Mail Stop 4561
September 20, 2005
By U.S. Mail and facsimile to (515) 576 7962
David W. Edge
Chief Financial Officer, Treasurer
North Central Bancshares, Inc.
c/o First Federal Savings Bank of Iowa
825 Central Avenue
Fort Dodge, Iowa 50501
Re: North Central Bancshares, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2004
Forms 10-Q for the Quarters Ended March 31, 2005 and June 30, 2005
File No. 000-27672
Dear Mr. Edge:
We have limited our review of your filing to the issue we
have
addressed in our comments. Please be as detailed as necessary in
your explanation. In some of our comments, we may ask you to
provide
us with information so we may better understand your disclosure.
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 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-Q for the Fiscal Quarter Ended June 30, 2005
Management`s Discussion and Analysis - Executive Overview, page 7
1. We note that you recorded a $255,000 and $424,500 other-than-
temporary impairment in the first and second quarter of 2005,
respectively, relating to your investment in FHLMC preferred
stock.
Your unrealized losses on your investment were $921,500 and
$499,000
at December 31, 2004 and 2003, respectively. Please tell us how
you
were able to conclude that no other-than-temporary impairment
relating to these securities existed as of or prior to December
31,
2004.
2. Pease tell us how you determined the amounts of the $255,000
and
$424,500 impairment charges and tell us how long the preferred
stock
was in an unrealized loss position. Please refer to the specific
relevant guidance in SFAS No.115 and SAB Topic 5:M in your
response.
* * * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please file
your
response on EDGAR. 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 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 comments on your filing.
You may contact Matthew Komar (Staff Accountant) at (202)
551-
3781 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
David W. Edge
North Central Bancshares, Inc.
September 21, 2005
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