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March 24, 2005

Mail Stop 0408

By U.S. Mail and facsimile to (410) 529-0147

Bonnie M. Klein
Vice President and Treasurer
BCSB Bankcorp, Inc.
4111 E. Joppa Road, Suite 300
Baltimore, MD  21236

Re:	BCSB Bankcorp, Inc.
      Form 10-K for the period ended September 30, 2004
      Form 10-Q for fiscal 2004 and 2005
	File No.  000-24589

Dear Ms. Klein:

      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
Investment Activities - page 18

1. In future filings please provide a note to the table setting
forth
the carrying value of your investments discussing the
concentration
of issuers which exceed 10% of stockholders` equity, if any.
Please
refer to Item II.C of Industry Guide III.
Deposit Activity and Other Sources of Funds - page 20

2. We note that the borrowings shown on the Consolidated
Statements
of Financial Condition were not identified as short or long-term
in
nature.  Please carefully review the requirements and related
instructions to Item VII of Industry Guide III and include the
relevant disclosures, or tell us why you believe they are not
required.
Deposit Activity and Other Sources of Funds - page 22

3. In future filings please specify the rounding denomination used
within the chart setting forth the change in dollar amounts of
deposits.  For example: "(dollars in thousands)".

Annual Report

Management`s Discussion & Analysis of Financial Condition &
Results
of Operations

Average Balance, Interest and Average Yields and Rates - page 8

4. In future filings please include a note to the table that
explains
the inconsistency between the Liabilities in the Consolidated
Statements of Financial Condition showing only Junior Subordinated
Debentures outstanding at September 30, 2004 and the Interest-
bearing
liabilities showing only Trust Preferred Securities.
Liquidity and Capital Resources - page 15

5. We note that approximately 50% of your time deposits and 35% of
your total deposits, comprising in excess of $201 million will
mature
within the next year.  Please in the future include a discussion
detailing how you plan on retaining a significant portion of these
deposits and your plans if you are unable to or unwilling to pay
market interest rates upon maturity.  Discuss and quantify
additional
funding sources should you experience significant
disintermediation
or deposit run-off.

Impact of New Accounting Standards - page F-7

6. In future filings please add a discussion specifically
addressing
the impact of Variable Interest Entities on the financial
statements.
See paragraph 23 -26 of FIN 46(R) Consolidation of Variable
Interest
Entities.

Note 1  -  page F-13
7. Include an accounting policy in future filings for your bank
owned
life insurance.  Disclose the nature of the investment and your
revenue recognition policy.

Form 10-Q/A filed February 25, 2005
8. Please file a Form 10-Q/A and address the comments which
follow.

General - Explanatory Note

9. Please revise to include a more robust description of the
nature
of the corrected information and the impact on the financial
statements.  We remain unclear as to the facts and circumstances
surrounding this restatement.

10. Supplementally, please provide your analysis and rationale for
not restating the financial statements for the year ended March
31,
2004.  You may opt to include a timeline detailing particular
events
and/or circumstances, their influence on your original accounting
and
why and when you decided to amend your financial statements.
Refer
to the authoritative accounting literature you followed as
necessary.

General - Item 3 and 4

11. Please supplementally advise us why you believe you do not
have
amend Item 3 Quantitative and Qualitative Disclosures about Market
Risk and Item 4 Controls and Procedures, or revise your upcoming
Form
10-Q/A accordingly.

Consolidated Statements of Cash Flows - page 6

12. The Cash and Cash Equivalents ending balance for the three
months
ended December 31, 2004 did not agree with the Cash and Cash
Equivalents balance provided in the Consolidated Statements of
Financial Condition.  Please carefully review all financial
statements and Management`s Discussion and Analysis for
mathematical
accuracy and internal consistency and revise accordingly.
Note 4 - Earnings Per Share - page 8

13. We note that Net Income available to shareholders for the
three
months ended December 31, 2003 does not reflect the amended value
shown in the Consolidated Statements of Operations.   Please
revise
or advise accordingly.
Management`s Discussion & Analysis of Financial Condition &
Results
of Operations
Income Taxes - page 16

14. Please include a discussion of the tax provision adjustment
made
to the Consolidated Statements of Operations for the three months
ending December 31, 2003.  Specifically address the nature of the
adjustment, how the adjustment was identified, and why or why not
it
impacts the March 31, 2004 year-end financial statements.

* * * * *

       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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Bonnie M. Klein, Vice President and Treasurer
BCSB Bankcorp, Inc.
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