| WRITER’S DIRECT DIAL NUMBER | WRITER’S E-MAIL |
| (202) 274-2004 | slanter@luselaw.com |
| Re: | West End Indiana Bancshares, Inc., Registration Statement on Form S-1 filed July 12, 2011; File No. 333-175509 | ||
| Response to Comment Letter Dated October 31, 2011 |
| 1. | We note that pre-effective amendment no. 2 does not include the prospectus registering the offer and sale of the participation interests of the West End Bank, S.B. 401(k) plan. Please include the prospectus in future amendments. | |
A prospectus supplement registering the offer and sale of the participation interests of the West End Bank, S.B. 401(k) plan is included in Pre-Effective Amendment No. 3 to the Company’s Registration Statement on Form S-1. |
| Exhibit 8.1 | ||
| 2. | We note the last sentence of the first paragraph on page 2. Counsel may not disclaim an obligation to update or supplement its opinion. Please arrange for counsel to revise accordingly. | |
| The federal tax opinion has been revised in response to the comment. | ||
| Exhibit 8.2 | ||
| 3. | Please arrange for BKD to revise its opinion in a manner consistent with comment 2. | |
| The state tax opinion has been revised in response to the comment. | ||
| Sincerely, | ||
| /s/ Steven Lanter | ||
| Steven Lanter |
| Enclosures | |
| cc: | John P. McBride |
| Kip A. Weissman, Esq. | |
