[LETTERHEAD OF FNB BANCORP]

November 1, 2007


Mr. John P. Nolan
United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 4561
Washington, D.C.  20549


Dear Mr. Nolan:


The Chief Executive Officer and Chief Financial Officer are responsible for the
accuracy and adequacy all disclosures in all filings with the Securities and
Exchange Commission. Our responsibilities include:

         o        We are responsible for the adequacy and accuracy of the
                  disclosure in each filing;

         o        Staff comments or changes to disclosure in response to staff
                  comments do not foreclose the Commission from taking action
                  any action with respect to the filing; and

         o        We 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.

Enclosed with this letter is a copy of our amended Form 10K filing for 2006 that
includes the revised language in our accountant's opinion as it relates to their
audit of our internal controls over financial reporting.

If you have any questions, please contact David Curtis, CFO at (650) 875-4862.


Sincerely,


/s/ Tom McGraw                            /s/ David Curtis
- ------------------------------------      --------------------------------------
Tom McGraw, CEO                           David Curtis, CFO