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Mail Stop 4561

      August 9, 2005

Patrick K. Gill
Chief Executive Officer
2445 84th Street, S.W.
Byron Center, Michigan 49315

      Re:	O.A.K. Financial Corporation
		Form 10-K for Fiscal Year Ended December 31, 2004
		File No. 000-22461

Dear Mr. Gill:

   We have reviewed your filing and have the following comments.
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.

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

1. Please tell us your basis, including the specific guidance upon
which you rely, for recording insurance premiums and brokerage
fees.

2. If you are underwriting insurance contracts, please tell us how
you record the costs associated with underwriting such contracts.

3. Please tell us how you determined that your income recognition
method related to each of your insurance products is in accordance
with GAAP.  Tell us how you considered the guidance of SAB Topic
13
and address the following as they relate to each type of product:

* Explain the typical coverage period (i.e. monthly, annually,
etc);
* At what point of the transaction do you substantially complete
or
fulfill the contractual terms of the sales arrangement;
* When is collection of the insurance commission received (i.e.
up-
front, monthly, quarterly, etc);
* Is any portion of the insurance commission refundable and if so,
what are the terms;
We may have further comments.

   As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your response 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.  Please contact Nancy
Maloney Staff Accountant at (202) 551-3427 or me at (202) 551-3490
if
you have questions.

   							Sincerely,

Donald Walker
Senior Assistant Chief Accountant

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Patrick K. Gill
O.A.K. Financial Corporation
August 9, 2005
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