August 2, 2006

MAIL STOP 3261

via U.S. mail and facsimile

Robert L. McKean, President and CEO
Albina Community Bancorp
2002 N.E. Martin Luther King, Jr. Blvd.
Portland, Oregon 97212

Re:      Albina Community Bancorp
      Form 1-A, filed June 19, 2006 File No.:  24-10150
      Comments supplemental to those issued on July 21, 2006

Dear Mr. McKean:

	We have the following supplemental comments on your filing.
We
first issued comments on this filing on July 21, 2006.  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 comments are 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 supplemental
information so we may better understand your disclosure.  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 on any other
aspect
of our review.

Credit Risk Management and Allowance for Loan Losses, page 43
1. We note your provision for loan losses has significantly
decreased
from $450,000 in the year ended December 31, 2004 to $0 for the
period ended March 31, 2006.  Please revise to provide a
discussion
for each period presented to describe the factors which influenced
your judgment in determining the amount of each provision for loan
losses in accordance with Instruction 2 to Item IV of Industry
Guide
3.
2. On page 45 you disclose that you allocate your allowance based
upon the evaluation of past history and the composition of the
loan
portfolio.   However, in your description of the methodology used
for
determining the allowance, you state that in addition to prior
loan
loss experience, factors based on current and anticipated economic
conditions, industry concentrations and the overall quality of the
portfolio are used.  Please revise this discussion and the
significant accounting policies discussion on F-11 to explain:

* How you determine each component of the allowance, including the
specific, general and unallocated allowances, as applicable,
* Which loans are evaluated individually and which loans are
evaluated as a group, and
* Describe how the allowance is allocated among the portfolio by
category of loans.

Closing Comments

      As appropriate, please amend your offering statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment 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.

      You may contact Brian Bhandari at (202) 551-3390 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Susann Reilly at (202) 551-3236 with
other
questions.

Sincerely,



John Reynolds
Assistant Director
Office of Emerging Growth Companies

cc:  Gordon Crim, Esq.
	503-221-0607
Albina Community Bancorp
August 2, 2006
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