March 15, 2006

Via Facsimile (212) 233-9713 and U.S. Mail

Spencer L. Schneider, Esq.
70 Lafayette Street
New York, NY  10013

      Re:	Community Bancshares Inc.
      Soliciting Materials filed pursuant to Rule 14a-12
Filed February 24, 2006, by The Stilwell Group

		Preliminary Proxy Statement on Schedule 14A
Filed March 8, 2006 by The Stilwell Group
		File No. 000-16461

Dear Mr. Schneider:

      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 a 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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Schedule 13D/A filed February 13, 2006
1. The filing persons state in Item 4 that the company`s "return
on
equity is substantially below average, and that its return on
equity
is likely to remain below average for the foreseeable future."  We
note the additional assertion that indicates the company "should
be
sold."  Finally, we note the extensive disclosure relating to
previous investments made by some or all of the filing persons and
the attribution of certain transactions undertaken by the subject
companies to actions of those filing persons.  Please be advised
that
these statements and related supporting rationale were not
required
by the Item 4 obligation of the filing persons to report certain
proposals.  Even though such statements appear in the Schedule
13D,
their voluntarily inclusion does not obviate the fact this
discussion
is considered a solicitation under Rule 14a-1(l) of Regulation
14A.
Please file the cited statements under cover of Schedule 14A
pursuant
to and in compliance with Rule 14a-12.

Schedule 14A
2. It appears that security holders who follow the instructions
included in these materials will be disenfranchised insofar as
they
will not be permitted to vote on any matters (other than the
election
of directors) that may be proposed by Community Bancshares.
Revise
to indicate that by executing and returning the green proxy card,
security holders will relinquish the opportunity to vote on other
matters to be voted upon at the annual meeting that Community
Bancshares may propose in its proxy statement.   Alternatively,
revise the form of proxy to mirror Community Bancshares` form of
proxy when filed.
3. Please revise the cover page of the Schedule 14A to include as
filing persons each of the persons forming the Stilwell Group
instead
of merely listing the group as a filing person.
4. Throughout your proxy statement you refer security holders to
information that you are required to provide and will be contained
in
Community Bancshares` proxy statement for the 2006 Annual Meeting.
We presume that you are relying upon Rule 14a-5(c) to refer to
this
information; if so, please note that we believe that reliance upon
Rule 14a-5(c) before Community Bancshares distributes the
information
to security holders would be inappropriate.  Alternatively, if you
determine to disseminate your proxy statement prior to the
distribution of the company`s proxy statement, you must undertake
to
provide the omitted information to security holders.  Please
advise
as to your intent in this regard.

Cover Letter
5. Each statement or assertion of opinion or belief must be
clearly
characterized as such, and a reasonable factual basis must exist
for
each such opinion or belief.  Support for opinions or beliefs
should
be self-evident, disclosed in the proxy statement or provided to
the
staff on a supplemental basis.  We note your disclosure in the
second
paragraph in this letter in which you state that you do not
believe
the bank will "earn an adequate return on equity."  Provide the
support described above and explain what would an "adequate" rate
of
return and whether your measure of adequacy is necessarily the
same
as that of other security holders.
6. Please provide the information required by Item 1(b) of
Schedule
14A.

Election of the Group`s Nominees, page 2
7. To the extent company nominees do not agree to serve with any
of
the insurgent nominees if the insurgent nominees are successful in
their campaign to be elected, revise to indicate whether or not
the
remaining seats are likely to be vacant or filled by company
nominees.  Disclose how such vacancies would be filled and
specifically discuss any plan to fill such vacancies and whether
or
not security holders would be included in any such plan to fill
vacancies.  See footnote 76 in Exchange Act Release No. 34-31326
(October 16, 1992).
8. Support for opinions or beliefs should be self-evident,
disclosed
in the proxy statement or provided to the staff on a supplemental
basis.  Please provide support your belief that your three
nominees
would be "strong" additions to Community Bancshares` board of
directors.
9. Please expand to describe the nominees` plans with regard to
the
company in more detail.  We note that a reference to your belief
that
the company "should be sold" without more is not sufficient
disclosure.  Disclose, for example, whether you have any specific
proposals with respect to a sale of the company, whether relating
to
the identity of an acquiror, or the structure or timing of a sale.
10. Please ensure that, in discussing your nominees to the board,
you
clearly disclose that no assurance can be given that the election
of
your nominees will result in any increase in return of equity or
in
the sale of the company, the latter given that your nominees would
constitute a minority on the board if elected.

Solicitation; Expenses, page 4
11. Please disclose whether you will seek reimbursement from the
company for costs of this solicitation and whether the question of
such reimbursement will be submitted to a vote of security
holders.
See Item 4 (b)(5) of Schedule 14A.
12. We note that you and D.F. King may employ various methods to
solicit proxies, including mail, advertisement, telephone,
facsimile,
and personal solicitation.  Be advised that all written soliciting
materials, including any e-mails or scripts to be used in
soliciting
proxies over the telephone or any other medium, must be filed
under
the cover of Schedule 14A on the date of first use.  Refer to Rule
14a-6(b) and (c).  Please confirm your understanding.

Form of Proxy
13. Revise to indicate in bold-face type the information regarding
discretionary authority.  Refer to Rule 14a-4(b)(1).

Soliciting Materials
14. Please note that the above comments and those noted in this
section apply to this any future soliciting or definitive
additional
materials.
15. Each statement or assertion of opinion or belief must be
clearly
characterized as such, and a reasonable factual basis must exist
for
each such opinion or belief.  Support for opinions or beliefs
should
be self-evident, disclosed in the proxy statement or provided to
the
staff on a supplemental basis.  We note your disclosure in the
third
paragraph of the letter to Community Bancshares security holders
in
which you state that "the majority of last year`s earnings... came
from  one-time gains" and the "bulk of this year`s earnings will
come
from one-time gains."  Provide the support described above.
16. Your disclosure that "after this year, there won`t be many
[one-
time gains] left to pull out of the hat" implies that the board
and
management of Community Bancshares are acting inappropriately in
reporting the company`s financial results.  You must avoid
statements
that directly or indirectly impugn the character, integrity, or
personal reputation or make charges of illegal or immoral conduct
without factual foundation.  Note that the factual foundation for
such assertions must be reasonable and the factual basis must be
disclosed in the document or provided to the staff on a
supplemental
basis.  Refer to Rule 14a-9.
17. Each statement or assertion of opinion or belief must be
clearly
characterized as such, and a reasonable factual basis must exist
for
each such opinion or belief.  Support for opinions or beliefs
should
be self-evident, disclosed in the proxy statement or provided to
the
staff on a supplemental basis.  We note your disclosure in the
fourth
paragraph of the letter to Community Bancshares security holders
in
which you assert the company`s CEO does not have "much confidence
in
the Bank`s ability to produce operating earnings."  We also note
your
disclosure that current management "cannot show us a bright
future."

Closing Comments

      Please amend the preliminary proxy statement in response to
these comments.  Clearly and precisely mark the changes to the
preliminary proxy statement effected by the amendment, as required
by
Rule 14a-6(h) and Rule 310 of Regulation S-T.  We may have further
comments upon receipt of your amendment; therefore, please allow
adequate time after the filing of the amendment for further staff
review.

      You should furnish a response letter with the amendment
keying
your responses to our comment letter and providing any
supplemental
information we have requested.  You should transmit the letter via
EDGAR under the label "CORRESP."  In the event that you believe
that
compliance with any of the above comments is inappropriate,
provide a
basis for such belief to the staff in the response letter.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the filing persons 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 statement from each of the filing persons
acknowledging
that:

* the filing persons are 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 filing persons 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.

      Please direct any questions to me at (202) 551-3619 or, in
my
absence, to Pam Carmody, Special Counsel, at (202) 551-3265.  You
may
also contact me via facsimile at (202) 772-9203.  Please send all
correspondence to us at the following ZIP code: 20549-3628.


Sincerely,



Daniel F. Duchovny
Attorney-Advisor
Office of Mergers and Acquisitions

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Spencer L. Schneider, Esq.
March 15, 2006
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3628

         DIVISION OF
CORPORATION FINANCE