Mail Stop 4561


								October 13, 2005


By U.S. Mail and facsimile to 740-435-2021

Mark A. Severson
Chief Financial Officer
Camco Financial Corporation
6901 Glenn Highway
Cambridge, Ohio  43725

Re:	Camco Financial Corporation
	Form 10-K for the Fiscal Year Ended December 31, 2004
	File No. 000-25196

Dear Mr. Severson:

      We have reviewed your response letter dated September 23,
2005
and have the following additional comments.

Item 9A. Controls and Procedures, page 75

1. We note your supplemental response to comment 1 of our letter
dated September 8, 2005.  Please tell us the basis for your
officers`
conclusions that your disclosure controls and procedures were
effective as of December 31, 2004 in light of this material
weakness
that you assert could result in materially misstated financial
statements.  Refer to paragraph D of SEC Release No. 33-8238, in
particular the Staff`s view that disclosure controls and
procedures
will include those components of internal control over financial
reporting that provide reasonable assurances that transactions are
recorded as necessary to permit preparation of financial
statements
in accordance with generally accepted accounting principles.

2. In your response you state that the identified material
weakness
could have caused the allowance for loan losses to be materially
misstated.  Please tell us the procedures you performed to
mitigate
this material weakness when determining your allowance for loan
losses as of December 31, 2004.

* * * * *

      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 responses to our comments.

      You may contact Matthew Komar, Staff Accountant at (202)
551-
3781 or me at (202) 551-3449 if you have questions regarding
comments
on the financial statements and related matters.



      Sincerely,



      Joyce Sweeney
								Accounting Branch Chief

Mark A. Severson
Camco Financial Corporation
October 13, 2005
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