SecProbe.io

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                                  [Muldoon Murphy Faucette & Aguggia Letterhead]

                                November 4, 2004

VIA EDGAR AND COURIER (SEC MAIL STOP 0408)

Barry McCarty, Esq.
Senior Counsel
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

                  Re:      Kentucky First Federal Bancorp
                           Form S-1 filed September 16, 2004
                           File No. 333-118597

                           Frankfort First Bancorp, Inc.
                           Proxy Statement filed September 16, 2004
                           Form 10-K for the Fiscal Year Ended June 30, 2004
                           File No. 0-26360

Dear Mr. McCarty:

         On behalf of Kentucky First Federal Bancorp (the "Company"), enclosed
for filing is Pre-Effective Amendment No. 1 to the Registration Statement on
Form S-1 (the "Amended Registration Statement"), including exhibits, marked
pursuant to Rule 472 under the Securities Act of 1933, as amended, to indicate
changes from the Registration Statement on Form S-1 filed on September 16, 2004
(the "Registration Statement").

         In addition, on behalf of Frankfort First Bancorp, Inc. (the
"Frankfort"), enclosed for filing are amended preliminary proxy materials (the
"Amended Proxy Statement"), marked to indicate changes to the preliminary proxy
materials filed by Frankfort on September 16, 2004 (the "Proxy Statement"), and
Amendment No. 1 to the Annual Report on Form 10-K (the "Amended Form 10-K"),
marked to indicate changes from the Annual Report on Form 10-K filed on
September 30, 2004 (the "Form 10-K").

         The Amended Registration Statement, the Amended Proxy Statement and the
Amended Form 10-K are filed in response to the staff's comment letter issued on
October 15, 2004. To aid in your review, we have repeated the staff's comments
followed by the Company's and/or

<PAGE>

Barry McCarty, Esq.
November 4, 2004
Page 2

Frankfort First's responses and indicated where the applicable document has been
revised in response to such comments. The prospectus also reflects revised
disclosure in response to comments received from the Office of Thrift
Supervision ("OTS") on the Application on Form MHC-2 by the Company. A copy of
the OTS response letter, which includes all OTS comments and the Company's
responses, has been included with this filing.

REGISTRATION STATEMENT ON FORM S-1 FOR KENTUCKY FIRST BANCORP

COMMENT NO. 1:

Please advise the staff, with a view towards revised disclosure, how Kentucky
First will meet its minimum offering amounts in the event that only a small
percentage of the Frankfort First shareholders elect to take Kentucky First's
shares as merger consideration.

RESPONSE TO COMMENT NO. 1

         In the extreme case assuming the minimum number of Frankfort First
shareholders were to elect to receive Kentucky First common stock in the merger,
then Kentucky First would be required to pay the most of the merger
consideration of $31.2 million in cash. Specifically, because directors and
officers of Frankfort have indicated their intention to elect to receive
347,152, shares of Kentucky First common stock in the merger, the Prospectus
reflects the assumption that the minimum possible number of shares to be issued
in the merger is 347,152 and that the remaining cost of the merger would be
$28.7 million in cash. In that event, in order to complete the offering Kentucky
First would be required to sell at least the remainder of the minimum of the
offering range, or 2,486,250 shares less 347,152 shares, for a total of
2,139,098 shares, for cash. Even at the minimum of the range, Kentucky First
would retain net proceeds of $16.4 million. After receipt of the $14.9 million
cash distribution from Kentucky First, Kentucky First would have sufficient
funds to pay $28.7 million in cash in the merger. In connection with its
regulatory applications to the OTS, First Federal of Hazard has requested
approval to pay a cash distribution to Kentucky First of from $4.1 to $14.9
million to enable it to pay for the acquisition of Frankfort First. Under these
circumstances, following completion of the offering and the merger, Kentucky
First would retain cash totaling $3.6 million, and First Federal of Hazard would
have tangible capital of 10.6% of adjusted total assets. At higher points within
the offering range, the amount of cash retained by Kentucky First and First
Federal of Hazard's capital levels both increase.

COMMENT NO. 2:

Please advise that staff whether the offering will terminate in the event that
the shareholders of Frankfort First do not approve the merger. Also, please
provide the staff with the expected timetable for events, including the
commencement of soliciting proxies for the merger and the commencement of the
offering.

RESPONSE TO COMMENT NO. 2

<PAGE>

Barry McCarty, Esq.
November 4, 2004
Page 3

         Assuming the Registration Statement is declared effective and the Proxy
Statement is approved by the Securities and Exchange Commission staff on
November 11, 2004, Kentucky first intends to mail its offering materials and
Frankfort First will commence its proxy solicitation on November 22. Kentucky
First will terminate its offering in approximately the third week of December
2004, and Frankfort First will hold its meeting of shareholders in late
December, 2004. The offering and the merger would be expected to close on the
same day in early to mid-January 2005.

         In the event Kentucky First shareholders do not approve the merger,
First Federal of Hazard will terminate the reorganization and the offering.
First Federal of Frankfort is undertaking the reorganization for the purpose of
consummating the merger, and will not consummate the merger or the
reorganization unless it can complete both the merger and the reorganization.
Disclosure to this effect is provide on page 12.

Cover Page:

COMMENT NO. 3:

Revise the cover page so that it more directly discusses the reorganization
transaction. Currently we are not able to find the rank order for participation
by eligible account holders, the ESOP plan or any supplemental account holders.
Also, please separate your discussions so that the impact of the merger is
discussed separately from the reorganization transactions and the rights that
the eligible account holders have in the transaction.

RESPONSE TO COMMENT NO. 3

The cover page has been revised in response to this comment.

COMMENT NO. 4:

The cover page presents a significant amount of information in a dense typeset.
Please revise the disclosure on this page to only include information required
by Item 501 or necessary to an investment decision. For example, consider
providing an accurate but concise discussion of the minimum offering amount and
the variable nature of the form of the merger consideration and refrain from
including technical details about how the merger will be accomplished or the
fate of the banking subsidiaries.

RESPONSE TO COMMENT NO. 4

The cover page has been revised in response to this comment.

COMMENT NO. 5:

It is not clear what "certain conditions" the best efforts offering is subject
to. Please revise to clarify or delete the reference.

<PAGE>

Barry McCarty, Esq.
November 4, 2004
Page 4

RESPONSE TO COMMENT NO.5

The reference to "certain conditions" has been deleted.

COMMENT NO. 6:

Please create a new paragraph, starting with the last sentence of the first
paragraph. In this new paragraph, disclose that you are using $___ millions in
cash proceeds from your conversion to acquire Frankfort First.

RESPONSE TO COMMENT NO. 6

The requested paragraph now appears as the second paragraph on the cover page of
the Prospectus.

SUMMARY - PAGE 1

COMMENT NO. 7:

Please consider moving the discussions of the conversion and the general
discussion of the merger transactions ahead of the descriptions of each of the
entities involved.

RESPONSE TO COMMENT NO. 7

The discussions of the conversion and the general discussion of the merger
transaction has been moved ahead of the descriptions of each of the entities
involved in the Summary section of the Prospectus. See page 1 of the Prospectus.

COMMENT NO. 8:

Provide a diagram illustrating the merger transactions and the respective
percentage of the resulting entity that will be held by both the Former
shareholders of Frankfort First and the depositors of First Federal of Hazard.

RESPONSE TO COMMENT NO. 8

In responding to this comment, it appeared to be confusing to provide a diagram
that would illustrate in a clear manner the respective percentage of the
resulting entity that will be held by the former shareholders of Frankfort First
and the depositors of Hazard other than the diagram that now appears on page 1
and the explanation below the table at the top of page 2 due to the fact that
preparation of that diagram would involve making an assumption as to whether the
Frankfort First shareholder elections would be as to the merger considerations.
Differing elections by the Frankfort First shareholders would result in
differing percentages of Kentucky First being owned by the former Frankfort
First shareholders and the First Federal of Hazard

<PAGE>

Barry McCarty, Esq.
November 4, 2004
Page 5

depositors. However, in lieu of a diagram, we have included a table on page 5
that sets out the percentages of the outstanding common stock of Kentucky First
that will be owned by the former Frankfort First shareholders, subscribers in
the reorganization offering and First Federal MHC under various assumptions as
to the final amount of stock sold and the extent to which Frankfort First
shareholders elect to receive Kentucky First common stock in the merger.

HOW WE DETERMINED THE OFFERING RANGE - PAGE 4

COMMENT NO. 9:

Please provide the staff with the calculations and assumptions used by the
appraiser in order to prepare the tabular presentation on page 5.

RESPONSE TO COMMENT NO. 9

This information will be provided to the Commission supplementally.

COMMENT NO. 10:

Please change the order of the two tabular presentations, as the converted
presentation more closely resembles the resulting company.

RESPONSE TO COMMENT NO. 10

The order of the tabular presentations has been changed on page 7 of the
Prospectus.

COMMENT NO. 11:

We note that the tabular presentation on page 5 that presents the valuation
multiples for Kentucky First, assuming the actual 45%/55% public/MHC stock
holdings and the valuation multiples for "National Mutual Holding Companies" and
does not include the similar valuation of the peer group used by Keller & Co. to
value Kentucky First. Revise the tabular presentation to also present the
relevant valuation multiples of the peer group.

RESPONSE TO COMMENT NO. 11

Keller & Company ("Keller") has advised the undersigned that the peer group
consists exclusively of fully converted public companies and excludes publicly
traded mutual holding companies. As a result, the peer group multiples would not
be relevant or comparable to Kentucky First upon issuance of 45% of its common
stock and would only be comparable if Kentucky First were considered on a fully
converted basis, as provided on the second table. Keller advises that mutual
holding companies cannot be part of the peer group because they do not all have
the same percentages of public shares. For instance, some mutual holding
companies may be 45% owned by the public, while others may be 30%-owned or
41%-owned by the public. Disclosure of this point is provided in footnote 1 to
the first table on page 7.

<PAGE>

Barry McCarty, Esq.
November 4, 2004
Page 6

COMMENT NO. 12:

Noting that on both a fully converted basis and on a pro-forma converted basis,
the company will be selling at a discount to the trading values of its peer
group by more than 25%, please include, under an appropriate heading,
managements analysis for why it chose to accept the lower valuation of Kentucky
Federal over the pricing multiples implied by the trading values of its peers.
The analysis should point to the factors that Keller & Co. cite for valuing the
company at a discount and should highlight why management decided to continue
with the reorganization despite the substantial discount to the peer group.

RESPONSE TO COMMENT NO. 12

Disclosure in response to this comment appears on page 9.

BENEFITS OF THE REORGANIZATION TO MANAGEMENT - PAGE 7

COMMENT NO. 13:

Please provide a table summarizing the estimated value of the benefits payable
under the employment agreements and change-in-control agreements, assuming a
triggering event as of a recent date.

RESPONSE TO COMMENT NO. 13

The disclosure on page 13 has been revised in response to this comment to
include a table outlining the estimated amounts that would be payable to the
officers covered by employment agreements upon a change in control immediately
following consummation of the merger and prior to December 31, 2004. We have not
referenced a specific date because the effective date of the merger is unknown
at this time, and the agreements (and payments thereunder) would not become
effective until completion of the transaction.

COMMENT NO. 14:

We note that you have placed a static value on the costs associated with the
restricted stock awards. In order for the investors to understand the effective
cost of this plan, please provide a range of potential values of the plan,
assuming different stock prices. Consider using the range of values ranging from
$8-14, as has been used in several recent conversions.

RESPONSE TO COMMENT 14

The table on page 14 has been expanded in response to this comment to estimate
the values of grants under the employee stock ownership plan and grants of
restricted stock awards at stock prices ranging from $8.00 to $14.00 per share.

<PAGE>

Barry McCarty, Esq.
November 4, 2004
Page 7

RISK FACTORS - PAGE 16

COMMENT NO. 15:

Add a risk factor that you are dependent upon regulatory approval from the OTS
in order for First Federal of Hazard to make the potentially large capital
contribution to Kentucky First in order to complete the merger. Please clarify
the amount of the expected contribution that exceeds the proceeds of the
offering, assuming that you raise the minimum offering amount and that 0% and
45% of the total outstanding shared of Kentucky First will be represented by
former Frankfort First shareholders.

RESPONSE TO COMMENT NO. 15

Kentucky First respectfully submits that such a risk factor is not necessary in
that we expect to receive OTS approval of the capital distribution in advance of
the mailing of the Prospectus. The amount of the expected capital distribution
needed to complete the merger is disclosed under "Use of Proceeds" in the table
and below the table on page 37.

RISING INTEREST RATES MAY HURT OUR PROFITS AND ASSET VALUES - PAGE 17

COMMENT NO. 16:

Revise this risk factor to include information as to the specific nature of your
exposure to an upward movement in interest rates. We note that both banks NPV
results indicated that they could suffer significant losses in value from an
upward movement in interest rates. Similarly, a reference to your individual or
combined gap position might better highlight the exposure that the two entities
face from an adverse movement in interest rates.

RESPONSE TO COMMENT NO. 16

The requested disclosure has been provided on page 19.

DUE TO OUR HIGH CAPITAL LEVELS... - PAGE 17

COMMENT NO. 17:

Revise the heading for this risk factor to clarify that the effect of lower ROE
levels than your peer groups might be that your share price might suffer.

RESPONSE TO COMMENT NO. 17

The requested disclosure has been provided on page 19 of the Prospectus.

<PAGE>

Barry McCarty, Esq.
November 4, 2004
Page 8

THE DISTRESSED ECONOMY IN FIRST FEDERAL OF HAZARD'S MARKET... - PAGE 18

COMMENT NO. 18:

Revise this risk factor to provide