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CORRESP
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      MMBC August 24, 2005 Correspondence

    August 24,
      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:

    On
      July 28, 2005 Merchants and Manufacturers Bancorporation, Inc. (the
      "Company") responded 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.

    On
      August
      11, 2005 John Spitz of the Securities and Exchange Commission orally requested
      additional supplemental information regarding the Company's state NOLs. This
      letter contains the supplemental information Mr. Spitz requested.

    A
      valuation allowance was provided against the Company's state NOL deferred tax
      asset because it is more likely than not that the asset will not be realized.
      The Company considered tax planning strategies in determining the amount of
      valuation allowance required. However, because of Wisconsin's separate return
      reporting and the regulatory constraints on income shifting opportunities from
      the subsidiary banks, the Company concluded that the allowance is
      appropriate.

    Wisconsin's
      separate return reporting requires a separate return for each corporation in
      the
      Company's consolidated group subject to taxation in Wisconsin. The holding
      companies with NOLs own banks, but none of the dividend income or undistributed
      income of the banks is reported on the holding company's state return. The
      Company, as the first tier holding company, currently does charge the subsidiary
      banks a management fee, but the amount of this fee is limited to an arm's length
      amount by the bank regulators. Even with this fee income, the Company is still
      generating new NOLs each year.

          Donald
            Walker, Senior Assistant

          Chief
            Accountant

          August 24,
            2005

          Page
            2

    Most
      Wisconsin bank holding companies have this same situation, especially those
      with
      debt at the holding company level. They are all interested in generating income
      at the holding company level, but the Company is not aware that any of these
      Wisconsin bank holding companies have come up with any feasible strategies
      to
      use the state NOLs.

    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