SecProbe.io

January 6, 2012

Via E-mail
Mr. Paul Frenkiel   Chief Financial Officer  and Secretary
The Bancorp, Inc.   409 Silverside Road   Wilmington, DE 19809
Re: The Bancorp, Inc.
Form 10-K for Fiscal Year Ended December 31, 2010  Filed February 23, 2011 Form 10-Q for the Quarterly Period Ended September 30, 2011 Filed November 9, 2011  Form 8-K filed October 20, 2011 File No. 000-51018

Dear Mr. Frenkiel:
We have reviewed your filings and have the following comments. In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. Where we have requested changes in future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclo sures. If you do not believe our
comments apply to your facts and circumstances or  do not believe an amendment is appropriate,
please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, including the draf t of your proposed disclosures, we may have
additional comments.

Form 10-K for Fiscal Year Ended December 31, 2010

 Notes to Consolidated Financial Statements

 Note B – Summary of Accounting Policies

 18. Stored Value Processing Fees, page 68

 Paul Frenkiel   The Bancorp, Inc.   January 6, 2012   Page 2
 1. Please revise your future filings to disclose  your accounting policy for the different types
of cardholder fees (e.g. upfront fees, usage fees, reloadable fees, overdraft fees, etc.) your
record.  Provide us with your proposed disclosures.

Form 10-Q for Quarterly Period Ended September 30, 2011
  Notes to the Consolidated Financial Statements

 Note 5. Investment Securities, page 11

2. We note your held-to-maturity investments in four single issuer pref erred trust securities
where the amortized cost is significantly in  excess of fair value. Please address the
following as it relates to each of the individua l single issuer trust pr eferred securities:

 Provide us with a detailed description of the OTTI analysis performed on each
security at each reporting period be ginning with December 31, 2010 through the
interim periods of fiscal 2011.  Identify a ll of the evidence cons idered, explain the
relative significance of  each piece of evidence, and identify the primary evidence on
which you relied to support your conclusi on of the recording of any OTTI;
 Tell us how you evaluated the financial c ondition of the issuer at each quarterly
reporting period;
 Tell us if any of the issuer s is subject to a regulatory agreement and if so, how you
considered and evaluated the regulatory agre ement within the context of the quarterly
OTTI analysis (if applicable);
 Provide us with the discounted cash flow analysis used to determine fair value at each
quarterly period; and
 Provide us with the assumptions and estimat es used in the fair value measurements
addressing the basis for, as well as any cha nges in and reasons fo r the changes in, the
assumptions or estimates, which may have occurred during these periods.

3. Considering the significant judgm ent required to determine if  a security is other than
temporarily impaired and the focus users of fi nancial statements have placed on this area,
we believe comprehensive and detailed disclo sure 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 po oled trust preferred se curity with at least
one rating below investment grade, please re vise your future filings to disclose the
following information (in tabular format) as of  the most recent period end: single-issuer
or pooled, class, book value, fair value, unreali zed gain/loss, lowest credit rating assigned
to the security, number of banks currently pe rforming, actual deferrals and defaults as a
percentage of the original collateral, expected  deferrals and defaults as a percentage of
the remaining performing co llateral and excess subordinatio n as a percentage of the
remaining performing collateral.  Additionall y, please clearly disclose how you calculate
excess subordination and discuss what the excess subordination pe rcentage signifies,

 Paul Frenkiel   The Bancorp, Inc.   January 6, 2012   Page 3
 including relating it to other column descriptio ns, to allow an investor to understand why
this information is relevant and meaningful.
 Note 6. Loans, page 19

4. In regard to the loans which have been classi fied as “unrated” please tell us the amount of
loans which are subject to review which have not yet been reviewed for each of the loan
categories. Tell us your policies for these loans addressing when these loans will be
reviewed.

Note 7. Transactions with Affiliates, page 20

5. We note you purchased securities from Princerid ge in the third quarter of fiscal 2011.
Tell us, and disclose in your future filings, which securities were purchased (e.g. RMBSs,
CMBS, etc.), quantify any am ount of fee or commission pa id, and discuss where the
securities are classified within your inve stment securities (e.g. AFS, HTM, etc.).

6. In regard to the loan particip ation, tell us and disclose in your future filings, the amount
of the loan held by the Company and whethe r there have been a ny delinquencies on the
loan to date.

Item 2. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Current Developments, page 26

7. Please revise your MD&A in future filings to provide a specific and thorough discussion
of the impact the cancellation of the agreem ent with the affinity group will have on your
financial condition and resu lts of operations.

8. In regards to the alleged vi olations, tell us how you ev aluated ASC Topic 450-20-50 in
your disclosures. In your response please addr ess the contractual indemnifications which
have been entered into with the third part y in regard to portions  of the liabilities
stemming from the alleged violations.
Allowance for loan and lease losses, page 35

9. Please tell us, and revise your future filings to disclose, the following asset quality credit
metrics for each of the periods presented and provide a narrative discussion addressing the changes therein as warranted:

 Ratio of the allowance for lo an losses to total loans;
 Ratio of the allowance for loan  losses to nonperforming loans;

 Paul Frenkiel   The Bancorp, Inc.   January 6, 2012   Page 4
  Ratio of the nonperforming asse ts to total assets; and
 Ratio of net charge-offs to average loans.

Form 8-K filed October 20, 2011

10. Please revise your future filings to change  the name of your non-GAAP measure to more
accurately reflect its content.  In this rega rd, the use of the word “core” implies you are
referring to your most central or essential ope rations and results.  Removal of income tax
expense, gains on sales of investment securities , OTTI charges, losses on other real estate
owned and the provision for loan and lease losses and other credit costs to arrive at
“core” earnings implies that these activities  are not an inherent part of your core
operations.  Thus, we believe it would be appr opriate to use a more descriptive title to
describe this non-GAAP measure, eliminating the use of the word "core" in its entirety in
the title.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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 responding to our comments, please provi de a written 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.

 Paul Frenkiel   The Bancorp, Inc.   January 6, 2012   Page 5

You may contact Marc Thomas, Staff Account ant, at (202)551-3452 or me at (202)551-
3872  with any questions.
  Sincerely,
   /s/ Hugh West
Hugh West
          Accounting Branch Chief