Mail Stop 4-8
								December 10, 2004

By mail and fax to: 817-336-0151

Tim Raso
Chief Operating Officer
Surety Capital Corporation
1501 Summit Avenue
Fort Worth, TX 76102

Re: Surety Capital Corporation
      Form 8-K filed August 17, 2004
      File No. 1-12818

Dear Mr. Raso,

The Staff has reviewed the above-referenced filing for compliance
with the requirements of Form 8-K and has the following comment in
that regard.

* Please revise the second paragraph of your Form 8-K to cover the
subsequent interim period from the date of the last audited
financial
statements to August 11, 2004, the date of dismissal of the former
independent accountants. See Item 304(a)(1)(iv) of Regulation S-K.

Please file an amendment via EDGAR in response to these comments
within 5 business days of the date of this letter, unless
specified
otherwise, or contact us immediately if you require additional
time.
Such amendment should be filed under cover of Form 8-K/A and
should
include the ITEM 4 designation. A letter from your former
accountant
addressing the revised disclosures should also be included in your
amended Form 8-K and filed as Exhibit 16. To expedite the
processing
of the Form 8-K, please furnish a courtesy copy of the filing to
the
undersigned.

You may direct any questions regarding this comment to me at 202-
942-
2952.

								Sincerely,



								Amit Pande
								Staff Accountant
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LSB Financial Corp.
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