SecProbe.io

Mail Stop 4561      July 17, 2008
By U.S. Mail and Facsimile to: (907) 562-1758

Joseph M. Schierhorn  Executive Vice President, Chief Financial Officer Northrim BanCorp, Inc. 3111 C Street Anchorage, AK 99503

Re: Northrim BanCorp, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2007
Filed March 14, 2008
 File No. 000-33501

Dear Mr. Schierhorn:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.   Please understand that the purpose of our re view 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 Fiscal Year Ended December 31, 2007

 Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 7
 Critical Accounting Estimates

 1. In future filings, please include a separate description of each critical accounting estimate or assumption, involving a high level of subjectivity and judgment,
which underlie each of the company’s crit ical accounting measurements, such as

Joseph M. Schierhorn
Northrim BanCorp, Inc.
July 17, 2008 Page 6

for determining the adequacy of the allowa nce for loan losses and the valuation of
the investment portfolio. The disclo sure should address the following:

• Describe the methodology underlying each critical accounting estimate.

• Identify where and how each critical accounting estimate affects the
company’s reported financial results, financial condition and changes in
financial condition, and when material, identify the affected line items.

• Discuss, if applicable, why you could have chosen in the current period
alternate estimates that would have had a materially different impact on your financial presentation.

• Discuss, if applicable, why the accounting estimate may change in future
periods and describe the impact on your financial statements.

Refer to the examples provided in It em III.D of the Commission’s Proposed
Release Nos. 33-8098 and 34-45907.

Analysis of the Allowance for Loan Losses, page 14

 2. We note that in 2007 the allowance for loan losses was $11.7 million, a $360,000
decrease as compared to 2006 resulti ng from increased nonperforming loans, a
provision of $5.5 million and net charge-offs  of $6.1 million.  According to the
“Loans and Lending Activities” section on page 20 of the company’s March 31, 2008 Form 10-Q, we note that as of March 31, 2008 nonperforming loans increased to $15 million as compared to  $11 million as of December 31, 2007 and
the ratio of the allowance to nonperformi ng loans decreased to 84% as compared
to 104% as of December 31, 2007.  Consider ing the apparently increased credit
risk characteristics of your loan portfolio, please tell us and in future filings discuss:

• The reasons for the increased levels  of nonperforming construction and land
development projects and if this is indicative of an  economic trend that is
expected to affect the company’s future operations, cash flow and liquidity.

• The consideration given, in evaluating the appropriateness of the allowance
for loans losses, to the extent to wh ich the nonperforming loans are fully or
partially collateralized and the na ture of the underlying collateral.

• The frequency for which the company obtains updated appraisals for your
relatively higher risk comme rcial and construction lo ans, which are 59% of
your loan portfolio and the majority of your nonperforming loans and charge-

Joseph M. Schierhorn
Northrim BanCorp, Inc.
July 17, 2008 Page 6

offs.

• Any material changes in the credit charac teristics of the loan portfolio as a
result of the acquisition of Alaska First in October 2007 stated in Note 2 on
page 40.
 3. We refer to the last paragraph on pa ge 14 that states the increase in
nonperforming loans and potential problem loans has been factored into the
company’s methodology for analyzing its allo wance for loan losses.  In future
filings, please expand your discus sion regarding your methodology for
determining the appropriaten ess of the allowance for loan losses to include the
following:

• A SFAS 5 assessment with respect to estimated unidentified losses on pools of
loans with similar graded credit characteristics.

• If loans are grouped by pool or by grading within type to estimate unidentified
probable losses, the basis for these gr oupings and the methods for determining
the loss factors to be applied to these grouping should be described.
 • A SFAS 114 credit risk anal ysis with respect to losses on specific evaluations
of known loss in individual loans.
 • The basis for estimating the impact of e nvironmental factors, such as local and
economic conditions, trends in delinquencies and losses, and credit
concentrations such as in high risk construction loans, whether through modifying loss factors or through a se parate allowance element should be
discussed.

• The extent to which the company obtain s current appraisals on collateral of
relatively higher risk commerc ial and construction loans.

Recent Accounting Pronouncements, page 26

 4. We note the company states it believes  the adoption of th e issuance of SFAS
141R, SFAS 157, and SFAS 160 will not have a significant impact on its financial
statements.  Please tell us and in future  filings expand the disclosure required by
SAB 103, Topic 11.M to disclose the following:

• A brief description of the new standard, the date that adoptio n is required and
the date that the company plans to adopt  it, if earlier adoption is permitted.

• A discussion of the methods of adop tion allowed by the standard and the

Joseph M. Schierhorn
Northrim BanCorp, Inc.
July 17, 2008 Page 6

method expected to be used by th e company, if it has already been
determined.

• In addition to the discussion of the impact  that the adoption of the standard is
expected to have on the company’s fina ncial statements, disclose the potential
impact that might result from adoption of the standard, such as technical
violations of debt covenants.

Financial Statements for the Period Ended December 31, 2007

 Note 1, Organization and Summary of Si gnificant Accounting Policies, page 37

 5. We note the company has subsidiaries that  provide investment advisory services,
insurance brokerage services, mortgage le nding and wealth management services.
Please tell us and disclose in future fi lings your consideration of providing the
segment reporting information requi red by SFAS 131 and related MD&A
disclosure.
 Part III

 Item 10.  Directors and Executiv e Officers of the Registrant

 Executive Officers, page 6 of Definitive Proxy Statement on Schedule 14A

 6. In future filings, please describe the busin ess experience during the past five years
of Messrs. Beedle and Hartung.  Refer to Item 401(e)(1) of Regulation S-K.
 Item 11.  Executive Compensation

 Compensation Discussion and Analysis, pa ge 7 of Definitive Proxy Statement on
Schedule 14A
 7. In future filings, with respect to performance based annual bonuses, please disclose and discuss the specific performan ce targets relating to return on equity,
the ratio of expenses to a ssets, net income as compar ed to budget, earning per
share growth and asset quality and how the company’s annual bonus awards are structured around such performance targets.   Refer to Item 402(b)(2)(v)-(vi) of
Regulation S-K.  If you did not disclose the performance targets because you determined that they were confidential due to the potential for competitive harm to Northrim BanCorp, as contemplated  by Instruction 4 to  Item 402(b) of
Regulation S-K, provide us with your c onfidentiality analysis supplementally and
include detailed disclosure analyzing the level of difficulty necessary to reach each of the targets contemplated by the In struction.  For more information on the
confidentiality of targets, please refer to the report of the Commission Staff

Joseph M. Schierhorn
Northrim BanCorp, Inc.
July 17, 2008 Page 6

regarding executive compensation disclosure, released October 9, 2007.

8. It appears that the company benchmarks certain elements of compensation to its peers.  In future filings, please (i) identify the component companies that make up the compensation peer group or groups, (ii) describe how the committee used
comparative compensation information in determining compensation or compensation ranges for each of the compensation components and (iii) disclose whether the compensation committee deviat ed from peer group benchmarks in
setting executive compensation, and if so, state the reasons for such deviation.
Refer to Item 402(b)(2)(xiv) of Regulation S-K.
 9. We note that the company identifies the compensation consultant engaged for
certain periods, but not for 2007.  In future  filings, to the extent the company used
a compensation consultant in any of th e reported periods, pl ease identify and
discuss the role of any compensation c onsultants engaged by the company during
a period addressed in the compen sation discussion and analysis.
 Item 13.  Certain Relationsh ips and Related Transactions

 Interest of Management in Certain Transa ctions, page 30 of Definitive Proxy Statement
on Schedule 14A

10. In future filings, please include the complete representations required by
Instruction 4(c) to Item 404(a) of Regulation S-K.  In  particular, please clarify
that the loans were on the same terms, in cluding interest rate s and collateral, as
those available to other pers ons not related to the lende r.  Also, avoid qualifying
the representations by including terms like “in the opinion of management.”

Part IV
 Exhibits 31.1 and 31.2

Section 302 Certifications
 11. We note that paragraphs 2, 3 and 4 of your  certifications included as Exhibits 31.1
and 31.2 to the Form 10-K contain modificati ons of the exact form of certification
as set forth in Item 601(b)(31) of Regulati on S-K.  For example, the certifications
include references to the “annual report” rath er than referring to only the “report”.
In future filings, please ensure that the cer tifications are in the exact form as set
forth in Item 601(b)(31) of Regulation S-K, except as otherwise indicated in
Commission statements or staff interpretations.
 Closing Comments

 As appropriate, please amend your filing and respond to these comments within

Joseph M. Schierhorn
Northrim BanCorp, Inc. July 17, 2008 Page 6

10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and
provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
  You may contact Edwin Adames at ( 202) 551-3447 or John Nolan at (202) 551-
3492 if you have questions regarding comments on the financial statements and related
matters.  Please contact Justin Dobbie at (202) 551-3469 or me at (202) 551-3448 with
any other questions.
Sincerely,

Jessica Livingston Staff Attorney