SecProbe.io

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February 11, 2005

Mail Stop 0408

By U.S. Mail and facsimile to (610) 269-0455

Joseph T. Crowley
Chief Financial Officer
Chester Valley Bancorp, Inc.
100 E. Lancaster Ave.
Downington, PA 19335

Re:	Chester Valley Bancorp, Inc.
      Form 10-K for the period ended June 30, 2004
      Form 10-Q for fiscal 2004
	File No.  000-18833

Dear Mr. Crowley:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Item 1. Business

Loan Fee and Servicing Income - page 6

1. We note you were servicing $9.9 million of loans for others at
June 30, 2004.  We are unable to determine from your current
disclosures whether or not servicing assets have been recorded.
Please supplementally explain to us your current and prior
accounting
for any and all loans serviced for others, giving effect to the
implementation dates and related guidance in SFAS No. 125 and 140,
as
appropriate.  For example, in correspondence dated January 21,
2001,
you stated that $20.6 million of loans being serviced for others
were
identified as being originated prior to the implementation of SFAS
125, but we remain unclear about other loan servicing agreements
you
entered into subsequent to the implementation dates of the above
guidance which could require the recognition of a servicing asset.
Please also revise future filing disclosures and/or your
accounting,
if necessary.

Non-Performing Loans  -  page 8

2. We note you have opted to present a non-GAAP disclosure for a
non-
performing loan originated prior to the current bank management.
Please carefully review Release No. 33-8176 and Item 10 of
Regulation
S-K to ensure that you are in compliance and continue to believe
your
presentation is appropriate.

Allowances for Losses on Loans and Classified Loans - page 9

3. In future filings, please fully explain how you determined the
allocation of the allowance for loan losses to the respective loan
categories.  For example, we note that the majority of your
historical charge-offs have been in the commercial business and
consumer loan areas, however, you have allocated less than 50% in
the
aggregate to these two categories.

Average Balance Sheets  -  page 18

4. Please review Item I.A of Guide III to ensure you have
presented
the appropriate level of category detail in your average balance
sheets and rate/volume tables in future filings.  For example, you
have commingled all deposits and repurchase agreement categories,
although it is more appropriate to separately present savings,
other
time deposits, repurchase agreements, etc.

Item 7A Quantitative and Qualitative Disclosures about Market Risk

Market Risk - page 48 - 49

5. In the narrative on Economic Value of Equity (EVE) and the
accompanying table outlining the impact of interest rate
sensitivity
on EVE please discuss the important economic factors driving the
changes for each interest rate shock scenario. For example, loan
prepayments and refinancing will decrease the value of the loan
portfolio as interest rates rise. Please refer to Regulation S-K
Item
305 (a)(1)(ii)(A&B)

Item 8.  Financial  Statements and Supplementary Data
Financial Statements and Notes

General

6. In future filings please add an accounting policy and related
footnote to the financial statements specifically addressing the
treatment of Goodwill and Intangible Assets.  See paragraph 18-29
of
SFAS No. 142.
Investment Securities - Note 3  -  page 65

7. We note your discussion regarding the three non-rated
Pennsylvania
Municipal Authority Bonds that have been classified as
substandard.
Please supplementally provide the following information:
* Provide a timeline detailing the facts and circumstances by
individual bond which will allow us to more fully understand how
you
determined your current accounting, including the amount and date
of
purchase;
* Clarify whether or not the zero coupon bonds are on non-accrual
and
the reasons supporting your determination;
* Discuss how you determined the level of any impairments or
write-
downs, including how you determine periodic market value and tell
us
when and how much you wrote-down by each respective date;
* Discuss the original treatment of the zero-coupon bonds`
discount
amortization to income and what the effect of the write-down had
on
the income for that period and the amortization schedule going
forward;
* Discuss how you complied with the guidance in paragraph 16 of
SFAS
No. 115 and SAB No. 59 by individual bond regarding the
possibility
of an other than temporary impairment for all interim and year-end
periods since you have considered them substandard or on non-
accrual.

Pension Plan Note 15  -  page 78

8. It was noted in the paragraph discussing the pension plan, that
information relative to the financial status of the Registrant`s
portion of the plan was unavailable.  The risks associated with
this
type of arrangement is not inherently clear.  Please include a
description of the multi-employer investment trust and its
investment
strategies, a discussion of the risks inherent in the trust
agreement
with respect to current and future pension distributions, and any
guarantees provided by the trust.

9. Supplementally, please provide your analysis for determining
the
annual pension costs and the funded status of the plan.

* * * * *

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging 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; and

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Paula Smith (Staff Accountant) at (202) 824-
5698
or me at (202) 942-1783 with any other questions.

Sincerely,

							John P. Nolan
							Accounting Branch Chief
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Joseph T. Crowley, Chief Financial Officer
Chester Valley Bancorp, Inc.
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