Mail Stop 4561
								August 25, 2005

By U.S. Mail and Facsimile to (209) 830-6981

Robert E. Bloch
Executive Vice President and Chief Financial Officer
Service 1st Bancorp
2800 West March Lane, Suite 120
Stockton, California, 95219

Re:	Service 1st Bancorp
	Form 10-KSB for Fiscal Year Ended December 31, 2004
	File No. 000-50323

Dear Mr. Bloch:

      We have reviewed your response filed on August 23, 2005, to
our
comment letter dated August 4, 2005, and have the following
additional comments:

1. Please revise the appropriate section of your document to
include
a discussion of your loan sales activities as set forth in your
response to prior comment 1.
2. Please refer to prior comment 1 and reclassify the cash flows
related to the sale of SBA loans as operating cash flows.   Refer
to
paragraph 9 of SFAS 102.
3. Please refer to prior comment 3.  It remains unclear as to how
your disclosed policy for amortizing the servicing asset using a
method that approximates the level yield method complies with
paragraph 13 of SFAS 140.  Please revise accordingly.
4. Please revise to disclose your policy for identifying and
measuring impairment of your servicing assets.

* * * * *

      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 with your response indicating your intent to provide
the
requested disclosures in future filings.  Please provide us drafts
of
your proposed revisions, where applicable, and any requested
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	You may contact Margaret Fitzgerald at (202) 551-3556 or me
at
(202) 551-3851 if you have questions regarding comments on the
financial statements and related matters.


      Sincerely,



      Paul Cline
      Senior Accountant




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Robert E. Bloch
Service 1st Bancorp
August 25, 2005
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