April 3 2007
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Bancorp Rhode Island, Inc. (the “Company”) Preliminary Proxy Statement on Schedule 14A Filed March 1, 2007 by PL Capital Group File No. 001-16101 |
| “Tandy” Statement |
Ladies and Gentlemen:
Each member of PL Capital Group, which consists of PL Capital Group (“PL Capital”), which consists of Financial Edge Fund, L.P.; PL Capital, LLC; Goodbody/PL Capital, LLC; Financial Edge-Strategic Fund, L.P.; PL Capital/Focused Fund, L.P.; PL Capital Offshore, Ltd.; Goodbody/PL Capital, L.P.; PL Capital Advisors, LLC; Richard J. Lashley; and John W. Palmer (each a “Filing Person”), in response to the comments of the Staff of the Securities and Exchange Commission (the “Staff”) commenting on the above-referenced preliminary proxy statement and form of proxy (collectively, the “Proxy Statement”) for use in conjunction with an annual meeting of shareholders of Bancorp Rhode Island, Inc., hereby acknowledge that:
| • | Each Filing Person is responsible for the adequacy and accuracy of the disclosure in the Proxy Statement; |
| • | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Securities and Exchange Commission from taking any action with respect to the Proxy Statement; and |
| • | Each Filing Person may not assert Staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or any person under the federal securities laws of the United States. |
| Very truly yours |
| FINANCIAL EDGE FUND, L.P. | ||
| By: PL CAPITAL, LLC | ||
| General Partner | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
| FINANCIAL EDGE-STRATEGIC FUND, L.P. | ||
| By: PL CAPITAL, LLC | ||
| General Partner | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
| PL CAPITAL/FOCUSED FUND, L.P. | ||
| By: PL CAPITAL, LLC | ||
| General Partner | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
| PL CAPITAL OFFSHORE, LTD. | ||
| By: PL CAPITAL ADVISORS, LLC | ||
| Investment Manager | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Director | Director | |
| GOODBODY/PL CAPITAL, L.P. | ||
| By: GOODBODY/PL CAPITAL, LLC | ||
| General Partner | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
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| GOODBODY/PL CAPITAL, LLC | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
| PL CAPITAL ADVISORS, LLC | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
| PL CAPITAL, LLC | ||
| By: /s/ John W. Palmer | /s/ Richard J. Lashley | |
| John W. Palmer | Richard J. Lashley | |
| Managing Member | Managing Member | |
| By: | /s/ John W. Palmer | |
| John W. Palmer | ||
| By: | /s/ Richard J. Lashley | |
| Richard J. Lashley | ||
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