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                   [New England Bancshares, Inc. Letterhead]


                                  June 9, 2006



VIA EDGAR
- ---------

Mr. Todd Schiffman
Assistant Director
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549

RE:      NEBS Bancshares, Inc.
         Registration Statement on Form SB-2
         File No. 333-128277

Dear Mr. Schiffman:

         In connection with our filing of the registration statement referenced
above, the Staff requested clarification on our determination that New England
Bancshares, Inc.'s (formerly NEBS Bancshares, Inc.) (the "Company") investment
in the Ultra Short Mortgage Fund and the Ultra Short Fund (collectively, the
"Funds") was "temporarily impaired." Our response dated November 10, 2005,
advised the Staff how we determined that these investments should be accounted
for as temporarily impaired. Additionally, the Company updated the Staff, in a
letter dated April 28, 2006, as to its current determination of the investments
in question. In response to that letter, the registrant had a conference call
with Donald Walker and Nancy Maloney on June 8, 2006, the details of which are
discussed below.

         In preparing the Company's financial statements for the year ended
March 31, 2006, management determined that its investment in the Funds was
"temporarily impaired." As stated in the previous letter, this determination was
based on the following criteria:

         1.      The length of the time and the extent to which the market value
                 has been less than cost;
         2.      The financial condition and near-term prospects of the issuer;
                 and
         3.      The intent and ability of the holder to retain its investment
                 in the issuer for a period of time sufficient to allow for any
                 anticipated recovery in market value.

         During the June 8, 2006 conference call, the Staff informed the Company
that they did not take issue with the "temporarily impaired" determination.
However, it was agreed upon that the Company will continue to assess whether the
investments are temporarily impaired at the end of each quarter and that such
assessment will be reviewed by the Company's independent auditors. In addition,
the Company agreed to include in the notes to its financial statements the

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Mr. Todd Schiffman
U.S. Securities and Exchange Commission
June 9, 2006
Page 2

Company's methodology for determining whether an investment is other than
temporarily impaired, including a discussion of the three criteria above and the
severity of the unrealized losses.

         If you have any questions concerning this submission, please telephone
the undersigned at (860) 253-4021.

                                           Very truly yours,

                                           /s/ David J. O'Connor

                                           David J. O'Connor
                                           President and Chief Executive Officer


DJO/ng
Enclosures
cc:      Donald Walker, Securities and Exchange Commission
         Joyce Sweeney, Securities and Exchange Commission
         Nancy Maloney, Securities and Exchange Commission
         Scott D. Nogles, New England Bancshares, Inc.
         Lawrence M.F. Spaccasi, Esq., Muldoon Murphy & Aguggia, LLP
         Scott A. Brown, Esq., Muldoon Murphy & Aguggia, LLP
         John D. Marsh, Shatswell, MacLeod & Company, P.C.