January 17, 2006
Mail Stop 4561

By U.S. Mail and facsimile to (978) 356-5937

Mr. Donald P. Gill
Chief Executive Officer
First Ipswich Bancorp
31 Market Street
Ipswich, MA  01938

Re:	First Ipswich Bancorp
      Form 10-K for Fiscal Year Ended December 31, 2004
	File No.  333-114018

Dear Mr. Gill:

      We have limited our review of your filing to the issue we
have
addressed in our comments. Where indicated, please provide us with
the supplemental documentation we requested in response to these
comments.  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.

Form 10-KSB

Item 3.  Legal Proceedings, page 23

1. Please provide us with the details surrounding the
Massachusetts
Department of Environmental Protection`s findings against the bank
and non-compliance concerning a parking lot behind the bank`s main
office. Your discussion should include but not be limited to the
following:

* The circumstances of the findings and non-compliance;

* The status of the "down-gradient property status" revised
application and the impact to the Bank if this status is not
granted;

* The methodology and assumptions for determining the amount of
your
portion of the liability and the amount accrued;

* How you considered SFAS No. 5, paragraphs 8 - 19 with respect to
any loss and/or gain contingencies recorded in your December 31,
2003
and 2004 consolidated financial statements, and

* How you considered the guidance provided in SOP 96-1 and SAB
Topic
5-Y and why you believe you have fully complied with the guidance
and
continue to believe your presentation is appropriate.

2. Please provide us with the proposed disclosures you will use in
your December 31, 2005 financial statements to meet the
requirements
of Rule 3-10(b) of Regulation S-X if you believe your previous
presentation was not appropriate and/or sufficient.

* * * * *

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested supplemental information.
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 reviewed by the staff to
be
certain that they have provided 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 comment, 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 Paula Smith (Staff Accountant) at (202) 551-
3696
or me at (202) 551-3490 if you have any questions regarding
comments
on the financial statements and related matters.


Sincerely,



							Don Walker
							Senior Assistant Chief
Accountant
Mr. Donald P. Gill, Chief Executive Officer
First Ipswich Bancorp
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