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      corresp092205response

      September
        22, 2005

      SENT
        VIA EDGAR

      Ms.
        Joyce Sweeney

      Senior
        Accountant

      United
        States Securities and Exchange Commission

      Division
        of Corporation Finance

      Washington,
        D.C. 20549-0408

      Re:    CFS
        Bancorp, Inc.

      Form
        10-K for the
        Fiscal Year Ended December 31, 2004

      Forms
        10-Q for the
        Quarters Ended March 31, 2005 and June 30, 2005

      File
        No.
        000-024611

      Dear
        Ms. Sweeney:

      The
        following are the responses of CFS Bancorp, Inc. (the
        Company) to the additional comments set forth in the letter of the staff of
        the Securities and Exchange Commission dated September 13, 2005 relating
        to the
        Company’s Form 10-K for the year ended December 31, 2004 (2004 Form
        10-K) and the Forms 10-Q for the quarters ended March 31, 2005 and June
        30,
        2005. For reference purposes, the text of the staff’s comment letter has been
        reproduced below in italics with the Company’s responses following immediately
        thereafter.

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

      Results
        of Operations

      Non-Interest
        Expense, page 26

      Comment
        No. 1

      We
        note your supplemental responses to comments 1 and 2 of our
        letter dated September 1, 2005. Based on your response it appears as though
        the
        write-down of viatical receivables was the result of not having sufficient
        documentation to support the reasonable collectibility of the receivables.
        Although subsequent developments created uncertainty that led you to decide
        to
        thoroughly review your viatical receivable files, the fact that you did not
        have
        sufficient documentation supporting the collectibility of the receivables
        was in
        existence prior to your determination to review the related files. Please
        tell
        us when you filed the changes in the beneficiary with the insurer and
        when

            Ms.
              Joyce Sweeney

            September
              22, 2005

            Page
              2 of 4

      you
        received the required documentation validating the
        transfers for the receivables for which you have sufficient documentation.
        Tell
        us how you concluded that your failure to identify deficient documentation
        supporting the collectibility of receivables was not an oversight of facts
        that
        existed at the time you prepared your financial statements for the year ended
        December 31, 2003.

      Response
        to Comment No. 1

      The
        write-down of viatical receivables was a result of a change in
        an accounting estimate based on the estimated collectibility of the assets
        due
        to the occurrence of various events and the receipt of additional information.
        Sufficient and appropriate documentation in the form of customer executed
        consent and assignment agreements existed to support the Company’s disbursements
        of cash and recording of a receivable at the time of the various transactions
        and through December 31, 2003. During the second quarter of 2004, the Securities
        and Exchange Commission and Florida regulators placed one of the largest
        viatical companies, Mutual Benefits Corporation (Mutual Benefits), into
        receivership. Based upon that event, beginning in the second quarter of 2004
        the
        Company reviewed its viatical receivables owned by Mutual Benefits and
        determined that the collectibility of $120,000 of those assets was highly
        uncertain and that those assets should be written down. Management, concerned
        with the continuing lack of information from the trustee in bankruptcy for
        one of the other viatical companies that offered these investments and the
        subsequent actions against Mutual Benefits, determined that further analysis
        of
        the collectibility of the remaining viatical receivables was warranted and
        should be completed. The level and quality of documentation that existed
        was
        merely one aspect of the review undertaken by the Company. Upon reviewing
        the
        results of its analysis, the Company revised its estimates as to the
        collectibility of these receivables.

      These
        receivables were not acquired primarily for investment
        purposes, but were purchased as an act of goodwill towards the Company’s
        customers. Although the Company, in its normal course of purchasing these
        assets, had a process which required that the customer sign a consent and
        assignment agreement allowing the Company to be named as the beneficiary
        on the
        underlying insurance policy, some purchase transactions were consummated
        prior
        to the receipt of the final acknowledgement from the respective viatical
        and/or
        insurance company. The lack of such documentation did not, in itself, render
        the
        assets uncollectible. The lack of receipt of acknowledgement from the viatical
        or insurance company documenting the transfer of the beneficial interest
        therein
        to the Company did not create unreasonable uncertainty relating to the
        collectibility of the receivables at the time the receivables were acquired.
        Subsequent events, including the increasing concerns surrounding the viatical
        industry, the difficulties associated with the bankruptcy of one of the viatical
        companies, and the May 2004 closure of Mutual Benefits caused the Company
        to
        conclude that a write-down of these receivables was appropriate.

            Ms.
              Joyce Sweeney

            September
              22, 2005

            Page
              3 of  4

      The
        Company requested changes in the beneficiaries with the
        respective viatical company who was the owner of the underlying policies
        typically within thirty days of executing the consent and assignment agreements.
        The viatical company was responsible for initiating the change in beneficiary
        directly with the insurer. Because the Company was dealing with more than
        one
        viatical seller and had purchased interests in policies issued by dozens
        of
        different insurance companies, the period between the time the Company forwarded
        the consent and assignment agreement to the viatical seller until the time
        the
        Company received the acknowledgement form from the insurance company
        varied
        significantly, ranging anywhere from several weeks to several months, and
        in
        some cases longer.

      The
        Company does not believe the lack of certain documentation
        that existed at December 31, 2003 was determinative at that point in time
        to
        establish the ultimate collectibility of the viatical receivables. As mentioned
        above, the Company recorded the viatical receivables at the time cash was
        disbursed to its customer upon the customer signing the consent and assignment
        agreement. The Company has legal title and interest in these receivables
        but,
        upon review in light of the above discussed factors, determined that the
        estimated collectibility was less than the then current book value. The
        subsequent events outlined above created the uncertainty that precipitated
        the
        Company’s decision to re-evaluate the collectibility of these assets.

      As
        outlined above, the Company believes the write-down of the
        viatical receivables meets the criteria of a change in an accounting estimate
        pursuant to paragraph 10 of APB 20.

      Management’s
        Closing Comments

      Management
        of the Company acknowledges that CFS Bancorp, Inc. is
        responsible for the adequacy and accuracy of the disclosure in the Form 10-K
        for
        the year ended December 31, 2004 and in the Forms 10-Q for the quarters ended
        March 31, 2005 and June 30, 2005. Management of the Company understands that
        staff comments or changes to disclosure in response to staff comments do
        not
        foreclose the Commission from taking any action with respect to the filings.
        In
        addition, management of the Company understands that 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.

      As
        applicable, the Company will revise its disclosures in future
        Forms 10-K and 10-Q in accordance with your comments. If you have any questions
        regarding these responses,

            Ms.
              Joyce Sweeney

            September
              22, 2005

            Page
              4 of 4

      please
        direct them to me, or in my absence, to Joyce Fabisiak,
        Vice President - Finance and Reporting, at 219-836-5500.

      Sincerely,

      /s/
        Charles V. Cole

      Charles
        V. Cole

      Executive
        Vice President and

      Chief
        Financial Officer

      cc:   Matthew
        Komar, Staff
        Accountan

          Philip
        R. Bevan,
        Esq.