (formerly known as)
                  Rush Financial Technologies, Inc. (the "Company")
                  Registration Statement on Form SB-2
                  Filed July 31, 2006
                  File No. 333-136194

Dear Ms. McHale:

         We are filing today the revised Form SB-2 for the Company and are
responding to each of your comments in your letter dated January 16, 2007 in the
Form SB-2 and as discussed below.

         We are also sending to you a courtesy copy of the Form SB-2, marked to
show changes from the prior filing. Page references described in this letter
pertain to the clean courtesy copy and not necessarily to either the marked
version of the Edgar filing. Each of your comments is re-written below followed
by the Company's response.

General
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1.       Please make sure text remains a consistent size throughout your
         prospectus; it appears somewhat smaller on page 5.

The Company will make every effort to insure the proper formatting of all
documents.



2.       We note your responses to our previous comment 3; however, we are
         unable to locate a recent developments section which discusses material
         events that occurred after September 30.

See Note 19 page F-65.

The Acquisition, page 3
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3.       We note your response to our prior comment 5; however, it is unclear
         from your disclosure how you calculated the number of shares upon
         conversion. It seems that 233,345,000 shares have been issued as a
         result of the Series E conversion and 116,655,000 shares of common
         stock are associated with the warrants. Please advise or revise.

The number of common stock which resulted from the Series E conversion is
233,333,347 and 116,666,673 shares of common stock are associated with the
warrants. Each Series E Preferred Stock converted to 6,667.67 shares of common
stock. The slight difference is due to rounding. Page 3 has been changed

Selected Financial Information, page 6
- --------------------------------------

4.       We note your response to our prior comment 7; however, the Loss
         attributable to common stockholders" and "Net loss per common share"
         remain different from the numbers presented on page F-52 of the
         financial statements. Therefore, we reissue our prior comment 7.

We believe they are consistent.

Page 6 reflects Net loss attributable to common shareholders as (26,642,800) and
(2,147,478) for nine months ended 9/30/06 and 2005 respectively. Page 6 further
reflects the years ended 12/31/05 and 12/31/04. For the nine month periods
ending 9/30/06 and 9/30/05, Page F-52 reflects Net loss attributable to common
shareholders as (26,642,800) and (2,147,478) respectively. Page F-52 also
reflects the three month period ending 9/30/06 and 9/30/05.

Please note that Page 6 also contains unaudited pro form earnings per share
data.

Risk Factors
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Our Past Due Obligations....page 13
- -----------------------------------

5.       We note your response to our prior comment 13; however, please
         elaborate to discuss the consequences and risks to shareholders if you
         enter into involuntary bankruptcy proceeding as a result of these
         unpaid vendors.



The Past Due Obligations risk has been amended to include the risk of
involuntary bankruptcy.

Plan of Distribution, page 25
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6.       Revise to disclose the applicability of and restrictions imposed on the
         sellers by Regulation M and the Penny Stock Rules.

The following language has been added to "Plan of Distribution" to address the
issue:

Regulation M promulgated by the SEC prohibits the selling shareholders and their
affiliates from, directly or indirectly, bidding for, purchasing, or attempting
to induce any person to bid for or purchase, the Company's common stock at any
time during the distribution of the stock covered by this Prospectus.

In addition, our stock is subject to the SEC's penny stock regulations. The
penny stock rules require a broker-dealer, prior to a transaction in a penny
stock not otherwise exempt from the rules, to deliver a risk disclosure document
that provides information about penny stocks and the risks in the penny stock
market. The broker-dealer also must provide the customer with current bid and
offer quotations for the penny stock, the compensation of the broker-dealer and
its salesperson in the transaction, and monthly account statements showing the
market value of each penny stock held in the customer's account. In addition,
the penny stock rules generally require that prior to a transaction in a penny
stock, the broker-dealer make a special written determination that the penny
stock is a suitable investment for the purchaser and receive the purchaser's
written agreement to the transaction.

Back Page of Prospectus
- -----------------------
Table of Contents
- -----------------

7.       Revise to include a line item for at least each applicable required
         item in Form SB-2.

The Table of Contents has been revised.

Legality Opinion, Exhibit 5.1
- -----------------------------

8.       We note the revision made to your legality opinion pursuant to our
         previous comment 16; however, in revisiting this issue, the staff has
         determined that it is inappropriate to limit reliance on your opinion.
         You may limit your opinion as to scope but not as to person who may
         rely on it. Accordingly, please revise the first full paragraph on page
         2 of your opinion to eliminate the second sentence in its entirety.

Revised as noted.





Please contact the undersigned with your further questions and comments.


                                           Sincerely,

                                           /s/ Ronald L. Brown

                                           Ronald L. Brown