SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 4561

      							August 9, 2005

Mr. Van A. Dukeman
Chief Executive Officer
Main Street Trust, Inc.
100 West University
Champaign, Illinois 61820

	Re:	Main Street Trust, Inc.
		Form 10-K for the Fiscal Year Ended December 31, 2004
      Form 10-Q for the Fiscal Quarter Ended March 31, 2005
      File No. 000-30031

Dear Mr. Dukeman:

		We have reviewed the above referenced filings and have
the
following comments.  Please note that we have limited our review
to
the matters addressed in the comments below.  We may ask you to
provide us with supplemental information so we may better
understand
your disclosure.  Please be as detailed as necessary in your
explanation.  After reviewing this information, we may 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 on 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 Fiscal Year Ended December 31, 2004

Note 3 - Investment in Debt and Equity Securities, page 46

1. We note that the Company`s investments in other securities had
unrealized losses of $749,000, $981,000 and $1.3 million for
fiscal
years 2004, 2003 and 2002, respectively.  Considering these
securities had been in a loss position for greater than 12 months
at
each period end, tell us how you considered SAB 59 in determining
that these unrealized losses were other than temporary.   We
further
note that the unrealized losses in common stocks decreased in 2004
compared to 2003 and "management believes the market value of
these
securities will continue to improve as the economy continues to
recover".  The $981,000 unrealized loss in 2003, however, is
attributable to the Company`s investment in ten common stocks
where
as the unrealized loss in 2004 is attributable to your investment
in
seven common stocks.  Therefore, it is not clear if the decrease
in
the unrealized loss is the result of an improvement in the economy
or
a change in the portfolio.  Please provide a breakdown of the
unrealized losses for each period presented by security and tell
us
how you applied the guidance in SAB 59 on an individual security
basis.  We also refer you to the guidance in the Current
Accounting
and Disclosure Issues in the Division of Corporation Finance dated
March 4, 2005 that can be found on our website at
http://www.sec.gov/divisions/corpfin/acctdis030405.htm#P493_74580,
which indicates that the ability to hold an equity security
indefinitely would not, by itself, allow an investor to avoid an
other-than-temporary impairment.  Your response should include
your
consideration of the Staff`s guidance, as well.  Also, provide a
similar analysis for the $3.6 million of unrealized losses on
federal
agency securities that have been in a loss position for greater
than
12 months at March 31, 2005.

2. We note from your disclosures in Note 1(f) that the Company`s
non-
marketable equity securities include investments in venture
capital
funds which are reported on the equity method.  Please provide a
breakdown of these investments, which includes the name of the
investee as well as the percentage ownership of common stock.
Tell
us how you considered the disclosure requirements of paragraph 20
of
APB 18 and tell us how you determined the fair value of these
investments.

*****

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please submit all
correspondence on EDGAR as required by Rule 101 of Regulation S-T.
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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 comment, 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 Christopher White, Staff Accountant, at (202)
551-3461 or me at (202) 551-3499 if you have any questions
regarding
our comments on the financial statements and related matters.

								Sincerely,

								Kathleen Collins
								Accounting Branch Chief

??

??

??

??

Mr. Van A. Dukeman
Main Street Trust, Inc.
August 9, 2005
page 1

</TEXT>
</DOCUMENT>