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CORRESP
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MAIN STREET TRUST, INC.

August 31,
2005

VIA EDGAR

Securities and Exchange
Commission

Division of Corporation
Finance

450 Fifth Street, N.W.

Mail Stop 4561

Washington, D.C.  20549-0408

Attention:  Ms. Kathleen Collins

  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 Ms. Collins:

Main
Street Trust, Inc. (“The Company”) has filed via EDGAR today its responses
to the comments of the Staff contained in a letter, dated August 9, 2005,
relating to the above-referenced filings.
Set forth below are the comments contained in the Staff’s letter and
immediately below each comment is the response with respect thereto.

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 whereas 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.

The
Company responds as follows:

Main Street Trust
Investment Team Process

The Company’s Investment
Team is comprised of the President and Chief Executive Officer, Chief
Investment Officer, Chief Equity analyst and five other investment
analysts.  The Investment Team meets no
less frequently than monthly.  The
Investment Team is responsible for recommending additions/deletions to the
Company’s Recommended for Purchase Stock List (“the
Stock List”).  At any given time, the
Stock List will have between 25 and 40 individual stocks.  Presentations on stocks recommended for
addition to or deletion from the Stock List include the CSFB Holt framework,
the most recent Value Line report, the most recent Zack’s Digest report and any
additional materials deemed relevant/important to the discussion.  While occasional transactions will be
necessary, the Investment Team strives to keep turnover low to minimize tax,
transaction and opportunity costs.  The
projections contained in this letter are those of our Investment Team which we
rely upon for managing the stock portfolio.

Application of SAB 59

On a quarterly basis, the
Company’s management reviews specific equity securities that are in a loss
position to determine whether or not any such loss is other than
temporary.  To assist management to that
end, key members of the Company’s Investment Team provide general information
about the economy and equity markets, as well as current issuer specific
information.  Management also considers
several other factors in determining whether an other than temporary loss
exists for a specific security, including, but not limited to, the length of
time and the extent to which the market value of the security has been less
than cost, the financial condition and near-term prospects of the issuer and
the intent and ability of the Company to retain its investment in the issuer
for a period of time sufficient to allow for any anticipated recovery in market
value.

Following is a discussion
of how we applied the guidance in SAB 59 to the stocks which had continuous
losses as documented in Table 1:

Bristol Myers Squibb
(BMY), Table 1.(a)

At the end of 2002, BMY’s
market price was 44% below our purchase price of $40.91.  The price had fallen after revelations of an
SEC investigation into BMY’s accounting and concerns about patent
expirations.  We believed that the
company’s net margins would rebound from the all-time low 11% in 2002 to more normal
levels (18-24%), and the valuation would expand to a multiple of earnings
closer to its peer group (20x-25x EPS).
Based on our projection that the company’s EPS would climb back above
$2/share over the next couple of years, a valuation of 20x, or $40/share, would
allow us to recoup our purchase cost within a reasonable period of time.  At the end of 2002, we had the ability and
intent to hold the stock until our valuation target was achieved.  Therefore, we did not consider the unrealized
loss to be other than temporary.

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At the end of 2003, BMY’s
market price was 30% below our purchase price of $40.91.  The stock appreciated 24% during 2003, which
was less than we had expected; however, the recovery in the company’s revenues
and margins appeared to be unfolding as we had expected.  Revenues grew by $2.7 billion and net margins
improved by 370 basis points.  We
believed that another year of continued performance improvement and resolution
of some of the legal and regulatory matters that were plaguing investor
psychology (and weighing on the stock’s valuation) would allow the share price
to move into the $40’s.  We expected the
company to earn more than $2/share (17.5% net margins on $22 billion in sales)
and estimated that the stock’s valuation would improve to a multiple of at
least 20x EPS, or $40+ per share.  At the
end of 2003, we had the ability and intent to hold the stock until our
valuation target was achieved.  Therefore,
we did not consider the unrealized loss to be other than temporary.

At the end of 2004, BMY’s
market price was 28% below our average purchase price of $35.58.  The stock price declined by 11% during 2004,
as BMY’s revenues and earnings remained under pressure due to patent expirations.  The last of the company’s major patent
expirations are expected to occur in 2005 and 2006, but it appears that
revenues will remain stable due to the introduction of new products during the
same timeframe.  The company is
continuing to increase spending on research and development and is incurring
increased costs due to the rollout of its new products.  We believe that after the expenses associated
with these new product launches dissipate and revenues begin to grow again
after 2006, the stock will appreciate in anticipation of margins recovering to
more normal levels for the industry and the company.  Revenue growth should resume after the last
of BMY’s patent expiries occurs in 2006.
Assuming 10% revenue growth in 2007 and 2008, a recovery in margins to
BMY’s historically normal 20%, and a price/earnings ratio of 18x
(which is conservative considering that pharmaceutical companies have usually
traded at a premium to the broader market which currently trades at a multiple
of 18x EPS), the stock would trade at $41.
Using a 15% discount rate, the stock appears to be discounting this
recovery scenario unfolding over the next 3 years.  We believe BMY’s shares will rise to $41 and
above.  We purchased 2,200 additional
shares of BMY during 2004 due to this conviction.  At the end of 2004, we had the ability and
intent to hold the stock until our valuation target was achieved.  Therefore, we did not consider the unrealized
loss to be other than temporary.

At March 31, 2005,
BMY’s market price was 2% below our purchase price of $25.91.  The unrealized loss of less than $1,500 at
the end of the first quarter was not considered material; therefore, we did not
consider the unrealized loss to be other than temporary.

Compuware (CPWR), Table 1.(b)

At the end of 2002, CPWR’s
market price was 63% below our purchase price of $13.07.    Based on management’s discussions of
cost-cutting measures being taken, we believed that the company’s net margins
would recover to the company’s pre-year 2000 range of 11-20% as revenue growth
resumed.  We thought it reasonable to
assume a 12-month forward revenue

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estimate of $1.5 billion,
15% net margins, a multiple of 20x EPS (below the historical average of 23x),
which, after adding in the company’s $2/share in cash on hand, would result in
a share price of $13.84, almost $1 above our purchase price.  At the end of 2002, we had the ability and
intent to hold the stock until our valuation target was achieved.  Therefore, we did not consider the unrealized
loss to be other than temporary.

At the end of 2003, CPWR’s
market price was 54% below our purchase price of $13.07.  The stock price appreciated 24% during 2003,
which was less than we had expected; however, we believed that management was
making positive changes that would help the company’s net margins recover to
the company’s average of 13% (pre-1998).
Based on our estimate of 2004 revenues of $1.4 billion and 15% net
margins, we believed the stock could trade at $14.48, or its average historical
price/earnings multiple of 23x EPS for 2004 of $.48, plus the company’s
$2/share cash balance.  At the end of
2003, we had the ability and intent to hold the stock until our valuation
target was achieved.  Therefore, we did
not consider the unrealized loss to be other than temporary.

At the end of 2004, CPWR’s
market price was 42% below our purchase price of $11.06.  The stock price appreciated 6% during 2004,
which was less than we had expected.  The
company’s turnaround was progressing as expected (the stock reached $9 in early
2004) but suffered a setback that caused the stock to stumble.  We continue to believe that management has,
and is, making positive changes that will boost net margins back to the company’s
average of 13%.  Revenues and earnings
are growing again, and we believe that CPWR’s results will continue to exceed
Wall Street expectations.  Even if CPWR
only earns $.45/share for calendar year 2006, we believe the stock should trade
above $12/share (23x $.45 EPS, plus $2/share for company’s cash balances).  We purchased 8,000 additional shares of CPWR
during 2004 due to this conviction.  At
the end of 2003, we had the ability and intent to hold the stock until our
valuation target was achieved.  Therefore,
we did not consider the unrealized loss to be other than temporary.

At March 31, 2005,
CPWR’s market price was 5% below our purchase price of $7.58. The unrealized
loss of less than $7,000 was not considered material; therefore, we did not
consider the unrealized loss to be other than temporary.

Dana Corp. (DCN), Table 1.(c)

At the end of 2002, DCN’s
market price was 40% below our purchase price of $19.59.  We were holding the stock due to our belief
that the company’s margins would recover to a more “normal” level of 4% (the
middle of the range experienced in 1996-2000) as their businesses recovered
after the 2001 recession in the U.S. economy.
Relative to historical trading ranges, the stock was significantly
under-valued based on several bases.  DCN
shares were trading at a price-to-book value of 1.2x compared to a 10-year
range of 0.8x-3.5x; a price/earnings ratio of 10x trailing 12-month EPS,
compared to a 10-year range of 5x-18x EPS; and a price/sales ratio of 0.18,
compared to a 10-year range of 0.15-0.80.
We were expecting a reversion to average

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historical valuation for
DCN shares, which would suggest an expected price of $21.40 based on price/book
valuation, $17.25 based on price/earnings valuation, and $30.28—or a blended
average expected price of $22.97.  At the
end of 2002, we had the ability and intent to hold the stock until our
valuation target was achieved.  Therefore,
we did not consider the unrealized loss to be other than temporary.

At the end of 2003, DCN’s
market price was 6% below our purchase price of $19.59.  The stock appreciated 56% in 2003, in-line
with our expectations.  We believed the
company would earn more than $2/share in 2004 and believed a multiple of 12x was appropriate for the stock, yielding a target price
of $24.  At the end of 2003, we had the
ability and intent to hold the stock until our valuation target was
achieved.  Therefore, we did not consider
the unrealized loss to be other than temporary.

At the end of 2004, DCN’s
market price was 12% below our purchase price of $19.76.  The stock price declined by 5% during 2004;
however, the stock traded above our purchase price during the year.  The unrealized loss was not continuous for
more than 12 months at year-end and we did not consider the unrealized loss to
be other than temporary.

Du Pont (DD), Table 1.(d)

At the end of 2002, DD’s
market price was 18% below our purchase price of $51.57.  DD’s management was in the midst of making
changes to its portfolio of businesses in an attempt to transform the company
into a faster-growing, higher-margin life sciences-driven organization when the
recession of 2001 occurred.  We believed
that the company’s transition would be delayed, not derailed, by the
recession.  It was our expectation that
the company’s valuation would expand to 20x EPS, which we expected to rebound
to $2.70 (10.5% net margins on $26 billion in sales) in 2003—or a price of
$54.00.  At the end of 2002, we had the
ability and intent to hold the stock until our valuation target was
achieved.  Therefore, we did not consider
the unrealized loss to be other than temporary.

At the end of 2003, DD’s
market price was 10% below our purchase price of $51.57. The stock appreciated 7%
in 2003, which was less than we had expected.
Rising commodity prices reduced DD’s profit margins in 2003, but
management continued to make progress with its efforts to divest of
slower-growing, lower-margin businesses for the purpose of transforming the
company into a faster-growing, higher-return enterprise.  At the end of 2003, we had the ability and
intent to hold the stock until our valuation target was achieved.  Therefore, we did not consider the unrealized
loss to be other than temporary.

DD had an immaterial loss
at the end of 2004, and we sold out our position in 2005 at a gain.

InFocus Corp. (INFS),
Table 1.(e)

At the end of 2002, INFS’s
market price was 73% below our purchase price of $22.73.  We

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believed
that shares of smaller-capitalization companies were under exaggerated pressure
due to the severe lack of liquidity in the markets, and prices would rebound
sharply from the lows caused by that lack of liquidity.  Our belief that much of the decline in stock
prices was liquidity-driven was based on the fact that a record number of
smaller-capitalization stocks were trading for less than the cash-per-share
held by the companies in their bank accounts.
Historically, when valuations were discounted this deeply, dramatic
price recoveries followed.  While the
company had declared a loss for the year 2002, INFS had overcome similar
difficulties in the past, triggering spectacular rallies in its stock (nearly
600% in 1993-1996, 300%+ in 1996-1998, and 2,000%+ in 1998-2000).  We were confide