January 16, 2015


Via EDGAR
Mr. John P. Nolan
Senior Assistant Chief Accountant
Securities and Exchange Commission
Washington DC 20549


Dear Mr. Nolan:

This is in response to your e-mail dated November 19, 2014.  The loan cost*
recovery income and increase in interest income in the second quarter was*
related to two borrowers: Interstate Holdings (Loan 1518) and Robesa*
Investments (Loans 1610 and 1721).*

Interstate Holdings (Loan 1518):*
This loan was originated and funds disbursed on August 13, 2004, in the amount*
of $3,187,500. Payments were made for a period of time, bringing the balance*
down to $3,008,401.  The loan became impaired and went into non-accrual*
status on August 31, 2010.  There were two subsequent writedowns; on March 31,*
2013 in the amount of $1,197,250. and on December 31, 2013 in the amount of*
$616,562.  These writedowns brought the loan balance to $1,194,589.  An*
appraisal completed in June of 2014 reflected a value of $1,750,000, well*
above the loan balance.  OptimumBank paid the 2009 real estate taxes for this*
property in March of 2012, in the amount of $110,664., and paid the 2010 taxes*
in January of 2013, in the amount of $112,681.  These transactions created a*
negative escrow balance of $223,345, which the Bank was required to expense*
under the terms of the Consent Order.  We were also required to accrue expense*
for the 2011 and 2012 taxes, a total of $230,042.*

In 2014 this loan was sold to a new borrower.  Conditions for the sale*
included OptimumBank being reimbursed for the 2009 and 2010 taxes that were*
previously paid, and the new borrower being responsible for paying the 2011,*
2012 and all subsequent taxes.  Therefore, the Bank was able to recover prior*
expenses for the negative escrow balance and the tax* accrual,*
a total of $453,387.*

Robesa Investments (Loan 1610):*
This loan was originated and funds disbursed on April 15, 2004, in the*
amount of $2,250,000.  Payments were made for a period of time, bringing the*
balance down to $2,082,049.  The loan went into non-accrual status on*
December 31, 2010.  There were no writedowns on the loan.  After falling*
behind on payments by approximately nine months, the borrower began making*
regular payments, but never catching up.  As a result, the Bank was unable*
to take the loan out of non-accrual status and take the interest payments*
into income. The principal balance as of May 2014 was $2,012,282.  An*
appraisal completed in April of 2014 reflected a value of $2,250,000.*
The loan was paid off on June 26, 2014.  The Bank was then able to take*
into income $266,166 in prior interest payments on non-accrual loans.*

Robesa Investments (Loan 1721):*
This loan was originated and funds disbursed on November 8, 2006, in the*
amount of $600,000.  Payments were made for a period of time, bringing*
the balance down to $570,536.  The loan went into non-accrual status on*
December 31, 2010.  There were no writedowns on the loan.  After falling*
behind on payments by approximately nine months, the borrower began*
making regular payments, but never catching up.  As a result, the Bank*
was unable to take the loan out of non-accrual status and take the*
interest payments into income.  The principal balance as of May 2014 was*
$548,515.  An appraisal completed in March of 2014 reflected a value of*
$1,200,000.  The loan was paid off on June 26, 2014.  The Bank was then*
able to take into income $89,644 in prior interest payments on non-accrual*
loans.*


Classification of Loan Costs Recovery:*
For the second quarter 10-Q, the Loan Costs Recovery was shown as*
Noninterest income.  In the third quarter 10-Q, the year-to-date amount*
was reclassified as a reduction of Noninterest expense.  The Bank did an*
assessment that a reduction of expense is a more appropriate presentation*
than an increase in income because the items detailed*
(Interstate Holdings) were originally expense items.  We will continue*
to present the items in this way.  We did not feel it was necessary to*
revise the filings because there was no impact on net earnings as a*
result of the reclassification.*

The company acknowledges that:*
The company is responsible for the adequacy and accuracy of the*
disclosure in the filing;*

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;*

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.*

Disclosures will be provided in future filings to provide a detailed*
understanding of relevant income and expense items.*



Sincerely,*


Thomas A. Procelli*
Principal Executive Officer and*
Principal Financial Officer*

2477 East Commercial Boulevard,*
Ft. Lauderdale, Florida  33308*
Phone: (954) 900-2800*
Toll-Free: (888) 991-BANK*
Fax: (954) 900-2801*