June 3, 2005
Mail Stop 0408

By U.S. Mail and facsimile to (724) 978-2744

Mr. Raymond G. Suchta
Chief Financial Officer
IBT Bancorp, Inc.
309 Main Street
Irwin, PA 15642

Re:	IBT Bancorp, Inc
      Form 10-K for Fiscal Year Ended December 31, 2004
      Form 10-Q for Fiscal Quarter Ended March 31, 2005
	File No.  001-31655

Dear Mr. Suchta:

      We have limited our review of your filing to those issues we
have addressed in our comments. Where indicated, please provide us
with the supplemental documentation we requested in response to
these
comments.  Please be as detailed as necessary in your explanation.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K

Nonperforming and Problem Assets - page 8

1. Please provide us with the type and size of loans comprising
the
increase of $2.9 million in the Mortgage category under the
"Accrual
loans which are contractually past due 90 days or more" table.

Analysis of the Allowance for Loan Losses  - page 10

2. Please provide us with the gross amounts of charge-offs and
recoveries by loan type for 2004 and 2003.  In future filings
please
revise the Net (Charge-off)/Recoveries for each loan category to
reflect the gross amounts of the charge-offs and recoveries
separately.  Refer to Item IV.A of Industry Guide III.

Exhibit 13

2004 Annual Report

Results of Operations

Provision for Loan Losses - page 5

3. Please provide us with the details, identifying the size and
amounts, of the specific loans which comprise the increase in the
Mortgage charge-offs of $1.2 million in 2004 and explain what
factors
you considered for determining each charge-off amount.

4. Please tell us what effect the changes in asset quality of the
loan portfolio, specifically but not limited to the increased
charge-
offs and the increase in past-due loans, had on your determination
of
the allowance allocation and provision for 2004.

5. Please describe for us any understandings or agreements you may
have with your regulators concerning future changes in your levels
of
loan loss provision and allowance.

Form 10-Q

Provision for Loan Losses - page 8

6. Please tell us why the effects of the large loan losses
identified
as occurring in the 4th quarter 2004 were not included in the
year-
end 2004 provision but deferred until the 1st quarter 2005.

7. Please tell us the specific loan details and circumstances for
each of the large loan losses identified as occurring in the 4th
quarter 2004.




* * * * *

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information required under the
Securities Exchange Act of 1934 and that they have provided all
information investors require for an informed investment decision.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Paula Smith (Staff Accountant) at (202) 551-
3696
or me at (202) 551-3490 if you have any questions regarding
comments
on the financial statements and related matters.


Sincerely,



							Don Walker
							Senior Assistant Chief
Accountant
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Raymond G. Suchta, Chief Financial Officer
IBT Bancorp, Inc.
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