EXHIBIT 99.7

                            COMMERCE GROUP CORP.
                            6001 NORTH 91ST ST.
                      MILWAUKEE, WISCONSIN  53225-1795
                               (414) 462-5310
                            FAX (414) 462-5312
                       E-MAIL  info@commercegroupcorp.com
                      WEBSITE www.commercegroupcorp.com



                     AND/OR COMMERCE/SANSEB JOINT VENTURE (Joint Venture)
                     AND/OR HOMESPAN REALTY CO., INC. (Homespan)
                     AND/OR ECOMM GROUP INC. (Ecomm)
                     AND/OR SAN LUIS ESTATES, INC. (SLE)
                     AND/OR SAN SEBASTIAN GOLD MINES, INC. (Sanseb)
                     AND/OR UNIVERSAL DEVELOPERS, INC. (UDI)
                     ALL LOCATED AT THE SAME ADDRESS



April 8, 2009


Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
1733 North Farwell Avenue
Milwaukee, Wisconsin  53202

Dear Mr. Machulak:

At today's Commerce Group Corp. (Commerce) Directors' meeting, the
Directors were informed about the annual confirmation, disclosure and
status letter from Commerce, its subsidiaries, its affiliates, and the
Joint Venture, and to establish and confirm the amount due and the
collateral pledged along with any other Commerce obligations or
agreements made to Machulak, Robertson & Sodos, S.C. (Law Firm) referred
to as Lender, as of Commerce's fiscal year ended March 31, 2009.  Today,
Commerce's Directors, by unanimous consent, approved, ratified and
confirmed the contents of this letter and authorized me to submit its
understanding of your status with Commerce, which is as follows:

1.   Accrued Legal Fees

     The Law Firm which represents Commerce in which a son of the
     President is a principal is owed the sum of $506,396.25 for 2,250.65
     hours of legal services rendered from July 1980 through February 28,
     2009.  By agreement on the date of payment, these fees are to be
     adjusted to commensurate with the current hourly fees charged by the
     Law Firm.  Such adjustment was made during this fiscal period to
     correspond with the current hourly rate change.


<PAGE>

Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
April 8, 2009
Page 2 of 8 Pages


     As of March 31, 2009, the following parties are collectively and
     individually identified as the Lender(s): General Lumber & Supply
     Co., Inc. (GLSCO); Edward L. Machulak  as an individual and not as a
     Director or Officer of Commerce (ELM); the Edward L. Machulak
     Rollover Individual Retirement Account (ELM RIRA), the Sylvia
     Machulak Rollover Individual Retirement Account (SM RIRA), Sylvia
     Machulak, as a consultant and as an individual (SM), John E.
     Machulak and Susan R. Robertson, husband and wife (M&R), the
     Machulak, Robertson & Sodos, S.C. Law Firm (Law Firm), Circular
     Marketing, Inc. (CMI) and Edward A. Machulak as an individual (EAM).

2.   Collateral Pledged

     The following collateral has been previously assigned to certain
     Lenders, including John E. Machulak and Susan R. Robertson, husband
     and wife (M&R), the Machulak, Robertson & Sodos, S.C. Law Firm (Law
     Firm), Circular Marketing, Inc. (CMI) and Edward A.  Machulak as an
     individual (EAM) as of March 31, 2007, pursuant to resolutions
     adopted by the Directors:

     (1)  Commerce/Sanseb Joint Venture (Joint Venture)

          Both Commerce and San Sebastian Gold Mines, Inc. have assigned
          all of the rights, title, claims, remedies and interest that
          each has in the Joint Venture to the Lenders.  Reference is
          made to Historical information - San Sebastian Gold Mine
          Concession.

     (2)  New SSGM Exploration Concession/License (New SSGM) -
          approximately 40.7694 square kilometers (10,070 acres)
          Government of El Salvador Resolution No. 27.

          On October 20, 2002, the Company applied for the New SSGM,
          which covers an area of 42 square kilometers and includes
          approximately 1.2306 square kilometers of the Renewed SSGM.
          The New SSGM is in the jurisdiction of the City of Santa Rosa
          de Lima in the Department of La Union and in the Nueva Esparta
          in the Department of Morazan, Republic of El Salvador, Central
          America.  On February 24, 2003, the El Salvador Department of
          Hydrocarbons and Mines (DHM) issued the New SSGM for a period
          of four years starting from the date following the notification
          of this resolution which was received on March 3, 2003.  The
          New SSGM may be extended for two two-year periods, or for a
          total of eight years.  Besides the San Sebastian Gold Mine,
          three other formerly operative gold and silver mines known as
          the La Lola Mine, the Santa Lucia Mine, and the Tabanco Mine
          are included in the New SSGM. The Company has complied as
          required by


<PAGE>

Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
April 8, 2009
Page 3 of 8 Pages


          filing its annual activity report and it paid the annual
          surface tax.  This concession had been assigned collectively to
          all of the Lenders named herein on May 12, 2003 and the
          assignment was included in the May 12, 2003 confirmation
          agreement as Exhibit B.

      (3) Lease agreement by and between Mineral San Sebastian Sociedad
          Anomina de Capital Variable (Misanse) and Commerce dated
          January 14, 2003

          The term of this lease agreement coincides with the term of the
          Renewed San Sebastian Gold Mine Exploitation Concession and
          consists of 1,470 acres owned by Misanse.  This lease agreement
          has been assigned to all of the Lenders named herein on May 12,
          2003 and the assignment was included in the May 12, 2003
          confirmation agreement as Exhibit B.

      (4) Renewed San Sebastian Gold Mine Exploitation Concession/License
          (Renewed SSGM) - approximately 1.2306 square kilometers (304
          acres), Department of La Union, El Salvador, Central America
          (pledged and assigned as collateral on May 10, 2004) Government
          of El Salvador Agreement No. 591.

          On September 6, 2002, at a meeting held with the El Salvadoran
          Minister of Economy and the DHM, it was agreed to submit an
          application for the Renewed SSGM for a 30-year term and to
          simultaneously cancel the concession obtained on July 23, 1987.
          On September 26, 2002, the Company filed this application.  On
          February 28, 2003 (received March 3, 2003) the DHM admitted to
          the receipt of the application and the Company proceeded to
          file public notices as required by Article 40 of the El
          Salvadoran Mining Law and its Reform (MLIR).  On April 16,
          2003, the Company's El Salvadoran legal counsel filed with the
          DHM notice that it believed that it complied with the
          requirements of Article 40, and that there were no objections;
          and requested that the DHM make its inspection as required by
          MLIR Article 42.  The Company then provided a bond which was
          required by the DHM to protect third parties against any damage
          caused from the mining operations, and it simultaneously paid
          the annual surface t ax.  On August 29, 2003 the Office of the
          Ministry of Economy formally presented the Company with the
          twenty-year Renewed SSGM which was dated August 18, 2003.  This
          Renewed SSGM replaces the collateral that the same parties held
          with the previous concession.  On May 20, 2004 (delivered June
          4, 2004) the Government of El Salvador, under their Agreement
          Number 591, extended the exploitation concession for a period
          of 30 years.  A copy of the assignment dated May 10, 2004, is
          attached to the May 10, 2004 confirmation letter as Exhibit B
          and the Renewed SSGM agreement is attached to Exhibit B and
          referred to as Exhibit 1.


<PAGE>

Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
April 8, 2009
Page 4 of 8 Pages


      (5) San Cristobal Mill and Plant (SCMP) three-year lease by and
          between Commerce and Corporacion Salvadorena de Inversiones
          (Corsain), an El Salvadoran governmental agency, executed on
          Monday, April 26, 2004, retroactive to November 13, 2003.
          Pledged and assigned as collateral on May 10, 2004.

          The renewed three-year SCMP lease for the property located near
          the City of El Divisadero was finalized and executed on Monday,
          April 26, 2004, and is retroactive to November 13, 2003.  This
          May 10, 2004 assignment is included in the May 10, 2004
          confirmation letter as Exhibit B and the lease agreement is
          attached to Exhibit B and referred to as Exhibit 2.

          On March 25, 2008 a nineteen-month lease retroactive to
          November 12, 2006 was executed by and between Corsain and
          Commerce.  The lease was renewed on June 12, 2008 for a
          six-month period to expire on December 11, 2008 with an option
          to subsequently renew it for additional three-month periods.
          The Company has chosen to exercise this option and has renewed
          the lease through June of 2009.  Reference is made to Exhibit
          10.16 of Commerce's Form 10-K for its fiscal year ended March
          31, 2008 for a copy of this lease.

      (6) Nueva Esparta Exploration Concession/License (Nueva Esparta) -
          45 square kilometers (11,115 acres) Resolution No. 271

          On or about October 20, 2002, the Company filed an application
          with the DHM for the Nueva Esparta Exploration
          Concession/License which consists of 45 square kilometers and
          is located north and adjacent to the New SSGM.  On May 25, 2004
          the Government of El Salvador, under their Resolution No. 271,
          issued the Nueva Esparta Exploration Concession/License for a
          period of four years starting from the date following the
          notification of this resolution which was received on June 4,
          2004.  This concession/license may be extended for two two-year
          periods or for a total of eight years.  This rectangular area
          is in the Departments of La Union (east) and Morazan (west) and
          in the jurisdiction of the City of Santa Rosa de Lima, El
          Salvador, Central America.  Included in the Nueva Esparta are
          eight other formerly operated gold and silver mines known as:
          the Banadero Mine, the Carrizal Mine, the Copetillo Mine, the
          Grande Mine, the La Joya Mine, the Las Pinas Mine, the
          Montemayor Mine, and the Or o Mine.  A copy of the assignment
          dated May 9, 2005 was attached to the May 9, 2005 confirmation
          letter as Exhibit C and the Nueva Esparta Exploration
          Concession is attached to Exhibit C and referred to as Exhibit
          1.

<PAGE>

Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
April 8, 2009
Page 5 of 8 Pages


      (7) Acknowledgment of collateral provided through March 31, 2009

          Commerce's Directors have on April 8, 2009 authorized and
          directed Commerce's Officers to assign all of the rights,
          titles, claims, remedies and interest in all of its assets that
          it has, including any assets owned by the Joint Venture, to
          GLSCO, ELM, the ELM RIRA, the SM RIRA, SM, and from March 31,
          2007 to include M&R, the Law Firm, CMI and EAM, collectively
          and individually referred to as Lenders, as additional
          collateral for all of the outstanding loans and obligations as
          of March 31, 2009, including all future advances of any kind.

3.   Cross Pledge Collateral Agreement

     GLSCO, ELM, the ELM RIRA, the SM RIRA and SM individually are
     entitled to specific collateral that has been pledged to them by
     Commerce, its subsidiaries, affiliates and the Joint Venture.  Upon
     default by Commerce, or its subsidiaries or affiliates or the Joint
     Venture, then GLSCO, ELM, the ELM RIRA, the SM RIRA and SM have the
     first right to the proceeds from the specific collateral pledged to
     each of them.  Commerce, its subsidiaries, affiliates, and the Joint
     Venture also have cross-pledged the collateral without diminishing
     the rights of the specific collateral pledged to each of the
     following:  GLSCO, ELM, the ELM RIRA, the SM RIRA and SM.  The
     purpose and the intent of the cross pledge of collateral is to
     assure GLSCO, ELM, the ELM RIRA, the SM RIRA, and SM, that each of
     them would be paid in full; thus, any excess collateral that would
     be available is for the purpose of satisfying any debts and
     obligations due to each of the named parties.  The formula to be
     used (after deducting the payments made from the specific
     collateral) is to total all of the debts due to GLSCO, ELM, the ELM
     RIRA, the SM RIRA, SM, and from March 31, 2007 to include M&R, the
     Law Firm, CMI and EAM, and then to divide this total debt into each
     individual debt to establish each individual's percentage of the
     outstanding debt due.  This percentage then will be multiplied by
     the total of the excess collateral to determine the amount of
     proceeds each party should receive from the excess collateral.  Then
     the amount due to each of them would be distributed accordingly.

4.   Cancellation of Inter-Company Debts Upon Default

     Since certain of the collateral specifically or collectively pledged
     to GLSCO, ELM, the ELM RIRA, the SM RIRA, SM and from March 31, 2007
     to include M&R, the Law Firm, CMI and EAM, consists of the common
     stock of Homespan, Ecomm, Sanseb, SLE, Misanse, UDI and the interest
     in the ownership of the Joint Venture, Commerce agreed, upon default
     of the payment of principal or interest to any of the individual
     Lender(s) mentioned herein, that it will automatically cancel any
     inter-company debts owed to


<PAGE>

Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
April 8, 2009
Page 6 of 8 Pages


     Commerce by any of its wholly-owned subsidiaries or affiliates or
     the Joint Venture at such time as any of the stock or Joint Venture
     ownership is transferred to the collateral holders as a result of
     default of any promissory note.

5.   Guarantors

     This agreement further confirms that Commerce and all of the
     following are guarantors to the obligations due to the Law Firm and
     to the loans made by the Law Firm to Commerce:  Joint Venture,
     Homespan, Ecomm, SLE, Sanseb and UDI.  They jointly and severally
     guarantee payment of the note(s) that they caused to be issued and
     also agree that these note(s) may be accelerated in accordance with
     the provisions contained in the agreement and/or any collateral or
     mortgages securing these notes.  Also, Commerce, all of its
     subsidiaries and the Joint Venture agree to the cross pledge of
     collateral for the benefit of GLSCO, ELM, the ELM RIRA, the SM RIRA,
     SM, and from March 31, 2007 to include M&R, the Law Firm, CMI and
     EAM.  Reference is made to Exhibit 5 included in the April 9, 1990
     confirmation letter.

6.   Re-Execution Agreement(s)

     In the event the Law Firm deems that it is necessary or advisable
     for the Law Firm to have Commerce re-execute any document(s) entered
     into, including, but not limited to the promissory note(s) or
     collateral agreement(s), Commerce will re-execute such document(s)
     reasonably required by the Law Firm.  Commerce also acknowledges
     that Commerce may be liable to pay certain costs related to any of
     the transactions entered into with the Law Firm.  If at a later date
     the Law Firm determines that an error has been made in the payment
     of such costs to the Law Firm, then the Law Firm may demand payment
     and Commerce does hereby agree to make such payment forthwith.  All
     requests for corrections of any errors and/or payment of costs shall
     be complied with by Commerce within seven (7) days of the Law Firm's
     written request.  The failure of Commerce to comply with Commerce's
     obligation(s) hereunder shall constitute a default and shall entitle
     the Law Firm to the remedies available for default under any
     provisions of the agreements including, but not limited to the
     promissory note(s) and/or the collateral pledge agreement(s) and/or
     any other Commerce obligation(s).

<PAGE>

Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
April 8, 2009
Page 7 of 8 Pages


7.    Omissions

      Commerce believes that it has included all of its obligations,
      monies due and has listed all of the collateral due to the Law
      Firm, however, since these transactions have taken place over  a
      long period of time in which changes could have taken place, it is
      possible that inadvertently some item(s), particularly collateral,
      could have been omitted.  If that should prove to be a fact, then
      Commerce, the Joint Venture, Homespan, Ecomm, SLE, Sanseb, and UDI
      agree that those omissions of collateral, if any, are meant to be
      included as collateral under this confirmation agreement.

If you are in agreement with the contents of this letter, please sign
below and return one copy to Commerce.

Very truly yours,

COMMERCE GROUP CORP.

/s/ Christine M. Wolski

Christine M. Wolski
Secretary



<PAGE>


Mr. John E. Machulak
Machulak, Robertson & Sodos, S.C. (Law Firm)
April 8, 2009
Page 8 of 8 Pages



The contents of this letter are agreed by the following:

COMMERCE/SANSEB JOINT VENTURE              HOMESPAN REALTY COMPANY, INC.
as Guarantor (Joint Venture)               as Guarantor (Homespan)

/s/ Edward A. Machulak                     /s/ Edward A. Machulak

---------------------------------------    ------------------------------
By:  Edward A. Machulak, Auth. Designee    By:  Edward A. Machulak, President


ECOMM GROUP INC.                           SAN LUIS ESTATES, INC.
as Guarantor (Ecomm)                       as Guarantor (SLE)


/s/ Edward A. Machulak                     /s/ Edward A. Machulak

---------------------------------------    ------------------------------
By:  Edward A. Machulak, President         By: Edward A. Machulak, President


SAN SEBASTIAN GOLD MINES, INC.             UNIVERSAL DEVELOPERS, INC.
as Guarantor (Sanseb)                      as Guarantor (UDI)

/s/ Edward A. Machulak                     /s/ Edward A. Machulak

---------------------------------------    ------------------------------
By:  Edward A. Machulak, President         By:  Edward A. Machulak, President


Accepted by:


MACHULAK, ROBERTSON & SODOS, S.C. (Law Firm)

/s/ John E. Machulak

--------------------------------------------
By:  John E. Machulak, Authorized Signer
Date:  April 8, 2009