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                             July 11, 2022

       Virginia Herring
       Chief Executive Officer
       1st Franklin Financial Corporation
       135 East Tugalo Street
       Toccoa, Georgia 30577

                                                        Re: 1st Franklin
Financial Corporation
                                                            Form 10-K for the
fiscal period ending December 31, 2021
                                                            Filed March 31,
2022
                                                            File No. 002-27985

       Dear Ms. Herring:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the fiscal period ending December 31, 2022

       Business, page 4

   1.                                                   We note that total
loans originated/acquired of $1,152 million in 2021 is different from the
                                                        $588.6 million of loans
originated or purchased as reported in your audited consolidated
                                                        statements of cash
flows on page 28. Please enhance your disclosures in future filings to
                                                        address this
discrepancy. Include information regarding a customer's eligibility for loan
                                                        renewals and or
refinancings and explain how these transactions are reflected in the
                                                        business metrics
disclosed as compared to your financial statements. In addition,
                                                        separately disclose the
amounts of loans renewed and or refinanced included in loans
                                                        originated or acquired
and loans liquidated. Provide us with your proposed disclosure.
                                                        Refer to Item 303(b)(2)
of Regulation S-K.
   2.                                                   We note that
liquidations include customer loan payments, refunds on precomputed
                                                        finance charges,
renewals and charge offs. We also note on page 33 you disclose that the
                                                        amount charged-off is
the unpaid balance less the unearned finance charges and the
 Virginia Herring
1st Franklin Financial Corporation
July 11, 2022
Page 2
         unearned insurance premiums, if applicable. Please tell us and enhance
future filings to
         disclose the components of liquidations and net losses/charge-offs,
including your basis
         for including refunds on precomputed finance charges in liquidations
and if renewals
         include unearned finance and other charges. Provide us with your
proposed disclosure.
Note. 2 Loans , page 32

3.       Please revise your future filings to disclose your accounting policies
for loan renewals and
         or refinancings, including reference to the authoritative guidance you
use to support your
         accounting. Provide us with your proposed disclosure.
4.       On page 36 you present principal balance of total loans at December
31, 2021 of $1,033.1
         million which you state is net of accrued interest, deferred fees and
deferred acquisition
         costs and net charge-off of $41.2 million which excludes unearned
finance charges
         and unearned insurance premiums, if applicable. Please tell us why you
present principal
         balance including unearned finance charges and unearned insurance
premiums but
         exclude these amounts from net charge-offs.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Michelle Miller at 202-551-3368 or Sharon Blume at
202-551-3474
with any questions.



FirstName LastNameVirginia Herring                             Sincerely,
Comapany Name1st Franklin Financial Corporation
                                                               Division of
Corporation Finance
July 11, 2022 Page 2                                           Office of
Finance
FirstName LastName