SecProbe.io

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September 28, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (610)366-1900

Mr. Mark W. Jaindl
President and Chief Executive Officer
American Bank Incorporated
4029 West Tilghman Street
Allentown, PA 18104

Re:	American Bank Incorporated
	Form 10-K for the Fiscal Year Ended December 31, 2004

Dear Mr. Jaindl:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comments are inapplicable or a revision
is
unnecessary.  Please be as detailed as necessary in your
explanation.
In our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not 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 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, filed on March 30, 2005

Management`s Discussion and Analysis of Financial Condition and
Results of Operations
1. Please include in future filings a separately-captioned section
discussing your off-balance sheet arrangements within Management`s
Discussion and Analysis of Financial Condition and Results of
Operations as required by Item 303(c) of Regulation S-B.

Asset Quality

Non-Performing Assets and Delinquencies, page 17
2. We note that you have described resolution and foreclosure
proceedings in process as of December 31, 2004.  In future
filings,
please provide a more robust discussion of your resolution
process,
including the assets obtained in satisfaction of loans, and ensure
that the disclosures for foreclosed assets are included.  Refer to
the guidance in FAS 15, FAS 114, and SOP 01-6.

Financial Statements as of and for the years ended December 31,
2004
and 2003

Note 4 - Securities, page F-15
3. You have recorded $522,000 in gross unrealized losses on your
U.S.
Government agency preferred stock securities as of December 31,
2004,
which is an increase of $249,000 from December 31, 2003, and these
securities are shown as having been in a continuous loss position
for
12 months or more.  Please provide in your response letter your
analyses supporting your belief that an other-than-temporary
impairment did not exist at December 31, 2004, at March 31, 2005,
or
at June 30, 2005.   Refer to the guidance in paragraph 16 of SFAS
No.
115 and SAB Topic 5:M.  Your response should include but not be
limited to the names of the securities, purchase dates and prices,
current amortized cost, respective unrealized losses and other
information you consider in your periodic analysis.

* * * * *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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 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 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 Amanda Roberts at (202) 551-3417 or me at
(202)
551-3490 if you have questions.

Sincerely,

      Donald Walker
Senior Assistant Chief Accountant

Mr. Mark W. Jaindl
American Bank Incorporated
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