MACKEY PRICE THOMPSON & OSTLER
                           A Professional Corporation
                         Attorneys and Counselors at Law

                                American Plaza II
                          57 West 200 South, Suite 350
                          Salt Lake City, UT 84101-3663
                             Telephone 801-575-5000
                                Fax 801-575-5006

Randall A. Mackey
rmackey@mpwlaw.com






                                November 8, 2005




VIA FACSIMILE    (202) 772-9218
- --- ---------
AND EDGAR

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W., Mail Stop 6010
Judiciary Plaza
Washington, D.C. 20549

Attn:    Julie Sherman
         Staff Accountant

         Re:      Security National Financial Corporation
                  Form 10-K for the year ended December 31, 2004
                  Filed April 15, 2005
                  File No. 0-9341

Ladies and Gentlemen:

     On behalf of Security National Financial Corporation (the "Company") and in
connection  with the  above-captioned  Form 10-K (the "Form  10-K"),  we enclose
responses to the comment  letter dated  October 5, 2005,  which we received from
the staff of the  Securities and Exchange  Commission  (the  "Commission").  The
following  responses to the comments are tied to the numbered  paragraphs in the
comment letter.

     1(a).  The mortgage  loans sold to investors  receivable as of December 31,
2004  and  December  31,  2003 of  $47,167,150  and  $114,788,185,  respectively
represents the unpaid loans sold to investors. Generally, these are the mortgage
loans funded by the  Company's  wholly owned  insurance  subsidiaries,  Security
National Life Insurance  Company and Southern  Security Life Insurance  Company,
from internal cash sources during the prior 90 day period.  See our responses in
1(c) and (d) below.

     1(b). Most mortgage loans are settled within a 90 day period.

     1(c) and (d). As disclosed in the Company's September 1, 2005 letter to the
Commission  the mortgage  loans are funded by means of two sources of cash:  (i)
internal cash flows from the Company's insurance subsidiaries, Security National
Life Insurance  Company and Southern Security Life Insurance  Company,  and (ii)
cash flows from unrelated  financial  institutions,  such as  Countrywide  Homes
Loans and Citi Mortgage, Inc. Mortgage loans funded from internal cash flows are
shown on the balance  sheet of the  Company's  financial  statements as mortgage
loans sold to  investors  until such funds have been  received  from  investors,
which is generally within a 90 day period.

     Mortgage  loans funded from  unrelated  financial  institutions  consist of
arrangements  with  such  financial   institutions  to  purchase  mortgage  loan
receivables.  The Company has indicated in previous  filings with the Commission
that it utilizes  warehouse  lines of credit in connection  with these  mortgage
loans.  Under these warehouse  lines of credit,  the Company has agreements with
the unrelated  financial  institutions in which the financial  institutions will
purchase  mortgage  loan  receivables  of up to  certain  amounts.  Under  these
agreements, the unrelated financial institutions will purchase approximately 97%
of each of the mortgage loans from the Company's insurance subsidiaries.  On the
same day as the mortgage loans are funded,  the Company  assigns its interest in
the mortgage  loans to the  financial  institution,  including the notes and the
investor  commitments  to purchase the mortgage  loans.  An amount  representing
approximately  3% of the  mortgage  loans  that  is  retained  by the  financial
institution  will  be  paid  to the  Company  at  such  time  as  the  financial
institution  receives the sale proceeds from the investor.  This amount is shown
on the balance sheet as mortgage loans sold to investors.

     1(e). The amounts the Company owes under line of credit  agreements are not
included in the balance  sheet or footnote  disclosure  because such amounts are
not a liability as explained in paragraphs  1(c) and (d) above.  The Company has
had lines of credit  commitments  to  purchase  mortgage  loans  from  unrelated
financial  institutions  in  amounts  not  to  exceed  $130,000,000,   of  which
$54,624,000  was  outstanding  at December  31,  2004.  These  amounts  were not
disclosed in the  Company's  Form 10-K  financial  statements.  The Company will
include this disclosure in future financial statements and Form 10-K filings.

     2. The Company had no outstanding  commitments to originate  mortgage loans
as of December 31, 2004. For the year ended December 31, 2004, there was not any
impact on the Company's consolidated financial position or results of operations
caused  by  commitments  to  originate   mortgage  loans.   Mortgage  loans  are
specifically  matched with  mandatory  delivery  commitments  from a third party
investor at the time of  disbursement  of funds and they bear no  interest  rate
risk or  fallout  risk.  For  mortgage  loans  that are not  closed or funded by
December  31,  2004,  there is a match of such loans with a  mandatory  delivery
commitment  from a third  party  investor.  For  reporting  in  accordance  with
Statement of Financial  Accounting  Standards  No. 149, the amount of derivative
risk as of December  31,  2004 was $60,337 for loans not closed or funded.  This
amount was offset by the same amount in mandatory  commitments  from third party
investors.

     3.  SecurityNational  Mortgage  Company  uses  two  basic  methods  to sell
mortgage loans to investors.  First, it uses a "best efforts" method.  Under the
"best efforts" method, the investor requires delivery of the mortgage loans sold
if committed  loans actually close. If the loans do not close under the terms of
the commitment,  there is no obligation to deliver or pair off fee charged.  The
second method of selling  mortgage  loans is the  "mandatory  delivery"  method.
Under this  method,  the seller is  required  to deliver  the amount and type of
loans committed.  If loans cannot be delivered as agreed, a market pair off will
result. In both of these methods,  commitment and delivery  expiration dates are
established.  An expiration date may be rolled forward for an agreed upon fee if
delivery  cannot be made. The purchaser is obligated to purchase loans delivered
under both of these  methods if the loan terms and  conditions  are met.  If the
loan terms and  conditions  do not match those  agreed to, the  purchaser is not
obligated to buy the loans.  At December 31, 2004,  the Company did not have any
volume requirements to sell mortgage loans to investors.

     The  Company  has  prepared  these  responses  in an effort to address  the
comments from the staff. Any additional comments or questions should be directed
to Randall A. Mackey, Esq, at (801) 575-5000, counsel for the Company.

                                    Very truly yours,

                                    /s/  Randall A. Mackey
                                        Randall A. Mackey
Enclosures
cc:      Scott M. Quist
         G. Robert Quist
         Stephen M. Sill
         Virgil R. Pugsley
         Douglas D. Hawkes