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      MMBC July 26, 2005 response correspondence

    July 26,
      2005

    SENT
      VIA
      EDGAR

    Donald
      Walker, Senior Assistant

    Chief
      Accountant

    United
      States Securities and Exchange Commission

    Division
      of Corporation Finance

    450
      Fifth
      Street, N.W.

    Washington,
      D.C. 20549

    Re:
      Merchants
      and Manufacturers Bancorporation, Inc.

      Form 10-K for the fiscal year ended December 31, 2004

      Filed March 16, 2005

      File No. 000-21292

      Dear
        Mr.
        Walker:

      The
        following is the response of Merchants and Manufacturers Bancorporation,
        Inc.
        (the "Company") to the comment in the letter of the staff of the Securities
        and
        Exchange Commission dated July 14, 2005 relating to the Company's Form 10-K
        for
        the year ended December 31, 2004. For reference purposes, the text
        of the
        staff's comment letter has been reproduced below together with the Company's
        response to the comment.

      Form
        10-K filed on March 16, 2005

      Notes
        to Consolidated Financial Statements

      Note
        14. Income Taxes, page 30

      Comment
        No. 1

      We
        note in your table on page 31 that you have a deferred tax asset valuation
        allowance equal to your net operating loss carryforwards for each period
        presented. Please tell us the following:

                ·

                Explain
                  what your net operating loss carryforwards are attributable to
                  and when
                  they are expected to expire. Refer to the disclosure requirements
                  prescribed by paragraph 48 of SFAS
                  109;

                ·

                Provide
                  us with the analysis you performed that led you to conclude that
                  it is
                  more
                  likely than not
                  that these net operating loss carryforwards will not be realized.
                  Refer to
                  the authoritative guidance included in paragraph 17(e) of SFAS
                  109;

      Donald
        Walker, Senior Assistant

      Chief
        Accountant

      July 26,
        2005

      Page
        2

      Response
        to Comment No. 1

      The
        net
        operating loss carryforwards are attributable to state net operating loss
        carryforwards which expire after 15 years.  Wisconsin is a separate
        return
        state, so even though the federal consolidated group of 22 corporations does
        not
        have a net operating loss, 6 of the 14 corporations in the consolidated group
        that file separate Wisconsin returns do have net operating loss carryforwards.

      The
        Company, which is the first tier holding company for the consolidated group,
        has
        state net operating loss carryforwards which started in 1987.  Each
        year
        some of these NOL carryforwards expire unused while the most recent year’s NOLs
        are added.  A second tier holding company, Merchants Merger Corp.,
        has
        state net operating loss carryforwards which started in 1991 and will begin
        to
        expire in 2006.  Other corporations in the consolidated group have
        state
        net operating loss carryforwards that are minimal and have not begun to
        expire.

      98%
        of
        the state net operating loss carryforwards are attributable to the Company
        and
        Merchants Merger Corp. and these two corporations have no likelihood of
        generating state taxable income of their own to use the state NOL
        carryforwards.

      The
        Company will expand the disclosure in the notes to the financial statements
        in
        future filings to address the maters discussed above.

      The
        Company acknowledges that (i) it is responsible for the adequacy and accuracy
        of
        the disclosure in the filing; (ii) 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 (iii) it 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.

      Please
        contact me at 262-827-5632 if you have any questions on any of the responses
        to
        your comments.

    Best
      regards,

    Merchants
      and Manufacturers Bancorporation, Inc.

    /s/
      Frederick R. Klug

    Frederick
      R. Klug

    Executive
      Vice President and

    Chief
      Financial Officer