Mail Stop 4561
								September 19, 2005

By U.S. Mail and Facsimile to (517) 423-5041

Dale L. Chadderdon
Executive Vice President and Chief Financial Officer
United Bancorp, Inc.
205 E. Chicago Boulevard
Tecumseh, MI
49286

Re:	United Bancorp, Inc.
	Form 10-K for Fiscal Year Ended December 31, 2004
      Filed March 15, 2005
	File No. 000-16640

Dear Mr. Chadderdon:

      We have limited our review of your filing to the issue we
have
addressed in our comment.  Where indicated, we think you should
revise your document in response to this comment.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  After reviewing this information,
we
may 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 comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 8-Financial Statements and Supplementary Data, page 14
1. Please amend your Form 10-K to reflect the requirements stated
in
the Securities Exchange Act Rule 12b-23(3)(i) and Part G of the
General Instructions to Form 10-K, regarding the incorporation by
reference.  Please be aware that the information called for by
Part
II of Form 10-K cannot be incorporated by reference from your
definitive proxy statement.  In your amendment, please ensure that
the financial statements are properly filed as an exhibit as
required
by Item 601(b)(13) of Regulation S-K.

       As appropriate, please amend your filing and respond to
this
comment within 15 business days or tell us when you will provide
us
with a response.  Please furnish a cover letter with your
amendment
that keys your response to our comment and provides any requested
information.  Detailed cover letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your amendment and response to our comment.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes 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 comment on your filing.

	You may contact Margaret Fitzgerald at (202) 551-3556 or me
at
(202) 551-3494 if you have questions regarding this comment on the
financial statements and related matters.

      Sincerely,



      Kevin Vaughn
								Accounting Branch Chief

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Dale L. Chadderdon
United Bancorp, Inc.
September 19, 2005
Page 1