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CORRESP
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    Unassociated Document

    April 21,
2010

    Mr.
Christian Windsor

    Division
of Corporation Finance

    United
States Securities and Exchange Commission

    450 Fifth
Street, N.W.

    Washington,
D.C. 20549

              Re:

              Kentucky
      First Federal Bancorp

    Form 10-K for the Fiscal Year Ended
June 30, 2009

    File No. 0-51176

    Dear Mr.
Windsor:

    This
letter is in response to your letter dated April 7, 2010, in which you provide
comments pursuant to your review of the above-referenced filing of Kentucky
First Federal Bancorp (“KFFB”) and your request for our response to those
comments.

    Our
response will be provided in the same format as outlined in your letter and is
as follows:

    Form 10-K for the year ended
June 30, 2009

    Item
7.  Management’s Discussion and Analysis of Financial Condition and
Results of Operations

    Statement of Financial
Condition

    Loans, page
11

                1.

                We
      note your response to comment #2 to our letter dated February 17, 2010 and
      the fact that Borrower B requested to make interest only payments for a
      period of time.  Please tell us the following concerning this
      borrower:

    Christian
Windsor

    Securities
and Exchange Commission

    April 21,
2010

    Page
2

    Item 1
comment (continued):

              ·

              whether
      or not you granted the request to make interest-only payments for a period
      of time;

              ·

              if
      you did grant the request to allow interest-only payments, the specific
      period of time for which the interest-only payments were granted, if the
      borrower has returned to paying principal plus interest as of the most
      recent date and whether or not you expect to collect all contractual
      amounts due;

              ·

              whether
      or not there were any other modifications of the terms of the debt;
      and

              ·

              whether
      or not you considered this to be a troubled debt
      restructuring.  If you did determine this was a troubled debt
      restructuring, please tell us and revise future filings to discuss the
      impact.

    Item 1
Response:  With regard to Borrower B’s request to make interest-only
payments for a period of time:

                ·

                We
      did grant the borrower’s request to make interest-only payments for a
      period of time;

                ·

                We
      agreed to allow interest-only payments until December 2009, and the
      borrower has not returned to paying principal plus interest as of March
      31, 2010; at this time we do not expect to collect all contractual amounts
      due;

                ·

                There
      were not any other modifications of the terms of the debt;
    and

                ·

                We
      did not consider this to be a troubled debt restructuring (“TDR”), because
      there was no modification of the debt terms, which are usually associated
      with a TDR:

              v

              Reduction
      in stated interest rate.

              v

              Extension
      of maturity.

              v

              Reduction
      in the face amount of the debt.

              v

              Reduction
      in the accrued interest.

                  2.

                  We
      note your response to comment #4 to our letter dated February 17,
      2010.  Please specifically tell us, and revise future filings to
      disclose how frequently you obtain updated appraisals for your collateral
      dependent loans.  If this policy varies by loan type please
      disclose that also.  Describe any adjustments you make to the
      appraised values, including those made as a result of outdated
      appraisals.  Discuss how you consider the potential for outdated
      appraisal values in your determination of the allowance for loan
      losses.

    Christian
Windsor

    Securities
and Exchange Commission

    April 21,
2010

    Page
3

    Item 2
Response:  For non-homogenous loans we obtain updated appraisals when
we determine that a loan has become collateral-dependent and we suspect that the
previous appraisal may no longer be reflective of the property’s current market
value.  This process varies from loan to loan, borrower to borrower,
and also varies based on the nature of the collateral.  Although all
of our loans are secured by collateral, we rely heavily on the capacity of our
borrowers to generate sufficient cash flow to service their debt.  As
a result, our loans do not become collateral-dependent until there is
deterioration in the borrower’s cash flow and financial condition, which makes
it necessary for us to look to the collateral for our sole source of
repayment.  We utilize the updated appraisals for the
collateral-dependent loans in determining our FAS114 specific
reserve.  In the calculation of our general valuation allowance we
consider the potential for outdated appraisal values to be of minimal risk and,
therefore, do not attribute a specific factor to it.

    In
connection with our response to your comments, we acknowledge 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.

    Sincerely,

    /s/ R.
Clay Hulette

    R. Clay
Hulette

    Vice
President and Chief Financial Officer

              cc:

              Gregory
      Dundas

    David Irving

    William Schroeder