Via Facsimile and U.S. Mail
Mail Stop 6010


August 25, 2005

Mr. Barry B. Goldstein
President and Chief Executive Officer
1158 Broadway
Hewlett, NY 11557


Re:	DCAP Group, Inc.
	Form 10-K for fiscal year ended
	December 31, 2004
	Filed March 31, 2005
	File No. 000-01665


Dear Mr. Goldstein:

      We have limited our review of your filing to those issues we
have addressed in our comments.  In our comments, we ask you to
provide us with information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
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.


Form 10-KSB for the fiscal year ended December 31, 2004

Item 6.  Management`s Discussion and Analysis or Plan of
Operation,
page 13

Critical Accounting Policies, page 14

Allowance for finance receivable losses, page 15
1. Please provide to us in a disclosure type format a more
detailed
discussion of the nature of this allowance such as the nature of
the
individuals to whom you extend credit, any credit checks made
prior
to the decision to extend the customer credit, how accurate your
allowance has been in the past, and a quantified discussion of the
sensitivity of your operations to this estimate.

Liquidity and Capital Resources, page 19
2. We note that your current presentation seems to reiterate what
can
be read in the statement of cash flows.  Please provide to us a
more
detailed discussion in disclosure type format of the actual
activities that generate and use cash in your operations and the
impact that these activities had on your cash flows.  In this
disclosure highlight the fact that the impact of your daily
operations is not entirely reflected in "operating activities."

Consolidated Financial Statements

2.  Summary of Significant Accounting Policies, page F-7

Commission and fee income, page F-7
3. We note your discussion page 22 that you recognize contingent
revenues under certain contracts.  Please provide to us in
disclosure
type format what your accounting policy related to these
arrangements
is as well as the amounts recognized under these agreements for
the
periods presented.


Franchise Fee Revenue, page F-7
4. Please provide to us in disclosure type format all of the
disclosures required by paragraphs 20-23 of SFAS 45 or tell us
where
the current disclosure complies with these requirements.

Finance Income, Fees and Receivables

5. Please provide to us in disclosure type format a discussion of
the
interest rates charged related to the "Finance contracts
receivable."
Further explain to us what results in the "Deferred interest"
related
to these contracts along with a discussion of how your current
accounting policy addresses these amounts.

11.  Revolving Credit Facility, page F-14
6. Please explain to us whether the entire finance receivable
balance
is eligible to be used in the calculation of the lending limit
disclosed here and disclose that calculated amount.


*    *    *    *

      Please respond to the comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your responses to our comments and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment 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 your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* 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 a 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 our review of your filing or in
response to our comments on your filing.

      You may contact Ibolya Ignat, Staff Accountant at (202) 551-
3656, or Jim Atkinson, Accounting Branch Chief, at (202) 551-3674
if
you have questions regarding the comments. In this regard, do not
hesitate to contact me, at (202) 551-3679.


							Sincerely,



							Jim B. Rosenberg
							Senior Assistant Chief
Accountant
??

??

??

??

Barry B. Goldstein
DCAP Group, Inc.
August 25, 2005
Page 1