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September 11, 2008

VIA EDGAR AND OVERNIGHT DELIVERY

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-4561

    Attention:

    Jessica Livingston
Justin Dobbins

    Re:

    Northrim BanCorp, Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2007

    Filed March 14, 2008

    File No. 000-33501

Dear Ms. Livingston:

On behalf of our client, Northrim BanCorp, Inc., an Alaska corporation (the “Company”), and
pursuant to the applicable provisions of the Securities Exchange Act of 1934, as amended, and the
rules promulgated thereunder, reference is made to your letter dated July 17, 2008, containing
certain comments regarding the above-referenced Form 10-K for the Fiscal Year Ended December 31,
2007, filed on March 14, 2008. We have carefully reviewed and considered each comment contained in
that letter, and would respectfully submit in response the proposed actions indicated below. For
ease of reference, each of your comments is set forth below with our response set forth immediately
below.

Staff’s Comment No. 1 : 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

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 critical accounting measurements, such as for determining the adequacy of the allowance
for loan losses and the valuation of the investment portfolio. The disclosure should address the
following:

Securities and Exchange Commission

September 11, 2008

Page 2

    •

    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 Item III.D of the Commission’s Proposed Release Nos. 33-8098 and
34-45907.

Response:

Please be advised that the Company will address these items in future filings and that it has
addressed these items in Note 5 to the Consolidated Financial Statements (page 10) and in the
section titled “Critical Accounting Policies (pages 16 and 17) in the Management Discussion and
Analysis in the Company’s Form 10-Q for the quarter ended June 30, 2008 filed with the Commission
on August 11, 2008.

Staff Comment No. 2: Form 10-K for the Fiscal Year Ended December 31, 2007, Analysis of the
Allowance for Loan Losses, page 14

We note that in 2007 the allowance for loan losses was $11.7 million, a $360,000 decrease as
compared to 2006 resulting 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 nonperforming loans decreased to 84% as compared to 104% as of December 31, 2007.
Considering 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 which the nonperforming loans are fully or partially
collateralized and the nature of the underlying collateral.

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    •

    The frequency for which the company obtained updated appraisals for your relatively
higher risk commercial and construction loans, which are 59% of your loan portfolio and
the majority of your nonperforming loans and charge-offs.

    •

    Any material changes in the credit characteristics of the loan portfolio as a result
of the acquisition of Alaska First in October 2007 stated in Note 2 on page 40.

Response:

The increase in nonperforming loans between December 31, 2007 and March 31, 2008 in general has
been caused by an increase in nonperforming residential construction and land development loans
which have increased due to several factors. First, there has been a slowdown in the residential
real estate sales cycle in the Company’s major markets that has been caused, in part, by more
restrictive mortgage lending standards that has decreased the number of eligible purchasers for
residential properties. Second, the slowdown in the sales cycle has led to slower absorption of
residential lots. Third, a number of the Company’s residential construction and land development
borrowers have been unable to profitably operate in this slower real estate market. As noted above,
as a result of the slower residential real estate market, the Company expects that its level of
lending in this sector will decrease which will lead to a lower level of earnings from this portion
of its loan portfolio, which in turn could decrease the Company’s overall cash flow and liquidity
levels.

In determining its total Allowance, the Company first estimates a specific allowance for impaired
loans. For loans that are collateral-dependent (which is substantially all of the Company’s
impaired loans), this analysis is based upon a specific analysis for each impaired loan, including
appraisals on loans secured by real property, management’s assessment of the current market, recent
payment history and an evaluation of other sources of repayment. The non-performing construction
and land development loans referenced in the Staff’s comments are assessed as part of this element
of our Allowance process.

With regard to our appraisal process, the Company obtains appraisals on real and personal property
that secure its loans during the loan origination process in accordance with regulatory guidance
and its loan policy. The Company obtains updated appraisals on loans secured by real or personal
property based upon its assessment of changes in the current market or particular projects or
properties, information from other current appraisals, and other sources of information. The
Company uses the information provided in these updated appraisals along with its evaluation of all
other information available on a particular property as it assesses the collateral coverage on its
performing and nonperforming loans and the impact that may have on the adequacy of its Allowance.

In October 2007, the Company acquired $13.2 million in loans as a part of its acquisition of Alaska
First Bank & Trust, N.A. (“Alaska First”). The Company has determined that acquisition of
these loans did not cause any material changes in the risk characteristics of the Company’s loan
portfolio.

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Securities and Exchange Commission

September 11, 2008

Page 4

Please be advised that the Company will address these items in future filings.

Staff Comment No. 3: Form 10-K for the Fiscal Year Ended December 31, 2007, Analysis of the
Allowance for Loan Losses, page 14

We refer to the last paragraph on page 14 that states the increase in nonperforming loans and
potential problem loans has been factored into the company’s methodology for analyzing its
allowance for loan losses. In future filings, please expand your discussion regarding your
methodology for determining the appropriateness 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 groupings and the methods for determining the loss
factors to be applied to these grouping should be described.

    •

    A SFAS 114 credit risk analysis with respect to losses on specific evaluations of
known loss in individual loans.

    •

    The basis for estimating the impact of environmental 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
separate allowance element should be discussed.

    •

    The extent to which the company obtains current appraisals on collateral of
relatively higher risk commercial and construction loans.

Response:

Please be advised that the Company will address these items in future filings and has addressed
these items in Note 5 to the Consolidated Financial Statements (page 10) and in the sections titled
“Nonaccrual, Accruing Loans 90 Days or More Past Due and Restructured Loans” (page 28) and
“Analysis of Allowance for Loan Losses and Loan Loss Provision” (page 29) in the Management
Discussion and Analysis in the Company’s Form 10-Q for the quarter ended June 30, 2008 filed with
the Commission on August 11, 2008.

Comment No. 4: Form 10-K for the Fiscal Year Ended December 31, 2007, Recent Accounting
Pronouncements, page 26

We note the company states it believes the adoption of the issuance of SFAS 141R, SFAS 157, and
SFAS 160 will not have a significant impact on its financial statements. Please tell us and in

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Securities and Exchange Commission

September 11, 2008

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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 adoption is required and the
date that the company plans to adopt it, if earlier adoption is permitted.

    •

    A discussion of the methods of adoption allowed by the standard and the method
expected to be used by the 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 financial statements, disclose the potential impact
that might result from adoption of the standard, such as technical violations of debt
covenants.

Response:

In December 2007, the Financial Accounting Standards Board issued Statement of Financial Accounting
Standards No. 141(revised 2007), Business Combinations (“SFAS 141R”). SFAS 141R modifies
the accounting for business combinations and requires, with limited exceptions, the acquirer in a
business combination to recognize 100 percent of the assets acquired, liabilities assumed, and any
noncontrolling interest in the acquiree at the acquisition-date fair value. In addition, SFAS 141R
requires the expensing of acquisition-related transaction and restructuring costs, and certain
contingent assets and liabilities acquired, as well as contingent consideration, to be recognized
at fair value. SFAS 141R also modifies the accounting for certain acquired income tax assets and
liabilities. SFAS 141R is effective for new acquisitions consummated on or after January 1, 2009
and early adoption is not permitted. The Company does not expect that adoption of SFAS 141R will
impact the Company’s financial condition and results of operations or otherwise materially impact
the Company.

In September 2006, the Financial Accounting Standards Board issued Statement of Financial
Accounting Standards No. 157, Fair Value Measurements (“SFAS 157”). This statement defines
fair value, establishes a framework for measuring fair value in generally accepted accounting
principles, and expands disclosures about fair value measurements. This Statement applies whenever
assets or liabilities are required or permitted to be measured at fair value under currently
existing standards. No additional fair value measurements are required under this Statement. The
Company adopted SFAS 157 on January 1, 2008 and there was no material effect on its results of
operations or otherwise.

In December 2007, the Financial Accounting Standards Board issued SFAS No. 160, Noncontrolling
Interests in Consolidated Financial Statements (“SFAS 160”). SFAS 160 requires all entities
to report noncontrolling (i.e., minority) interests in subsidiaries as equity in the Consolidated
Financial Statements and to account for transactions between an entity and noncontrolling owners as
equity transactions if the parent retains its controlling financial interest in the subsidiary.
SFAS 160 also requires expanded disclosure that distinguishes between the interests of the
controlling owners and the interests of the noncontrolling owners of a subsidiary. SFAS 160

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Securities and Exchange Commission

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is effective for the Company’s financial statements for the year beginning on January 1, 2009 and
earlier adoption is not permitted. The Company does not expect that adoption of SFAS 160 to have a
material impact on the Company’s financial condition and results of operations or otherwise
materially impact the Company.

Please be advised that the Company will include such expanded disclosure regarding these items in
future filings and that it has addressed these items in Note 2 to the Consolidated Financial
Statements (pages 8 and 9) in the Company’s Form 10-Q for the quarter ended June 30, 2008 filed
with the Commission on August 11, 2008.

Comment No. 5: Financial Statements for the Period Ended December 31, 2007, Note 1.
Organization and Summary of Significant Accounting Policies, page 37

We note the company has subsidiaries that provide investment advisory services, insurance brokerage
services, mortgage lending and wealth management services. Please tell us and disclose in future
filings your consideration of providing the segment reporting information required by SFAS 131 and
related MD&A disclosure.

Response:

Please be advised that based upon a review of the quantitative and qualitative requirements of SFAS
131, the Company believes that it operates as one segment and that separate segment reporting and
related MD&A disclosure is not required for these services. Our conclusion is based on the
following analysis:

Paragraph 10 of SFAS 131 provides the definition of an operating segment as a component of an
enterprise:

    (a)

    That engages in business activities from which it may earn revenues and
incur expenses (including revenues and expenses relating to transactions with other
components of the same enterprise),

    (b)

    Whose operating results are regularly reviewed by the enterprise’s
chief operating decision maker (“CODM”) to make decisions about resources
to be allocated to the segment and assess its performance, and

    (c)

    For which discrete financial information is available.

To apply Statement 131, an essential first step is to identify the CODM. SFAS 131 indicates that
the CODM is the function (not necessarily one person) that is responsible for allocating resources
to, and assessing the performance of, the segments of an enterprise (SFAS 131, ¶12). In the case
of the Company, the CODM is the CEO.

Next, in accordance with paragraphs (b) and (c) above, an evaluation of reporting to the CODM

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Securities and Exchange Commission

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must be performed. This includes reports to the CODM regarding a component’s operating results on
a quarterly or more frequent basis, financial results provided to the Board