LUSE GORMAN POMERENK & SCHICK
                           A PROFESSIONAL CORPORATION
                                ATTORNEYS AT LAW

                    5335 WISCONSIN AVENUE., N.W., SUITE 780
                             WASHINGTON, D.C. 20015
                                 -------------
                            TELEPHONE (202) 274-2000
                            FASCIMILE (202) 362-2902
                                WWW.luselaw.COM

WRITER'S DIRECT DIAL NUMBER                             WRITER'S E-MAIL
(202) 274-2037                                          lspaccasi@luselaw.com

September 11, 2009

Kathryn McHale
Staff Attorney
United States Securities and Exchange Commission
Washington, D.C. 20549

         Re:      Chicopee Bancorp, Inc.
                  Form 10-K for December 31, 2008
                  Form 10-Q for March 31, 2009
                  Definitive proxy Statement filed April 13, 2009
                  File Number 000-51996
                  -----------------------------------------------

Dear Ms. McHale:

     We are in receipt of your letter dated August 21, 2009  providing  comments
on the  referenced  filing for  Chicopee  Bancorp,  Inc.  (the  "Company").  The
Company's  responses  are set forth below and are keyed to the  staff's  comment
letter.

Form 10-K for the Fiscal Year Ended December 31, 2008.

1.       Please refer to our previous comment 12 in our letter dated April 30,
         2009. As requested, please provide the time horizon over which you
         predict recover of these assets. Please provide additional specific
         detail describing more fully the information considered by management
         in determining that your equity portfolio was not
         other-than-temporarily impaired.

     As the staff was  previously  advised,  in  connection  with  analyzing its
securities portfolio for other than temporary  impairment ("OTTI"),  the Company
monitors the market  performance  of each  security and when a security is in an
unrealized  loss  position  for 12  consecutive  months,  the  security  is then
considered  impaired for purposes of the Company's OTTI assessment.  Thereafter,
such impaired security is reviewed by the Company on at least a monthly basis to
determine if an OTTI has  occurred.  It should be stressed  that during any time
prior to such 12 months of consecutive  loss position of a particular  security,
if  management  has facts or  evidence  that  indicate  the market  value of the
security  will likely not recover in the recovery  period  discussed  below as a
result of issuer credit specific or industry  specific adverse events,  then the
Company will consider the security to have  experienced an OTTI at such time. It
should also be stressed  that the Company is mindful of the  difference  between
reviewing its securities portfolio for "permanent" impairment versus "other than
temporary" impairment and conducts its analysis accordingly.

LUSE GORMAN POMERENK & SCHICK
        A PROFESSIONAL CORPORATION

Ms. Kathryn McHale
September 11, 2009
Page 2

     In response to the staff's  question as to the "time  horizon" over which a
recovery is  projected  for impaired  securities,  the staff is advised that the
Company  generally  utilizes an 18 month  recovery  "time horizon" in connection
with any security which becomes  "impaired"  under its OTTI  analysis.  For each
individual  impaired  security,  the  Company's  OTTI analysis is based upon its
continuing  review of the  fundamentals of the issuer,  analysts  reports on the
industry in which the issuer operates and specific analysts reports and analyses
prepared by its investment advisors on the particular issuer. In making any OTTI
assessment,  the Company will apply the  above-referenced 18 month recovery time
horizon but if there are facts or evidence relevant to the issuer that result in
management  determining  that it is unlikely  for the security to reach at least
85% of its cost within that 18 month recovery period then the Company will write
down such security to fair market value at the time of such determination.

     As to the staff's request for information  upon which the Company relies to
determine whether a security has not suffered an OTTI, management performs their
own  due  diligence  using a  variety  of  resources,  including:  reports  from
Bloomberg,  The Wall Street Journal, Value Line and other financial publications
and financial media contacts,  and the issuer's SEC filings.  The Company relies
on objective and quantitative  indicators as well as some subject  indicators in
conducting the OTTI analysis.  Specific objective  indicators include changes in
an issuer's credit rating,  changes in dividend  payouts,  the issuer's "current
ratio," analyst's upgrades or downgrades on the issuer and analysts  projections
for the  industry  in which the  issuer  operates.  More  subjective  indicators
considered  by the Company  include  changes in  management  of the issuer,  the
overall trends in the market and national and global economies and the potential
effect of legislation, regulation or government action on the issuer.

     As of December 31, 2008, the Company had 37 securities that were identified
as impaired as a result of having experienced an unrealized loss position for at
least 12  months.  Based  upon the  Company's  OTTI  analysis  and review of the
indicators  discussed  above,  its was determined  that such  securities had not
experienced  an OTTI as of December 31, 2008 and the Company  expected that each
such security  would recover to at least 85% of its purchase price within the 18
month recover  period with some projected to recover to that level by the end of
2009.

     The Company has attached updated Exhibit A which lists the securities which
were impaired as of December 31, 2008 and some of the indicators  relied upon by
the Company in performing its OTTI analysis.

2.       Please specifically tell us and disclose in future filings what time
         frame you consider to be the "near term" for purposes of evaluating
         other-than-temporary impairment.

     As  stated  above,  for  the  purposes  of  evaluating  OTTI , the  Company
considers  "near term" to be an 18 month  period.  The Company will  disclose in
future filings such time frame considered to be "near term" for such purposes.


LUSE GORMAN POMERENK & SCHICK
        A PROFESSIONAL CORPORATION

Ms. Kathryn McHale
September 11, 2009
Page 3

3.       Please refer to our previous comment 13 in our letter dated April 30,
         2009. We note your disclosure regarding four of the collateralized
         mortgage obligation bonds. Please specifically clarify whether any of
         the remaining securities are sub-investment grade, or collateralized by
         sub-prime or alt-a loans. Please disclose any additional information
         you may have considered in determining whether these securities were
         other-than-temporarily impaired in addition to whether the interest
         payments are current, i.e., investment grade and changes, default
         rates, the tranche owned by the company as compared to the collateral,
         etc.

     The Company's remaining collateralized mortgage obligations ("CMO") are all
investment  grade  and  classified  as  held-to-maturity  ("HTM").  All of  such
securities   were  issued  by   government   sponsored   agencies  and  are  all
collateralized  primarily by triple AAA rated FHLMC and FNMA mortgage loans and,
to the best of the Company's  knowledge,  are not collateralized by sub-prime or
Alt-A loans..  The Federal National  Mortgage  Association  ("FNMA") and Federal
Home Loan Mortgage  Corporation  ("FHLMC") guarantees the contractual cash flows
of the Company's CMO portfolio.  The loans  collateralizing such CMOs consist of
fixed-rate,  15-year loans,  originated in early 2003 and 2004 with average FICO
scores, for the remaining CMO's, between 700 and 750, and average LTV of 60%.

     These CMO  securities  have been  substantially  paid down with an  average
current  factor of 30%,  and are  backed by well  seasoned  loans of an  earlier
vintage which have not been significantly affected by high delinquency levels or
vulnerable to lower collateral  coverage as seen in later issued pools. All such
CMOs are paying according to their contractual terms are expected to continue to
pay their contractual cash flows.

     The staff is advised that the Company  reviews its CMO  portfolio  for OTTI
similar to its OTTI analysis for its other  securities  whereby it considers the
length of time and the  extent to which the fair  value has been less than cost,
the financial  condition and near-term  prospects of the issuer,  and its intent
and  ability  to  retain  its  investment  in the  issuer  for a period  of time
sufficient  to  allow  for any  anticipated  recovery  in fair  value  or  until
maturity.

     The  Company  continues  to have the  ability  and  intent to hold such CMO
securities until their maturity. It should be noted that such securities are not
significant  to the  Company and it is more likely than not that it would not be
required to sell these investments to meet the Company's liquidity needs.

4.            Please refer to our previous comment 3 in our letter dated June
              22, 2009. We have reviewed the information provided in Exhibits A
              through F. Please address the following:

a.            We note in your response that certain of your analyses incorporate
              lengthy time horizons or rely on indefinite time horizons, such as
              those included in the second and last category of investments in
              Exhibit A and the investments included in Exhibit E. SAB Topic 5M
              states that the phrase other-than-temporary does not mean
              permanent. Additionally, the Staff believes that as the forecasted
              market price recovery period lengthens, the uncertainties inherent
              
LUSE GORMAN POMERENK & SCHICK
        A PROFESSIONAL CORPORATION

Ms. Kathryn McHale
September 11, 2009
Page 4

              in management's estimate increase, which impacts the reliability
              of that estimate. Please tell us whether the use of a more
              reasonable forecast period would materially impact your financial
              statements, either on an annual or interim basis for the periods
              included in your December 31, 2008 Form 10-K, March 31, 2009, and
              June 30, 2009 Form 10-Q.

     The Staff's  comment is noted but  Company  does not agree with the staff's
statement that the Company's analyses "incorporate lengthy time horizons or rely
on indefinite time  horizons." In this regard,  the Company would like to stress
that previously  provided  back-up  information  (which includes analyst reports
that  discuss 3 to 5 year time  horizons or do not set forth  definite  recovery
time  horizons) do not  constitute  the whole of the Company's  OTTI analysis as
such reports and analyses are merely part of the mix of information  the Company
utilized in performing its OTTI  assessments.  In this regard,  while an analyst
report  may  reference  a 3 to 5 year  time  horizon,  the  Company  nonetheless
attempts to determine the projected  recovery of the impaired  security over the
following  18  months  based on all the  information  and  indicators  known the
Company at such time.

     In response to the staff's request for information as to whether the use of
a  more  reasonable  forecast  period  would  materially  impact  the  Company's
financial statements, it appears that the staff may be assuming that the Company
utilized a 3 to 5 year projected recovery period which, as explained above, such
assumption would be incorrect as the Company generally uses an 18 month recovery
period when analyzing impaired securities.

     In response to the staff's comment and for illustration  purposes only, the
Company  performed an  impairment  analysis on its impaired  securities  for the
periods ending  December 31, 2008,  Form 10-K,  March 31, 2009 and June 30, 2009
Form 10-Q and applied a recovery period of 18 months for each security. Pursuant
to such illustrative  impairment analysis, the Company did the following:  1) it
reviewed  all  impaired  securities  existing  at each  period  end,  2) it then
projected the market value that could occur over the following 18 months, 3) for
each such security the projected market value estimate was obtained by using the
high end of the  range of the "1 to 2 year  target  price" as  published  in the
relevant Bloomberg Consensus Value Line report ("Value Line estimate"), 4) based
on the Value Line estimate it was then determined whether such impaired security
could recover to 85% of its purchase price during the 18 month recovery  period.
When this  analysis is performed at each of the subject  period ends it does not
result  in any of the  Company's  impaired  security  being  subject  to an OTTI
determination and corresponding write-down and, accordingly, application of such
methodology would not materially impact the Company's financial results for such
periods.

     The staff is further  advised that in  connection  with its OTTI review for
the  quarter  ending  September  30,  2009,  to the extent any of the  Company's
impaired  securities  are in a loss  position for greater than 12 months and the
current  Value Line  estimates  do not  indicate  that the market  value of such
securities  could  approach 85% of the purchase price over the relevant 18 month
recovery  periods (or other adverse  developments  have occurred related to such
security), the Company would record the appropriate write-downs on such impaired

LUSE GORMAN POMERENK & SCHICK
        A PROFESSIONAL CORPORATION

Ms. Kathryn McHale
September 11, 2009
Page 5

securities  during the quarter  ending  September 30, 2009 unless  objective and
materially  positive  facts and  circumstances  present  themselves  which would
otherwise reasonably indicate the market value will recover in the short term (3
to 6 months).  Such materially  positive facts and  circumstances  would include
announcements  of the  acquisition  of the issuer for amounts at or in excess of
the Company's purchase price.

b.            On a related note, some of the documentation underlying your
              other-than-temporary analysis, such as the first page of Exhibit
              B, appears to be prepared using a "permanent impairment" model
              rather than an "other-than-temporary impairment" model. Please
              update your analysis accordingly.

     As  stated  in the  response  to  Comment  4(a),  the  previously  provided
information was utilized by the Company in making its OTTI analysis but does not
represent  the whole of such OTTI  analysis.  As also stated in the  response to
Comment  1,  the  Company  is  mindful  of  the  distinction  between  permanent
impairment and other than temporary impairment.

c.       We have also noted that other evidence  included in your analyses is
         vague and includes  assumptions  for which there is no or little
         objective  supporting  evidence  as to  occurrence  or timing,  such as
         certain of the  information  included  in investment 3 in Exhibit E.
         The staff believes that market price recoveries that cannot  reasonably
         be expected to occur within an  acceptable  forecast  period should not
         be included in the  assessment  of  recoverability.  Further,  as the
         severity   and/or   duration  of  the   impairment   increases,   the
         evidence   required  to  support  that  it's  not other-than-temporary
         increases accordingly.  Therefore, please tell us whether you believe
         your assessment of other than temporary  impairment would change if you
         excluded  information  that is not reasonably  expected to occur within
         a more reasonable  recovery period.  Please tell us whether this change
         would have a material impact on your financial  results, either on an
         annual or interim basis for the periods  included in your December 31,
         2008 Form 10-K,  March 31, 2009,  and June 30, 2009 Form 10-Q.

     The staff is directed to updated Exhibit A and to the responses to Comments
1, 2 and  4(a) as to the  reasonableness  of the  recovery  periods  used by the
Company for its OTTI analyses and the impact of the use of such recovery period.

d.            SAB Topic 5m states that a decline in value can occur for various
              reasons, including general market conditions. Therefore, an other
              than temporary impairment may occur on securities that are in an
              unrealized loss position due to factors attributable to general
              market conditions, factors that are issuer specific, or both.
              Please tell us if your assessment of whether an other than
              temporary loss has occurred for those securities that have
              experienced declines in value due to general market conditions,
              such as certain of the securities included in the general
              information for all groups of investments included in Exhibits A
              and B, would change if you considered a decline in general market
              conditions to be other than temporary.

LUSE GORMAN POMERENK & SCHICK
        A PROFESSIONAL CORPORATION

Ms. Kathryn McHale
September 11, 2009
Page 6

         The staff is advised that the Company recognizes that general market
conditions can, by themselves, result in a determination that an other than
temporarily impairment of a particular security has occurred and takes that into
consideration when conducting its OTTI analyses. Updated Exhibit A has been
revised to more clearly indicate the information or indicators relied upon by
the Company, including any projections or assumptions related to the general
market conditions at the time, to determine if an OTTI write down was required
for each reporting period.

         Pursuant to SEC Rule 83, 17 C.F.R. ss.200.83, the Company requests
confidential treatment for each of the attached exhibits. The Company believes
that to release such information would have adverse consequences to its business
and competition position.

         We trust the foregoing is responsive to the Staff's comments. We
request that any questions with regard to the foregoing should be directed to
the undersigned at 202-274-2037.




                                              Sincerely,

                                              /s/ Lawrence M.F. Spaccasi

                                              Lawrence M.F. Spaccasi


cc:      William J. Wagner, Chicopee Bancorp, Inc.
         SEC Freedom of Information and Privacy Act Office
         Marc Levy, Esq.



                                    EXHIBIT A

                             Confidential Treatment
                                    Requested




                                    EXHIBIT B

                             Confidential Treatment
                                   Requested