SecProbe.io

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Mail Stop 4561
								July 5, 2005

Home City Financial Corporation
Attn: Charles Mihal, Treasurer and Chief Financial Officer
2454 North Limestone Street
Springfield, Ohio, 45503

	Re:	Home City Financial Corporation
	Registration Statement on Form 10-KSB
	Filed March 21, 2005
	File No. 000-21809

Dear Mr. Mihal:

      We have limited our review of your filing to the issue we
have
addressed in our 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.

Note 2: Securities, page 48

1. Please tell us the factors specifically considered by
management
in evaluating the existence of an other than temporary impairment
of
the Fannie Mae preferred stock, and ultimately how management`s
conclusion was reached that the security impairment was temporary.
In your response, please specifically address the following
factors:

* The analysis performed by management to determine the loss was
temporary after being in a loss position greater than 15% for over
two years
* The financial condition and near-term prospects of the Fannie
Mae
considered by management, including any specific events which may
influence the operations of the issuer, such as changes in
interest
rates that may impair the earnings potential of the investment
* The intent and ability of management to retain the investment in
Fannie Mae for a period of time sufficient to allow for any
anticipated recovery in market value, including management`s
anticipated timeline for recovery of the investment and the
documentation supporting management`s estimates

	In your response, please refer to the technical guidance in
Staff Accounting Bulletin No. 59 and SFAS 115.

      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 Margaret Fitzgerald at (202) 551-3556 or me
at
(202) 551-3490 if you have questions regarding comments on the
financial statements and related matters.

	Sincerely,

      Don Walker
                                        Sr. Assistant Chief
Accountant
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Charles Mihal
Home City Financial Corporation
July 5, 2005
Page 1

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