LAW OFFICES OF
KELLER ROHRBACK L.L.P.
- --------------------------------------------------------------------------------
LAURIE B. ASHTON + P > C
IAN S. BIRK
STEPHEN R. BOATWRIGHT + > C
KAREN E. BOXX C
JOHN H. BRIGHT
GRETCHEN FREEMAN CAPPIO
JASON P. CHUKAS
T. DAVID COPLEY #
ALICIA M. CORBETT + > C
CLAIRE CORDON
SHANE P. CRAMER # C
ROB J. CRICHTON -
CHLOETHIEL W. DEWEESE
MAUREEN M. FALECKI !
JULI FARRIS ! /
RAYMOND J. FARROW
DANIEL S. FRIEDBERG < C
GLEN P. GARRISON S
LAURA R. GERBER
GARY A. GOTTO + > C
MARK A. GRIFFIN
AMY N.L. HANSON <
IRENE M. HECHT
SCOTT C. HENDERSON
TOBIAS J. KAMMER
RON KILGARD + > C
BENJAMIN J. LANTZ
HEIDI LANTZ
CARI CAMPEN LAUFENBERG
ELIZABETH A. LELAND
TANA LIN ? ** /
DEREK W. LOESER
DAVID R. MAJOR
JOHN MELLEN ?
ROBERT S. OVER * /
AMY PHILLIPS
LORRAINE LEWIS PHILLIPS
ERIN M. RILEY <
PAUL M. ROSNER
DAVID J. RUSSELL
MARK D. SAMSON + > C
LYNN LINCOLN SARKO / <
FREDERICK W. SCHOEPFLIN
WILLIAM C. SMART
THOMAS A. STERKEN
BRITT L. TINGLUM <
LAURENCE R. WEATHERLY
MARGARET E. WETHERALD -
AMY WILLIAMS-DERRY
MICHAEL WOERNER
BENSON D. WONG

+ ADMITTED IN ARIZONA
# ALSO ADMITTED IN ARIZONA
! ALSO ADMITTED IN CALIFORNIA
P ALSO ADMITTED IN COLORADO
S ALSO ADMITTED IN IDAHO
? ALSO ADMITTED IN ILLINOIS
* ALSO ADMITTED IN MARYLAND
** ALSO ADMITTED MICHIGAN
" ALSO ADMITTED IN NEW YORK
- - ALSO ADMITTED IN OREGON
/ ALSO ADMITTED IN WASHINGTON, D.C.
< ALSO ADMITTED IN WISCONSIN
> NOT ADMITTED IN WASHINGTON
C OF COUNSEL

November 14, 2006

Mr. Todd K. Schiffman
U.S. Securities and Exchange Commission
Division of Corporate Finance, #7 Financial Services
100 F Street NE
Washington, DC 20549

Re: WSB Financial Group, Inc.
Amendment No. 3 to Registration Statement on Form S-1
File No. 333-137038

Dear Mr. Schiffman:

This letter accompanies the above-referenced filing and responds to
your letters, dated November 9, 2006, to David K. Johnson, President and Chief
Executive Officer of WSB Financial Group, Inc., relating to the Registration
Statement on Form S-1, File No. 333-137038.

We are filing Amendment No. 3 today on Edgar in response to these
comments. Four marked copies of Amendment No. 3 are enclosed to expedite your
review.

General

1. We note that the marked copy you provided us does not show all changes
to the document from the previous registration statement. Please
provide marked copies that show all additions and deletions.

Response: We believe that we provided you with the same format for
marked changes that we provided with Amendment No. 1, which shows all addtions
and where all deletions were made in the document, without showing the deleted
language that appeared in the previous document. We understand that this is the
standard format provided by Bowne and other financial

REPLY TO: 1201 THIRD AVENUE SUITE 3200 SEATTLE, WASHINGTON 98101-3052
TELEPHONE: (206) 623-1900 FAX: (206) 623-3384

WWW.KELLERROHRBACK.COM

AFFILIATED OFFICE: KELLER ROHRBACK PLC 3101 N. CENTRAL AVENUE, SUITE 900
PHOENIX, ARIZONA 85012 (602) 248-0088 FAX (602) 248-2822

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 2

printers for courtesy copies. In any event, we are supplementally providing to
the Staff, another set of four marked copies of Amendment No. 2, prepared by
Bowne, which show all additions and deletions from the previous document, as
requested.

Cover Page

2. We note that you have added disclosure regarding the directed share
program. Please revise your statement in the first paragraph that all
shares will be purchased by underwriters to exclude up to 325,000
shares reserved for sale to your directors, officers, employees and
others.

Response: We have declined to modify the disclosure as suggested in
the comment because all shares, including those to be reserved for sale in the
directed share program (the "DSP"), offered by the prospectus will be purchased
by the underwriters. If and to the extent that any shares reserved for sale in
the DSP are sold to participants therein, the underwriters will purchase such
shares from the company at the initial public offering price, and will not
receive any underwriting discount or commission on the sale of such shares.

3. We note the addition of footnote 1 in which you assume that none of
the 325, 000 shares offered for sale under the directed share program
will be sold to directors, officers, employees and others though the
directed share program. Please advise us as to your basis for this
assumption and explain why you have reserved the shares if you believe
none will be purchased. Otherwise, please revise the disclosure, on
the cover, in the summary and elsewhere, to assume that all of these
shares will be purchased by management and others for whom you are
reserving the shares.

Response: Neither the company nor the underwriters have received or
solicited, nor expect to receive or solicit, binding indications of interest
from proposed participants in the DSP. The company cannot be certain if any of
the shares reserved for sale in the DSP will actually be sold to participants
therein. Consequently, the company believes it is prudent and appropriate
disclosure to assume that none of the shares reserved in the DSP will be sold to
participants therein.

As noted above in response to comment 2, if and to the extent that
shares reserved for sale in the DSP are sold to participants in the program, the
underwriters will purchase such shares from the company at the initial public
offering price, and will not receive any underwriting discount or commission on
the sale of such shares. We have revised footnote (1) to the table on the cover
page to note that, if all shares reserved for sale in the DSP are sold to
participants in the program, then the company will receive additional proceeds
(equal to the product of 325,000 shares times the underwriting discount), and
the underwriting discount will be reduced by an equivalent amount.

Because ultimate participation in the DSP is uncertain, we
respectfully submit that modifying the disclosure to assume that all reserved
shares will be purchased by participants in the DSP would be misleading. As
noted above, because participation, if any, in the DSP will result in an
increase in gross proceeds to the company (albeit in a relatively immaterial
amount), the company believes that assuming no participation in the DSP is the
more conservative and appropriate disclosure.

WSB Financial Group, Inc., page 1

4. We note your response, on page 1, to comment 1 of our letter to you
dated October 27, 2006. Please revise this section as follows:

- as we have requested, revise your claim, in the first paragraph
and similar claims elsewhere, that you have "an array of
commercial bank and real estate lending products" to state, as
the FDIC states in its CRA Performance Evaluation, that your
primary business is real estate lending;

Response: We respectfully submit that our disclosure is accurate and
is balanced by the insertion of the percentage of our loans comprised of real
estate collateral. The company's subsidiary, Westsound Bank, is a Washington
chartered commercial bank offering an array of commercial bank and real estate
lending and deposit products, including, for example, checking and savings
accounts, CDs, IRAs, money market accounts, personal lines of credit, debit and
credit cards, online banking and bill pay, business loans and lines of credit,
cash management, auto loans, as well as commercial and residential real estate
loans. Further, the company's current levels of concentrations in real

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 3

estate loans, including construction and development loans, are not unique in
Washington. According to the FDIC's Fall 2006 report, Washington banks have the
fourth-highest median concentration of CRE loans to Tier 1 capital and the
third-highest concentration in C&D loans in the nation. We have attached a
spreadsheet showing the real estate concentrations of publicly-traded banks in
Washington, Oregon and Idaho. Four of the nineteen banks have real estate
concentrations over 80% and fourteen of the nineteen have real estate
concentrations over 70% of total loans. For example, Frontier Financial
Corporation (FTBK), one of WSB Financial Group's competitors which has more than
$2 billion in assets, has 88.3% real estate loans, Cascade Financial Corporation
(CASB) has 80.4%, City Bank (CTBK) has 95%, and Horizon Financial Corp. (HRZB)
has 84%. Like the company, all of these banks describe their banking business
generally, based on the range of loans and deposits that they offer their
business customers and consumers.

Additionally, the company's concentrations related to real estate,
which the FDIC report you cite is also referring to when it states the company's
primary business is real estate lending, are fully disclosed in the Summary,
Risk Factors, and MD&A sections.

- as we requested, revise the first paragraph to supplement your
disclosure of net loans to disclose that all, or virtually all,
of the loans relate to real estate located in the west Puget
Sound area of Washington state and most are located in Kitsap
County;

Response: We have included this disclosure in page 1 of the Amendment.

- disclose in the second paragraph the number of branches located
in the west Puget Sound area and the number that are located
outside the State of Washington;

Response: We have modified disclosure in page 1 of the Amendment, to
address this comment.

- revise your claim in the third paragraph regarding your being the
"fastest growing bank in the Pacific Northwest" to clarify that
it is based on the percentage of growth not real dollar growth
and provide us with the basis for your claim;

Response: As requested, a spreadsheet is attached that includes the
asset data reported to the FDIC for all banks formed in 1999 or earlier located
in Washington, Oregon and Idaho and their CAGR and absolute growth rates from
December 31, 2001 to June 30, 2006 (the most recent publicly available data for
all banks). By either measure, the company was clearly the fastest growing bank
in these states over the past five years on a percentage growth basis. This data
is publicly available on the FDIC's website for each of the individual banks.

- revise your claim, in the fifth paragraph, that you offer a full
range of other lending products and services to disclose the
percentage of your loans that are commercial and industrial and
the percentage that are consumer; and

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 4

Response: We have included the additional information in page 3 of the
Amendment

- disclose, in the sixth paragraph and in the related risk factor
on page 16, the percentage of shares that will be beneficially
owned by directors and executive officers assuming that they
purchase all of the shares reserved in the directed offering and
that they exercise all their options and disclose the number of
shares reserved for future issuance under your option plan;

Response: We have included disclosure on page 1 and the related risk
factor that sets forth the percentage of shares that the directors and executive
officers will beneficially own, assuming that they exercise all their options.
We also have disclosed the number of shares reserved for future issuance under
the company's option plan.

We supplementally advise the staff that the company currently expects
to invite over 540 persons - including directors, employees, existing
shareholders, business associates, and other parties - to participate in the
DSP. The company expects to reserve an aggregate of approximately 90,000 shares
in the DSP for sale to existing officers and directors. If all directors and
officers purchase their full allotment of the shares proposed to be allocated to
them in the DSP, their beneficial ownership of the company would increase, in
the aggregate, by less than 1%. If and to the extent that any of our officers or
directors, or all of them, purchase their respective full allotments of shares
in the DSP, we respectfully submit that the increase in beneficial ownership of
the company as a result of their participation in the DSP would be immaterial to
investors in this offering.

Our Market Area, page 3

5. Please revise this section, and similar disclosure elsewhere, as
follows:

- revise the first sentence to clarify that all of your operations
are located in the west Puget Sound area and most are located in
one county;

Response: We have deleted the word "primarily" in this sentence, and
clarified this sentence in page 3 of the Amendment to describe the location of
our operations more precisely, but to say that most of our operations are
located in one county is just not true. The company currently has operations in
six counties (Kitsap, Clallam, Pierce, King, Mason and Jefferson counties) with
full-service branches in three (Kitsap, Clallam and Pierce) and expects to have
a branch in Federal Way in King County by December, 2006.

The company's management has reviewed its branch deposits as of
September 30, 2006 and June 30, 2004 and June 30, 2002 to see what has changed
over the years. As stated in the S-1 registration statement, 69% of the
company's deposits are located in the four branches (out of 7 total) currently
operated in Kitsap County. That compares to 79% at June 30, 2004 in three
branches in Kitsap County (out of 4 total) and 100% of its deposits at June 30,
2002 in two branches in Kitsap County (out of 2 total).

In addition, other smaller publicly-traded banks in the region have
similar geographic concentrations as the company and they all describe their
market area much more broadly than the one county that they are concentrated in
as of June 30, 2006. Washington Banking Company (WBCO) has 57% of its deposits
in Island County and 42% of its branches in that county. United Financial Corp.
(UBMT) has 57% of its deposits in Cascade County (MT)

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 5

and 23% of its branches in that county. Horizon Financial (HRZB) has 67% of its
deposits in Whatcom County and 47% of its branches in that county. Heritage
Financial (HFWA) has 43% of its deposits in Thurston County and 29% of its
branches in that county. Cowlitz Bancorporation (CWLZ) has 70% of its deposits
in Cowlitz County and 44% of its branches in that county. City Bank (CTBK) has
82% of its deposits in Snohomish County and 75% of its branches in that county.
This compares to 69% of WSB Financial's deposits in Kitsap County and 57% of its
branches (or 40% of the company's total locations including loan production
offices) in that county.

- explain your statement, in the second sentence, that "we have
expanded our footprint" to the Oregon border;

Response: We have clarified this statement in page 3 of the Amendment.

- supplement your statement, in the second paragraph that 69
percent of your deposits are in Kitsap County to disclose the
percentage of your loans originated in that county;

Response: We have added this disclosure in page 3 of the Amendment.

- balance your statement, in the second paragraph, regarding the
"national attention" that Kitsap County has received for its
"economic success" to disclose that, according to the CRA
Performance Evaluation, the median family income in the county is
$62,000; and

Response: We made this change in page 3, as requested. We also note
that Kitsap County ranks 6th out of the 39 Washington counties in median family
income, and is the 3rd most densely populated county.

- revise your claim, in the second paragraph, that Bremerton is
"one of the top 5 up and coming hot cities" to disclose that this
designation was made in an article in Money Magazine in June 2004
and was limited to cities with a population under 250,000
persons.

Response: We have revised the magazine article we reference on page 3
to only include the Inc. magazine reference, which is a more recent article. We
have added additional language to that description both in page 3 and in page 58
of the Business section.

The Offering, page 5

6. Please revise this section as follows:

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 6

- disclose the number of shares that you have reserved for sale to
directors, officers, employees and others; and

- disclose the aggregate number of shares that they presently
intend to purchase.

Response: We have revised the reference to the DSP on page 5 to refer
to the number of shares reserved for sale in the DSP.

As noted above in response to comment 3, neither the company nor the
underwriters have received or solicited, nor expect to receive or solicit,
binding indications of interest from proposed participants in the DSP. The
company cannot be certain if any of the shares reserved for sale in the DSP will
actually be sold to participants therein. Consequently, the company cannot
revise the disclosure as suggested in the second bullet of comment 6 because the
company does not presently know, and will not know until after the registration
statement is declared effective and the offering has been priced, who will
participate in the DSP and how many shares each participant will propose to
purchase in the offering.

7. We note your response, in the second risk factor on page 11, to
comment 9 of our letter to you dated October 27, 2006. As we
requested, please revise both the caption and the text to clarify that
the FDIC required your Board enter into the MOU to correct both the
violations of law and the deficiencies in internal controls.

Response: We have made these changes in page 11, as requested.

Risks Relating to the Offering, page 14

8. We note the changes you have made to the risk factor, on the bottom of
page 15, relating to the lock up agreements. Please revise as follows:

- change the caption to reflect the fact that some of the lockups
are only for 60 days not 180; and

- state that you have agreed to release Mr. Parr from the lock up
if the market price exceeds the initial offering price by 20
percent for ten consecutive trading days.

Response: We have included the additional disclosures in page 15 of
the Amendment.

Dilution, page 20

9. Please revise your discussion in the last paragraph and in the related
risk factor on page 16, of the dilution that would result from stock
issued pursuant to options as follows:

- disclose your intent, immediately after this offering is
completed, to register over 1.3 million shares for issuance upon
exercise of stock options; and

- calculate the dilution as if all outstanding options were
exercised.

Response: We have referenced the S-8 registration statement and
provided the numbers of outstanding and reserved shares to address the first
bullet point, and included the requested calculation of dilution on a
fully-diluted basis, in page 20 of the Amendment.

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 7

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page 21

10. Please provide analysis, in the third paragraph on page 21, regarding
your various sources of revenue, and the percentage of revenue from
each source.

Response: We have included this additional information on page 21 of
the Amendment, as requested.

11. We note your response, in the third paragraph on page 21, to comment
12 of our letter to you dated October 27, 2006 and comment 20 of our
letter to you dated September 27, 2006. Please revise the second
sentence to disclose the percentage of your loans that are consumer
loans.

Response: We have included this information, as well as the percentage
for C&I loans, in the third sentence of this paragraph on page 21 of the
Amendment.

Key Factors in Evaluating Financial Condition and Results of Operations, page 23

12. As we requested in comments regarding the summary in our letters to
you dated September 27, 2006 and October 27, 2006, please disclose, in
this section, the business section and elsewhere in the document, the
growth each year rather than the compound annual growth rate ("CAGR").

Response: We have removed all references to a compound annual growth
rate ("CAGR") throughout the document, specifically in the MD&A and Business
sections, on pages 23, 24, 56 and 57 of the Amendment.

Kitsap County, page 57

13. Please disclose percentage of loans and the percentage of your
deposits that are from Kitsap County. In addition, disclose that,
according to the CRA Performance Evaluation, the median family income
in the county is $62,000.

Response: We have included these additional disclosures in pages 57
and 58 of the Amendment.

Seattle Metropolitan Area, page 59

14. Please disclose percentage of loans and the percentage of your
deposits that are from the Seattle metropolitan area.

Response: We have modified the language to remove any discussion
regarding origination of loans and deposits in this market. With a branch and a
loan production office

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 8

located in the counties encompassed by the Seattle metropolitan area, we
respectfully submit that our characterization of our bank benefiting from
Seattle economic activity, is accurate, although difficult to quantify.

Our Competition, page 59

15. Please delete your claims, in the second paragraph, that "no reliable
loan market data is available" and "we are one of the leading real
estate lenders in these counties." Please disclose that; according to
the Federal Deposit Insurance Corporation, you rank number 20 of 330
mortgage lenders in Kitsap county with 1.2 percent market share in
number and dollar volume of the county's mortgage lending activity.

Response: We have revised the second paragraph of "-- Our Competition"
to address your concerns about these disclosures, in page 70 of the Amendment.
We were referring primarily to commercial real estate here. We have included the
disclosure about the report for Kitsap County you cite, as requested, which we
note is for consumer home mortgage lending.

Underwriting, page 94

16. Please provide more detail regarding your statement in the fifth
paragraph on page 94 that "if all the shares are not sold at the
initial public offering price, D.A. Davidson may change the offering
price and other selling terms."

Response: We have provided the requested additional detail on page 94
of the Amendment. As with all underwritten offerings, the ultimate public
offering price will be determined based on the demand in the market. This
statement simply reflects the fact that, based on that demand, the offering
price and other selling terms (such as the selling concession, allowance, and
re-allowance) may differ from the price range and other selling terms described
in the preliminary prospectus.

Loans and Allowances for Loan Losses, page F -23

17. Please refer to prior comment 25. Given your assessment that the error
of recording the liability for off-balance sheet commitments in the
allowance was not material, but considering the impact on trends, on
your allowance rollforward and related notes, we believe that the
immaterial errors noted in prior periods should be corrected in order
to comply with GAAP and your presentation as of September 30, 2006.
Please revise accordingly for all periods affected throughout your
registration statement.

Response: We have made all these requested changes in Summary
Financial Data, MD&A and the Financial Statements at pages 6, 7, 22, 41, 45, 46,
F-2, F-13, F-18 and F-30, of the Amendment, and made all related changes in
dollar amounts throughout the Amendment.

Exhibit 23.4

18. Please revise to include the referenced report dates in the consent of
your independent financial consultant.

Mr. Todd K. Schiffman KELLER ROHRBACK L.L.P.
November 14, 2006
Page 9

Response: We have obtained these dates from LC Financial Advisors, LLC
and included the report dates in the consent, as requested.

The updated letter from LC Financial Advisors, LLC and the updated
consents of Moss Adams LLP, Ball & Treger, LLP and LC Financial Advisors, LLC
are attached to Amendment No. 3 as Exhibits 16.1, 23.1, 23.2 and 23.4,
respectively. In addition, the consent of Keller Rohrback L.L.P. is attached as
Exhibit 5.1.

The required statement from the company acknowledging its
responsibility for disclosures in the filing and the status of Staff comments,
is also enclosed.

Please call the undersigned at (206) 224-7585 (direct) with any
questions.

Very truly yours,

/s/ Thomas A. Sterken
----------------------------------------
Thomas A. Sterken

TAS:sjm
Encs: Real Estate Concentrations
Asset Growth Data
Company Acknowledgement
Marked copy of Amendment No. 3

cc w/encs.: Jonathan E. Gottlieb
Margaret B. Fitzgerald

cc: w/o encs.: David K. Johnson
C.J. Voss

LOAN MIX DETAIL 1
(% OF TOTAL LOANS)
-----------------------------------------------------------------------
AG &
COMPANY NAME TICKER CITY STATE C & I COMMERCIAL RE CONSTRUCTION RESIDENTIAL RE CONSUMER OTHER TOTAL RE
- ------------ ------ ---- ----- ----- ------------- ------------ -------------- -------- ----- --------

AmericanWest Bancorporation AWBC Spokane WA 17.5 46.0 13.4 6.7 1.6 15.0 66.0
Banner Corporation BANR Walla Walla WA 16.5 26.2 33.9 16.3 1.7 5.8 76.5
Cascade Bancorp CACB Bend OR 23.5 34.9 29.5 5.7 3.4 3.0 70.2
Cascade Financial Corporation CASB Everett WA 16.3 41.4 26.6 12.4 0.7 2.6 80.4
City Bank CTBK Lynnwood WA 4.8 29.1 62.5 3.4 0.2 0.0 95.0
Columbia Bancorp CBBO The Dalles OR 15.4 30.3 26.1 7.1 2.6 18.8 63.5
Columbia Banking System, Inc. COLB Tacoma WA 29.2 43.7 6.9 8.2 5.0 6.4 58.8
Cowlitz Bancorporation CWLZ Longview WA 28.7 39.5 19.9 10.4 0.9 0.1 69.8
Frontier Financial Corporation FTBK Everett WA 8.6 37.3 43.4 7.6 1.5 2.3 88.3
Glacier Bancorp, Inc. GBCI Kalispell MT 13.4 24.5 24.4 30.2 5.5 2.1 79.1
Heritage Financial Corporation HFWA Olympia WA 13.0 50.0 14.1 12.9 1.0 9.0 77.0
Horizon Financial Corp. HRZB Bellingham WA 14.1 37.9 33.2 12.9 0.5 1.4 84.0
Pacific Continental Corporation PCBK Eugene OR 19.6 49.9 20.2 7.0 2.1 1.3 77.0
PremierWest Bancorp PRWT Medford OR 20.3 40.0 28.2 5.3 2.9 3.4 73.5
Sterling Financial Corporation STSA Spokane WA 16.4 28.2 26.1 22.2 5.0 2.3 76.5
Umpqua Holdings Corporation UMPQ Portland OR 16.4 51.9 20.8 7.1 0.9 2.7 79.9
United Financial Corp. UBMT Great Falls MT 19.3 15.2 23.0 21.2 7.1 13.4 59.4
Washington Banking Company WBCO Oak Harbor WA 8.4 34.3 20.9 16.0 18.1 2.4 71.1
West Coast Bancorp WCBO Lake Oswego OR 18.7 40.2 16.3 14.5 1.5 8.9 71.0

---- ---- ---- ---- --- --- ----
AVERAGE 16.8 36.9 25.7 12.0 3.3 5.3 74.6
MEDIAN 16.4 37.9 24.4 10.4 1.7 2.7 76.5
---- ---- ---- ---- --- --- ----

WSB Financial Group Bremerton WA 5.3 21.2 53.9 18.5 1.0 0.0 93.6

- -------------
1 Data is as of 6/30/2006 for publicly traded peers and 9/30/06 for WSB
Financial Group

<Table>
<Caption>
Total Total
Institution Date Assets Assets Total
Company Name Key Established State ($000) ($000) CAGR Growth
2001Y 6/30/2006

WESTSOUND BANK 1991072 03/17/1999 WA 32,458 301,107 64.1% 827.7%

North County Bank 4050689 04/01/1999 WA 32,867 170,059 44.1% 417.4%
Umpqua Bank 1005874 10/19/1953 OR 1,436,493 7,159,630 42.9% 398.4%
Columbia Community Bank 4050717 04/12/1999 OR 49,365 222,116 39.7% 349.9%
Bank of the Cascades 1004374 02/01/1977 OR 487,961 2,146,115 39.0% 339.8%
Syringa Bank 1030050 02/24/1997 ID 45,750 178,434 35.3% 290.0%
Panhandle State Bank 1007266 05/18/1981 ID 236,827 781,489 30.4% 230.0%
Town Center Bank 1136031 07/21/1997 OR 37,984 125,234 30.4% 229.7%
Pierce Commercial Bank 1974008 12/08/1997 WA 67,232 213,038 29.2% 216.9%
Bank of Clark County 1991059 02/16/1999 WA 92,927 289,872 28.8% 211.9%
Summit Bank 1005665 01/01/1914 WA 18,956 57,874 28.2% 205.3%
Shoreline Bank 4051720 09/15/1999 WA 29,933 90,197 27.8% 201.3%
Prime Pacific Bank NA 1024635 05/22/1995 WA 34,986 98,479 25.9% 181.5%
Pacific Continental Bank 1012493 08/15/1972 OR 309,346 832,844 24.6% 169.2%
ShoreBank Pacific 1023940 05/07/1993 WA 42,242 113,026 24.4% 167.6%
Home Valley Bank 1004419 08/15/1980 OR 68,530 182,820 24.4% 166.8%
Sterling Savings Bank 4103615 01/01/1981 WA 3,038,538 8,041,997 24.1% 164.7%
Viking Community Bank 1023665 07/01/1992 WA 150,918 396,534 23.9% 162.7%
Coastal Community Bank 1032536 04/01/1997 WA 59,894 153,405 23.2% 156.1%
Community First Bank 1014397 12/05/1980 OR 65,716 167,365 23.1% 154.7%
Venture Bank 1009576 05/24/1979 WA 364,581 915,778 22.7% 151.2%
Mountain West Bank 4050900 10/05/1993 ID 343,757 862,345 22.7% 150.9%
NCW Community Bank 4051727 11/01/1999 WA 33,211 82,375 22.4% 148.0%
Citizens Community Bank 1032559 06/18/1997 ID 67,537 163,793 21.8% 142.5%
Bank of Eastern Oregon 1004342 03/03/1945 OR 76,448 182,921 21.4% 139.3%
D. L. Evans Bank 1010689 08/29/1904 ID 264,104 611,761 20.5% 131.6%
Westside Community Bank 1024559 03/29/1995 WA 49,199 110,959 19.8% 125.5%
Bank of Washington 1025158 07/29/1996 WA 67,346 146,877 18.9% 118.1%
Idaho Banking Company 1026247 10/07/1996 ID 100,442 216,406 18.6% 115.5%
F & M Bank 1010111 11/28/1906 WA 238,679 514,202 18.6% 115.4%
Bank of the Pacific 1007881 12/26/1979 WA 243,617 517,270 18.2% 112.3%
Bank of Salem 1023204 02/19/1991 OR 90,323 191,591 18.2% 112.1%
MBank 1024932 12/01/1995 OR 124,620 264,148 18.2% 112.0%
AmericanWest Bank 1004644 04/01/1977 WA 659,310 1,375,704 17.8% 108.7%
Bank of Whitman 1005651 09/29/1977 WA 227,209 472,755 17.7% 108.1%
Albina Community Bank 1024754 12/19/1995 OR 59,523 122,124 17.3% 105.2%

Idaho Independent Bank 1024051 10/11/1993 ID 276,973 559,436 16.9% 102.0%
PremierWest Bank 1022778 06/18/1990 OR 487,061 983,709 16.9% 102.0%
Columbia River Bank 1011873 06/06/1977 OR 482,747 953,769 16.3% 97.6%
Charter Bank 1981019 01/26/1998 WA 137,929 266,810 15.8% 93.4%
People's Bank of Commerce 1981011 03/02/1998 OR 45,068 85,009 15.1% 88.6%
South Valley Bank & Trust 1015144 01/12/1977 OR 280,406 524,070 14.9% 86.9%
State National Bank of Garfield 1009910 01/01/1902 WA 40,409 74,607 14.6% 84.6%
Peoples Bank 1009617 01/07/1921 WA 417,919 771,588 14.6% 84.6%
EvergreenBank 100714 10/01/1971 WA 156,365 286,047 14.4% 82.9%
Oregon Pacific Banking Company 1006055 12/17/1979 OR 86,587 155,228 13.9% 79.3%
LibertyBank 4087975 01/01/1978 OR 449,221 804,119 13.8% 79.0%
Whidbey Island Bank 1004951 07/03/1961 WA 436,899 766,466 13.3% 75.4%
Mt. Rainier National Bank 1022788 07/02/1990 WA 125,820 216,872 12.9% 72.4%
Cashmere Valley Bank 1011031 09/24/1932 WA 439,174 747,758 12.6% 70.3%
Cascade Bank 4073148 01/01/1916 WA 761,941 1,294,017 12.5% 69.8%
Frontier Bank 1005951 09/11/1978 WA 1,791,322 3,022,363 12.3% 68.7%
Bank of Astoria 1005809 12/23/1968 OR 128,414 214,408 12.1% 67.0%
Washington Trust Bank 1004900 11/03/1902 WA 1,898,389 3,168,437 12.1% 66.9%
Community Bank 1013602 06/01/1955 OR 191,428 316,789 11.8% 65.5%
Banner Bank 1008404 1/1/1890 WA 2,081,147 3,391,106 11.5% 62.9%
CityBank 1009626 04/15/1974 WA 590,895 944,028 11.0% 59.8%
West Coast Bank 1011258 01/01/1925 OR 1,434,315 2,291,104 11.0% 59.7%
Horizon Bank 1010277 05/01/1978 WA 745,838 1,190,766 11.0% 59.7%
Fife Commercial Bank 1983022 07/15/1998 WA 52,168 81,802 10.5% 56.8%
Bank of Idaho 1007805 09/25/1985 ID 136,609 212,822 10.4% 55.8%
Columbia State Bank 1024010 08/16/1993 WA 1,489,381 2,319,054 10.3% 55.7%
Kitsap Bank 1011148 08/08/1908 WA 451,972 685,204 9.7% 51.6%
Commerce Bank of Washington, NA 1020935 07/01/1988 WA 529,396 790,391 9.3% 49.3%
Bank of Commerce 1008080 08/01/1959 ID 432,071 637,845 9.0% 47.6%
Security State Bank 1005520 12/26/1903 WA 234,676 344,333 8.9% 46.7%
American Marine Bank 1012462 09/17/1948 WA 250,010 366,590 8.9% 46.6%
Central Valley Bank, NA 1004624 11/01/1962 WA 81,290 118,802 8.8% 46.1%
Valley Bank 1010101 10/01/1973 WA 140,282 202,586 8.5% 44.4%
Yakima National Bank, NA 1136022 08/04/1997 WA 36,324 51,851 8.2% 42.7%
Siuslaw Bank 1014470 01/17/1964 OR 204,274 291,339 8.2% 42.6%
Wheatland Bank 1005720 09/04/1979 WA 111,795 156,704 7.8% 40.2%
Bank of Fairfield 1005373 01/01/1908 WA 90,925 125,089 7.3% 37.6%
Washington First International Bank 1022767 05/15/1990 WA 385,011 526,404 7.2% 36.7%
Inland Northwest Bank 1022493 10/02/1989 WA 192,850 263,028 7.1% 36.4%
First Independent Bank 1002476 02/21/1910 WA 643,678 865,923 6.8% 34.5%

First Heritage Bank 1004412 01/08/1982 WA 102,305 137,572 6.8% 34.5%
Heritage Bank 1014878 01/01/1927 WA 528,082 709,405 6.8% 34.3%
Skagit State Bank 1006885 06/16/1958 WA 402,021 510,956 5.5% 27.1%
Twin River National Bank 1009308 11/15/1979 WA 44,187 55,567 5.2% 25.8%
Farmers National Bank of Buhl 1007873 05/11/1917 ID 262,720 329,692 5.2% 25.5%
Lamont Bank of St. John 1010393 01/01/1908 WA 19,671 24,271 4.8% 23.4%
Mid State Bank 1015482 10/30/1978 WA 36,904 45,492 4.8% 23.3%
Islanders Bank 1009524 07/07/1981 WA 129,609 157,921 4.5% 21.8%
Farmers State Bank 1012509 01/01/1916 WA 13,243 15,987 4.3% 20.7%
Citizens Bank 1005352 10/05/1957 OR 278,507 334,879 4.2% 20.2%
Ireland Bank 1009312 1/1/1892 ID 146,955 173,302 3.7% 17.9%
Farmington State Bank 1009883 05/10/1929 WA 6,070 7,028 3.3% 15.8%
Cowlitz Bank 1010725 05/01/1978 WA 369,471 423,137 3.1% 14.5%
North Cascades National Bank 1005610 12/01/1986 WA 204,942 221,024 1.7% 7.8%
Clackamas County Bank 1011840 01/31/1911 OR 149,055 160,029 1.6% 7.4%
Baker-Boyer National Bank 1005023 11/10/1869 WA 398,932 372,274 -1.5% -6.7%
Community First Bank 1974046 12/30/1997 WA 76,505 70,046 -1.9% -8.4%
Sound Banking Company 1023004 11/01/1990 WA 60,078 54,813 -2.0% -8.8%
Pioneer Trust Bank, NA 1014510 01/01/1924 OR 249,445 223,882 -2.4% -10.2%

------- ------- ----- -----
AVERAGE 334,490 669,139 14.9% 98.4%
MEDIAN 150,918 266,810 13.1% 73.9%
------- ------- ----- -----
</Table>

COMPANY ACKNOWLEDGEMENT

The registrant, WSB Financial Group, Inc. ("Company"), hereby acknowledges
to the U.S. Securities and Exchange Commission ("Commission"), with respect to
the Company's Registration Statement on Form S-1, File No. 333-137038, filed
August 31, 2006, and amendments thereto, as follows:

1. The Company is responsible for the adequacy and accuracy of the
disclosure in the filing;

2. 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

3. 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.

DATED this 14th day of November, 2006.

WSB FINANCIAL GROUP, INC.

By: /s/ David K. Johnson
------------------------------------
David K. Johnson
President and Chief Executive
Officer

WSB GROWTH SUMMARY

2001 TO 9/30/06 2003 TO 2005
2001 2002 2003 2004 2005 9/30/2006 CAGR CAGR
------ ------ ------ ------- ------- --------- --------------- ------------

Assets 32,453 52,760 75,999 137,381 249,943 338,080 63.8% 81.3%
% growth 62.6% 44.0% 80.8% 81.9% 35.3%

Loans 25,254 39,764 58,209 117,588 207,117 306,056 69.1% 88.6%
% growth 57.5% 46.4% 102.0% 76.1% 47.8%

Deposits 28,112 48,017 68,003 123,593 224,167 308,066 65.5% 81.6%
% growth 70.8% 41.6% 81.7% 81.4% 37.4%

LTM Net Income 15 286 631 1,340 2,412 3,537 NM 95.5%
% growth NM 120.6% 112.4% 80.0% 46.6%