<PAGE>

                                                                    Exhibit 31

                          RULE 13a-14(a) CERTIFICATION

I, R. Clay Hulette, certify that:

1.       I have reviewed this quarterly report on Form 10-QSB of Frankfort First
         Bancorp, Inc.;

2.       Based on my knowledge, this quarterly report does not contain any
         untrue statement of a material fact or omit to state a material fact
         necessary to make the statements made, in light of the circumstances
         under which such statements were made, not misleading with respect to
         the period covered by this quarterly report;

3.       Based on my knowledge, the financial statements, and other financial
         information included in this quarterly report, fairly present in all
         material respects the financial condition, results of operations and
         cash flows of the registrant as of, and for, the periods presented in
         this quarterly report;

4.       The small business issuer's other certifying officer(s) and I are
         responsible for establishing and maintaining disclosure controls and
         procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e))
         for the small business issuer and have:

a)       Designed such disclosure controls and procedures, or caused such
         disclosure controls and procedures to be designed under our
         supervision, to ensure that material information relating to the small
         business issuer, including its consolidated subsidiaries, is made known
         to us by others within those entities, particularly during the period
         in which this quarterly report is being prepared;

b)       N/A

c)       Evaluated the effectiveness of the small business issuer's disclosure
         controls and procedures and presented in this report our conclusions
         about the effectiveness of the disclosure controls and procedures as of
         the end of the period covered by this report based on such evaluation;
         and

d)       Disclosed in this quarterly report any change in the small business
         issuer's internal control over financial reporting that occurred during
         the small business issuer's fiscal quarter ended March 31, 2004 that
         has materially affected, or is reasonably likely to materially affect,
         the small business issuer's internal control over financial reporting;
         and

5.       The small business issuer's other certifying officer(s) and I have
         disclosed, based on our most recent evaluation of internal control over
         financial reporting, to the small business issuer's auditors and the
         audit committee of the small business issuer's board or directors (or
         persons fulfilling the equivalent functions):

a)       All significant deficiencies and material weaknesses in the design or
         operation of internal control over financial reporting which are
         reasonably likely to adversely affect the small business issuer's
         ability to record, process, summarize and report financial information;
         and

b)       Any fraud, whether or not material, that involves management or other
         employees who have a significant role in the small business issuer's
         internal control over financial reporting.


Date: May 12, 2004


                                     /s/ R. Clay Hulette
                                     ------------------------------------
                                     R. Clay Hulette
                                     Vice President and Chief Financial Officer



<PAGE>


                                                                    Exhibit 31

                          RULE 13a-14(a) CERTIFICATION

I, Don Jennings, certify that:

1.       I have reviewed this quarterly report on Form 10-QSB of Frankfort First
         Bancorp, Inc.;

2.       Based on my knowledge, this quarterly report does not contain any
         untrue statement of a material fact or omit to state a material fact
         necessary to make the statements made, in light of the circumstances
         under which such statements were made, not misleading with respect to
         the period covered by this quarterly report;

3.       Based on my knowledge, the financial statements, and other financial
         information included in this quarterly report, fairly present in all
         material respects the financial condition, results of operations and
         cash flows of the registrant as of, and for, the periods presented in
         this quarterly report;

4.       The small business issuer's other certifying officer(s) and I are
         responsible for establishing and maintaining disclosure controls and
         procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e))
         for the small business issuer and have:

a)       Designed such disclosure controls and procedures, or caused such
         disclosure controls and procedures to be designed under our
         supervision, to ensure that material information relating to the small
         business issuer, including its consolidated subsidiaries, is made known
         to us by others within those entities, particularly during the period
         in which this quarterly report is being prepared;

b)       N/A

c)       Evaluated the effectiveness of the small business issuer's disclosure
         controls and procedures and presented in this report our conclusions
         about the effectiveness of the disclosure controls and procedures as of
         the end of the period covered by this report based on such evaluation;
         and

d)       Disclosed in this quarterly report any change in the small business
         issuer's internal control over financial reporting that occurred during
         the small business issuer's fiscal quarter ended March 31, 2004 that
         has materially affected, or is reasonably likely to materially affect,
         the small business issuer's internal control over financial reporting:
         and

5.       The small business issuer's other certifying officer(s) and I have
         disclosed, based on our most recent evaluation of internal control over
         financial reporting, to the small business issuer's auditors and the
         audit committee of the small business issuer's board or directors (or
         persons fulfilling the equivalent functions):

a)       All significant deficiencies and material weaknesses in the design or
         operation of internal control over financial reporting which are
         reasonably likely to adversely affect the small business issuer's
         ability to record, process, summarize and report financial information;
         and

b)       Any fraud, whether or not material, that involves management or other
         employees who have a significant role in the small business issuer's
         internal control over financial reporting.


Date: May 12, 2004



                                        /s/ Don Jennings
                                        --------------------------
                                        Don Jennings
                                        President and Chief Executive Officer