Mail Stop 4561



November 17, 2005


By U.S. Mail and facsimile to (301) 201-0629.

David R. Brown
Chief Financial Officer
National Mercantile Bancorp
1880 Century Park East
Los Angeles, CA 90067

Re:	National Mercantile Bancorp
Form 10-KSB
	Filed March 31, 2005
	File No. 001-13015

Dear Mr. Brown:

      We have reviewed your response letter filed with the
Commission
on October 7, 2005 and have the following additional comment.
Please
provide us with the requested information so we may better
understand
your response.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may or may not
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.

Financial Statements

Note 13 - Derivatives, page 63

1. We note your response to our comment letter dated September 22,
2005.  Based on your response it appears that you have applied the
shortcut method to assume no ineffectiveness in your $15 million
interest rate swaption designated as a fair value hedge of your
fixed
rate junior subordinated deferrable interest debentures.  Please
provide us with the following with respect to this hedging
relationship:

* More clearly describe the terms of both the hedged item and the
hedging instrument.  For example, describe the terms of the call
options embedded in both the swaption and the hedged item.

* Explain your rationale for using a swaption, rather than a swap,
as
the hedging instrument in this transaction.  For example, explain
what event(s) would cause you to exercise your option to enter
into
the interest rate swap.

* Tell us how you determined the shortcut method of assessing
hedge
effectiveness to be appropriate given the fact that paragraph 68
of
SFAS 133 can only be applied to hedges of interest rate risk
involving an interest rate swap.

* * * * *

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
cover
letter that keys your response to our comment, indicates your
intent
to include the requested revisions in future filings and provides
any
requested supplemental information.  Please understand that we may
have additional comments after reviewing your responses to our
comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

      You may contact Rebekah Moore, Staff Accountant, at (202)
551-
3463 or me at (202) 551-3426 if you have questions.

Sincerely,



Angela Connell
Senior Accountant
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David R. Brown
National Mercantile Bancorp
November 17, 2005
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