SecProbe.io

May 21, 2010
By U.S. Mail and facsimile: (515) 222-2346
Mr. David D. Nelson
Chief Executive Officer and President West Bancorporation, Inc. 1601 22
nd Street
West Des Moines, IA 50266
Re: West Bancorporation, Inc.         Form 10-K for fiscal year ended December 31, 2009  File Number 000-49677

 Dear Mr. Nelson:

We have reviewed the above referenced filing and related materials and have the
following comments.  Where indicated, we thin k your documents should be revised.  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 other
comments, where indicated, we think you should revise your document in response to these
comments in future filings.  In your response, pleas e indicate your intent to include the requested
revision in future filings and pr ovide us a draft of your proposed disclosures.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosures.  After reviewing this info rmation, we may have additional comments.
             The purpose of our review process is to assist you in your comp liance 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 we lcome 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.  Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Loan Portfolio, page 18

1. We note that your real estate – construction, land and land devel opment loan portfolio totaled
$148.5M as of December 31, 2009 which represented about 15% of your total loan portfolio.
We also note that it appears that this portfolio  has a relatively high amount of credit risk.
Please tell us and revise future filings to disc lose the following information related to loan
portfolio with interest reserves, as applicable:

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 2
• Disclose the amount of such loans and the accompanying interest re serves as of each
period-end;
• Disclose how you monitor such projects throughout their lives to make sure the properties are moving along as planned such that it is appropriate to c ontinue to capitalize
the interest on the loan;
• Disclose whether you have ever extended, rene wed or restructured terms of the related
loans, and the reasons for the changes;
• Describe your underwriting process for loans with interest reserves, and any specific
differences in how your underwrite loans with in terest reserves and loans that do not have
interest reserves; and
• Disclose whether any of your loans with interest reserves  are currently on nonaccrual
status.
 Risk Elements, page 21

 2. We note your disclosure on page 21 that outstanding loans of $46.727M were placed on non-accrual during 2009. We also note your disclosu re of the ending balance of non-accrual loans
and the amount of charge-offs recorded during th e year related to non-acc rual loans. Please
tell us and revise future Fo rm 10-K filings to provide a tabular roll forward of your
nonperforming loans and assets, which include non- accrual loans, simila r to that provided on
page 30 of your Form 10-Q for the period ended March 31, 2010.
 3. As a related matter, please revise future f ilings to present your nonperforming loans included
within your nonperforming assets table disaggregated by each lo an type. Please also provide
us this information as of March 31, 2010 and December 31, 2009.
 Item 8.  Financial Statements and Supplementary Data

 Note 1. Organization and Nature of Business and Summary of Signifi cant Accounting Policies

Loans, page 43
 4. We note your disclosure that a lo an is classified as restructur ed when the interest rate is
materially reduced or the term is extended beyond the original maturity date because of the inability of the borrower to service the loan at market terms. We also note that restructured
loans have increased from $12.8M as of December 31, 2009 to $16.6M as of March 31,
2010. We also note disclosure in Exhibit 99.2 of  your Form 8-K filed on April 30, 2010 that
you are currently earning interest on these restructured loans and that 90% are current less
than 30 days past due. Please address the following:

• Clearly label these rest ructurings as troubled-debt restru cturings (TDRs) pursuant to ASC
310-40;

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 3
• Tell us whether at the time the loan is restru ctured you continue to accrue interest. If so,
tell us all of the factors you consider in making this determin ation so as to be reasonably
assured of repayment and performance according to the modified terms;
• For your restructurings that accrue interest at the time the loan is restructured, please tell
us in detail and disclose how you determine that the loan has been restructured so as to be
reasonably assured of repayment and of perf ormance according to the modified terms and
is supported by a current, well-documented cred it assessment of the borrower’s financial
condition and prospects for repayment under the revised terms;

• For your restructurings that accrue interest at the time the loan is restructured, tell us and
disclose whether you have charged-off any porti on of the loan.  If you have, please tell us
how you concluded that repayment of intere st and principal contractually due on the
entire debt is reas onably assured;
• Disclose how you determine whether the borrower has demonstrated repayment
performance with modified terms.  Specifically disclose how many payments the borrower needs to make before retu rning a loan to accrual status; and
• Quantify the types of concessions made (i.e. re duction in interest rate, extensions of the
loan’s maturity, or other actions) distingui shing between each loan product along with a
discussion of your success with thes e different types of concessions.
 Note 3. Securities, page 48

 5. We note your disclosure on page 50 that dur ing 2009 you recognized $2.267M in other-than-
temporary impairment relating to five single-issu er trust preferred secu rities, four of which
were subsequently sold. We also note disc losure on page 8 that you liquidated these
securities during the seco nd half of 2009 in order to reduce cr edit risk in your  portfolio. As a
result, please compare and contra st how you determined which secu rities to sell as compared
to the pooled trust preferred security with a fair value and unrealized loss of $1.136M and
$3.475M as of December 31, 2009, respectively, and the other two si ngle-issuer trust
preferred securities that you decided to retain.

6. We note your disclosure that as a result of  the adoption of a new accounting pronouncement
(ASC 320-10-35) you recorded a cumulative effect adjustment to increa se beginning retained
earnings by $2.622M, which represents 100% of  the other-than-temporary impairment
recorded during quarter ended December 31, 2008 re lated to a pooled trust preferred security.
Please tell us in detail how you determined th at the entire amount of other-than-temporary
impairment was not credit-related. Additionally, pleas e tell us if there were any differences in
the assumptions/inputs used in the cash flow analysis for your calculation of the cumulative
effect adjustment and your discounted cash flow s calculation used to determine whether there
was an adverse change in estimated cash flows as of December 31, 2008, which is prior to
your adoption of the provisions of ASC 320-10-65. If  there were differenc es, please identify
them, explain why you believe the differences we re appropriate and identify any accounting
guidance that supports your position.

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 4   7. We note that as of December 31, 2009, you had thr ee trust preferred secu rities with current
unrealized losses that have existed for longe r than one year. Considering the significant
judgment required to determine if a security is other than temporarily impaired and the focus
users of financial statements have placed on this  area, we believe comprehensive and detailed
disclosure is required to meet the disclosure  requirements in ASC 310-20-50 and Item 303 of
Regulation S-K for your material loss exposure.   Therefore, for each individual and pooled
trust preferred security with at least one rati ng below investment grade, please revise future
filings to disclose the following information as of the most recent period end: single-issuer or
pooled, class, book value, fair valu e, unrealized gain/loss, lowest  credit rating a ssigned to the
security, number of banks curre ntly performing, actual deferrals and defaults as a percentage
of the original collateral, expected deferrals and defaults as a percentage of the remaining
performing collateral and excess subordination as a percentage  of the remaining performing
collateral.  Please also clearly disclose how  you calculate excess subordination and discuss
what the excess subordination percentage signi fies, including relati ng it to other column
descriptions, to allow an investor to unde rstand why this information is relevant and
meaningful. Additionally, please provide us with this inform ation as of March 31, 2010 and
December 31, 2009.

8. We note disclosure that you engage d an independent consulting firm  to assist in the valuation
of your pooled trust preferred security as of December 31, 2009. Please provide us with a
detailed description of the other-than-temporar y impairment analysis you performed on these
securities as of December 31, 2009. In your response, please address your consideration of
the following:

• Discount rate: tell us and disclose in future filings how you determine the discount rate to
use in your calculation.
• Deferrals and defaults:
a. Please tell us in detail how you develop your esti mate of future deferrals and defaults.
b. Tell us and disclose in future filings if you treat actual deferrals the same as defaults.
c. Tell us and disclose in future filings your recover rate assumption and how you
determine it.  Specify if you have different recovery rates for actual defaults as
compared to actual or estimated future deferrals.
• Prepayment rate: Tell us how you determined  no prepayments of the underlying debt is a
reasonable assumption. Otherwise, please provide us with a sensitivity analysis of the change in credit loss at December 31, 2009 if you used a 1% prepayment assumption.
 9. For your two single-issuer trust preferred securities for which you disclose on page 50 that the unrealized losses are due to reduced demand along with interest rate fluctuations and
illiquid markets, not estimated cash flows, pl ease provide us a detaile d description of the
other-than-temporary impairment analysis  you performed as of March 31, 2010 and
December 31, 2009.  Please identify all of the ev idence you considered, explain the relative
significance of each piece of evidence, and iden tify the primary evidence on which you relied
to support a realizable va lue equal to or greate r than the carry ing value of the investment.

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 5    Note 16. Fair Value Measurements, page 62

 10. We note disclosure on page 64 that for collat eral-dependent impaired loans fair value is
determined based on appraisals by qualified licensed appraisers. We also note that appraised and reported values may be discounted based on historical knowledge, changes in market conditions from the time of valuation, and/or your expertise and knowledge of the client and
their business. As it relates to these loans, please tell us and revise your future filings, to
include the following enhanced disclosures:
• The approximate amount or percentage of im paired loans for which the Company relied
on current third party appraisals of the collatera l to assist in measuring impairment versus
those for which current apprai sals were not available;
• The typical timing surrounding the recogni tion of a collateral dependent lending
relationship and respective loans as nonpe rforming, when you order and receive an
appraisal, and the subsequent recognition of any provision or related charge-off. In this
regard, tell us if there have been any significant time lapses during this process;
• In more detail, the procedures you perform to  monitor these loans be tween the receipt of
an original appraisal and the updated appraisal;
• Whether you have charged-off an amount differe nt from what was determined to be the
fair value of the collateral as presented in the appraisal for any pe riod presented.  If so,
please tell us the amount of the difference and corresponding reasons for the difference,
as applicable;
• How you account for any partially charged-off loans subsequent to receiving an updated
appraisal. In this regard, specifically tell us your policies regarding whether or not these
loans return to performing or remain non-performing status, in additi on to whether or not
any of the terms of the original  loans have been modified (e .g. loan extension, changes to
interest rates, etc);
• In the event that you do not use external appraisals to fair value the underlying collateral
for impaired loans or in cases where the appr aisal has not been updated to reflect current
market conditions, please provide us with  a comprehensive response which discusses
your process and procedures for estimating the fa ir value of the collat eral for these loans;
and
• For those loans you determined that no speci fic valuation allowance was necessary, the
substantive reasons to su pport this conclusion.

Item 11.  Executive Compensation

Compensation Committee Report, page 9
 11. We note that you have not included any disclosure  in response to Item 402(s) of Regulation
S-K.  Please advise us of the basis of your c onclusion that disclosure is not necessary and
describe the process you undertook to reach that conclusion.

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 6   Summary Compensation Table, page 16

 12. We note that you have provided disclosures for only one named executive officer (Mr. Winterbottom) that may be considered a covered person in accordance with Item
402(a)(3)(iii) rather than three such individuals  as the rule requires.  Please revise your Form
10-K to satisfy the requirements of Item 402(a)(3)(iii).
    *  *  *  *  *
  Please respond to these comments within 10 business days or tell us when you will
provide us with a response.  Please submit all correspondence and supplemental materials on
EDGAR.  Please furnish a cover letter that ke ys your response to our comments, provide any
requested information and provide us drafts of pr oposed revisions to future filings in response to
our comments.  Please understand that we may have additional comments after reviewing any
amendment and your response to our comments.    We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.     In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with res