SecProbe.io

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Mail Stop 4561
								August 4, 2005

By U.S. Mail and Facsimile to (209) 830-6981

John O. Brooks
Chief Executive Officer
Service 1st Bancorp
2800 West March Lane, Suite 120
Stockton, California, 95219

Re:	Service 1st Bancorp
	Form 10-KSB for Fiscal Year Ended December 31, 2004
      Filed March 31, 2005
	File No. 000-50323

Dear Mr. Brooks:

      We have reviewed your filing and have the following
comments.
We have limited our review to the issues addressed in our
comments.
We think you should revise your future filings 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
provide us drafts of your intended revisions.   Please be as
detailed
as necessary in your explanation.  In some of our comments, we may
ask you to provide us with information so we may better understand
your disclosure.  After reviewing this information, we may 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.

Note 1: Summary of Significant Accounting Principles, page 42

Loans, page 43
1. We note your loan sale disclosures and the related activity
reflected in the statements of cash flows.  Please revise to
disclose
how your accounting for sold loans complies with SFAS 65, which
states that a loan shall not be classified as a long term
investment
unless the enterprise has both the intent and ability to hold the
loan for the foreseeable future.  Noting both the nature of the
loans
and the recurrence of your sales activity, it appears that the
loans
sold were originated with the intent to be sold.  If this is true,
please provide us a schedule of the origination and sale activity
for
sold loans for the periods presented and include the relevant
balance
sheet, income statement and cash flow statement disclosures
required
under SOP 01-6.  Disclose if you have recourse obligations under
your
sales agreements, and if you do, how you account for them,
including
the amount of any recorded recourse liability.
2. Please revise to disclose how your policy for recognizing more
amortization for loan servicing rights when prepayments and
expected
cash flows do not agree with management`s estimates complies with
paragraph 17(e) of SFAS 140 and provide the disclosures required
by
that paragraph for servicing assets.
3. Please revise to disclose the method used to recognize
servicing
assets in income.
4. Please revise here or in MD&A to provide a discussion of
specifically how your loan sale agreements are structured such
that
these transactions result in the recognition of an interest-only
strip.  Also, disclose the amount of these assets capitalized in
each
period, the material assumptions used to initially record them and
the method and assumptions used to subsequently measure them.

* * * * *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter with your response indicating your intent to provide
the
requested disclosures in future filings.  Please provide us drafts
of
your proposed revisions and any requested 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 to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 Margaret Fitzgerald at (202) 551-3556 or me
at
(202) 551-3851 if you have questions regarding comments on the
financial statements and related matters.

      Sincerely,

      Paul Cline
      Senior Accountant

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John O. Brooks
Service 1st Bancorp
August 4, 2005
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