June 7, 2005

Mail Stop 0408

By U.S. Mail and Facsimile to (303) 672-0101

Jeffrey D. Rudolph
Chief Executive Officer
Entrust Financial Services, Inc.
6795 E. Tennessee Avenue, 5th Floor
Denver, Colorado 80224

Re:	Entrust Financial Services, Inc.
	Schedule 14A
      Filed May 23, 2005
	File No. 0-23965

Dear Mr. Rudolph:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. Please provide the financial information required under Item
14(c)(1) of Schedule 14A.  Refer to Question 6 under section H in
the
third supplement (July 2001) to the Telephone Interpretations
Manual.

2. Please provide a description of the securities for which
authorization is being sought.  Refer to Item 11 of Schedule 14A.

3. Please disclose the financial information required under Item
13(a) of Schedule 14A.

4. We note that you use the term "Summary Term Sheet" for a 12-
page Q
& A.  Please revise to include the type of summary term sheet
contemplated by Item 1001 of Regulation M-A and Item 14(b)(1) of
Schedule 14A, namely a brief description in bullet-point format of
the most material terms of the proposed transaction.

5. Please include the Selected financial data required under Item
14(b)(8) of Schedule 14A.

Summary Term Sheet - page 3

6. Revise the discussions on pages 9 and 23 of the officers` and
directors` interests in the transactions to reconcile and update.
Also, please state that these interests are "financial"

Proposal 2 - Approval of the Entrust Financial Stock Sale - page
37

7. Please provide a fuller disclosure of the nature of the
discussions that took place between March 28 and April 7, 2005.


*      *      *
Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a state from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      Please contact Gregory Dundas at (202) 551-3436 or me at
(202)
551-3448 with any other questions.

						Sincerely,


Jessica Livingston
Senior Counsel

cc:	 Paul Koenig, Esq.




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Jeffrey D. Rudolph
Entrust Financial Services, Inc.
June 7, 2005
Page 3