Mail Stop 4561
September 2, 2005
By U.S. Mail and facsimile to 810-987-0079
Timothy D. Regan
Chief Financial Officer
Citizens First Bancorp Inc.
522 Water Street
Port Huron, MI 48060
Re: Citizens First Bancorp Inc.
Form 10-K for the Fiscal Year Ended December 31, 2004
File No. 000-32041
Dear Mr. Regan:
We have limited our review of your filing to the issue we
have
addressed in our comments. Where indicated, we think you should
revise your document in response to these comments. 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. 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-K for the Fiscal Year Ended December 31, 2004
Note 3 -Securities, page 60
1. We note that as of December 31, 2004 your unrealized losses
over
twelve months on equity securities were $1.1 million and are
related
to preferred stock issued by FHLMC. Please provide us with your
comprehensive analysis supporting your conclusion that your
investment in FHLMC preferred stock is not other than temporarily
impaired as of December 31, 2004. Please refer to SAB Topic 5M
and
address the following in your analysis:
* Duration of impairment;
* The current increasing trend in interest rates;
* The financial condition and near-term prospects of the issuer,
including any specific events which may affect the future earnings
potential of the issuer; and
* Your estimate of the forecasted period of time sufficient to
allow
for any anticipated recovery in market value.
Item 15. Exhibits and Financial Statement Schedules, page 79
2. Your Form 10-K/A filed on April 28, 2005 did not include
Section
1350 Certifications of the Chief Executive Officer and Chief
Financial Officer. Please revise your Form 10-K to include these
certifications and re-submit Exhibits 23, and 31 with your amended
Form 10-K.
* * * * *
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
Timothy D. Regan
Citizens First Bancorp Inc.
September 2, 2005
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