SEC Division of Corporation Finance no-action letter: Greenville Federal Financial Corporation

221 East Fourth St. VORYS Suite 2000, Atrium Two PO Box 0236 Vorys, Sater, Seymour and Pease LLP Cincinnati, OH 45201-0236 Legal Counsel 513-723--4000 I www.vorys.com Founded 1909 Jason L. Hodges Securities Exchange Act of 1934, Direct Dial (513) 723-8590 Sections 12(h), 13(a) and 15(d), and Direct Fax (513) 852-7857 Email jlhodges@vorys.com Rule 12h-3 July 2,2010 VIAE-MAIL Office ofthe Chief Counsel Division of Corporation Finance Securities and Exchange Commission 100 F Street N.E. Washington, DC 20549 Re: Greenville Federal Financial Corporation Commission File No. 000-51668 Ladies and Gentlemen:
On behalf of our client, Greenville Federal Financial Corporation (the "Company"), we hereby request that the staff of the Division of Corporation Finance (the "Staff') ofthe Securities and Exchange Commission (the "Commission") concur in the Company's view that the automatic updating ofthe Company's Registration Statement on Form S-8 during the fiscal year ended June 30,2010, pursuant to Section 10(a)(3) ofthe Securities Act of 1933, as amended (the "1933 Act"), will not preclude the Company from utilizing Rule 12h-3 under the Securities Exchange Act of 1934, as amended (the "Exchange Act"), to suspend the Company's duty to file with the Commission periodic and current reports required by Sections 13(a) and 15(d) of the Exchange Act and the rules and regulations under those sections on or before September 28, 2010, the filing deadline for the Company's Annual Report on Form 10-K for the fiscal year ended June 30,2010. Alternatively, we hereby request that the Commission use its discretionary authority under Section 12(h) of the Exchange Act to exempt the Company from the requirement to file an Annual Report on Form lO-K for the fiscal year ended June 30, 2010. The Company filed on June 22, 2010, a Form 15 terminating the registration of its common stock in accordance with Rule 12g-4(a)(1) under the Exchange Act. Subject to the Staffs concurrence with the request set forth in this letter, the Company intends to complete the filing ofa Form 15 pursuant to Rule 12h-3(b)(I) to discontinue its reporting obligations under
Section 15(d) of the Exchange Act prior to the filing deadline for its Annual Report on Form
lO-K for the fiscal year ended June 30, 2010.
The Company has authorized us to make the representations set forth in this letter on its behalf. Columbus I Washington I Cleveland I Cincinnati I Alexandria I Akron I Houston