Response: This minority interest represents a non-controlling interest in a variable interest entity "VIE" as defined by FASB Interpretation No. 46(R) (As Amended) - Consolidation of Variable Interest Entities. The Company owns 99% of a limited partnership known as Guilford Corporate Tax Credit Fund XVII, Ltd., which in turn owns 9.9% of another limited partnership, LaVista Foundation I, Limited Partnership ("LaVista"), which operates an apartment complex. The Company has an existing loan with LaVista which necessitates its consolidation based on guidelines established by FASB Interpretation No. 46(R). The Company began consolidating the VIE's in its consolidated financial statements during 2004. At December 31, 2005, the VIE's had a negative equity balance which caused the reported balance in this minority interest to have a debit balance. Once the balance became negative the Company reviewed the appropriate accounting rules to ensure that the Company was properly recording the minority interest balance on the Company's consolidated financial statements. Based on our review of Paragraph 15 of Account Research Bulletin No. 51 "Consolidated Financial Statements", the Company concluded that this minority interest was required to be reported in retained earnings.

The minority interest in the net loss of the VIE's represents 0.58% of interest income and other income of the Company as of December 31, 2006, and is not material based on guidelines established under Rule 9-04 of Regulation S-X.

- the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

- 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.