July 1, 2005 Mail Stop 4561 By U.S. Mail and facsimile to (724) 978-2744 Mr. Charles G. Urtin President and CEO IBT Bancorp, Inc. 309 Main Street Irwin, PA 15642 Re:	IBT Bancorp, Inc. Form 10-K for fiscal year ended December 31, 2004 Forms 10-Q for fiscal quarter ended March, 31 2005 File No. 1-31655 Dear Mr. Urtin: We have reviewed your response letter dated June 30, 2005 and have the following additional comment. Form 10-K Allocation of the Allowance for Loan Losses, page 11 1. We read your June 30, 2005 response to our June 16, 2005 comment letter. We are not yet able to understand the changes in your allowance which resulted in a substantially smaller allowance at December 31, 2004 since: * Loans have increased from December 31, 2003 to December 31, 2004; * You stated that there were no specific impairment allowances at December 31, 2003 for the significant loans charged off in 2004, and * You stated in your June 13, 2005 response to our June 3, 2005 comment letter that the overall quality of the loan portfolio did not change significantly from 2003 to 2004. We are also unable to reconcile your fifth response in your June 30, 2005 response to our June 16, 2005 comment letter that there were no specific impairment allowances at December 31, 2003 with the $283,781 specific impairment allowance in the December 31, 2004 audited financial statements. 	Please provide us with a quantitative and qualitative analysis which shows how 	you applied your allowance methodology in a consistent fashion to your loan 	portfolios at each of December 31, 2004 and December 31, 2003. Your analysis 	should clearly demonstrate how you determined that the December 31, 2004 	allowance and the related provision for the year of $600,000 were appropriate 	even though you charged off $777,916 and $409,651 for two major loans for 	which you had not made specific impairment provisions in prior periods. In your 	response, consider the documentation requirements set forth in the FFIEC Policy 	Release on Allowances for Loan and Lease Losses dated July 2, 2001. * * * * Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your responses to our comment and provide any requested supplemental information. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your response to our comments. You may contact Paula Smith, Staff Accountant at (202) 551- 3696 or me at (202) 551-3490 if you have questions regarding comments on the financial statements and related matters. 	Sincerely, 	Don Walker 	Senior Assistant Chief Accountant ?? ?? ?? ?? Charles G. Urtin, President and CEO IBT Bancorp, Inc. Page 1 of 2