Mail Stop 4561

October 21, 2005

Norris Nissim
Vice-President, General Counsel and Secretary
BKF Capital Group, Inc.
One Rockefeller Plaza
New York, New York 10200

RE:	BKF Capital Group, Inc.
Item 4.02 Form 8-K
Filed October 17, 2005
File No. 001-10024

Dear Mr. Nissim,

	We have reviewed your filing and have the following comment.
In
our comment, we have asked you to provide us with more 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 comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

1. We note that you intend to file restated financial statements.
Please tell us when you will file them.

	As appropriate, please respond to this comment within five
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your response to our comment.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes 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 comment, please provide,
in
writing, a statement 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 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 comment on your filing.

   	You may contact Michael Volley, Staff Accountant, at (202)
551-
3437 or me at (202) 551- 3423 if you have questions regarding our
comment.

Sincerely,



Amit Pande
Assistant Chief Accountant

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Norris Nissim
BKF Capital Group, Inc.
October 21, 2005
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