SecProbe.io

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       June 21, 2005

Mark R. Ruh
White River Capital, Inc.
250 North Shadeland Avenue
Indianapolis, Indiana 46219

Re:	White River Capital, Inc.
	Amendment No. 1 to Registration Statement on Form S-1 and
Form
S-4
      Filed June 10, 2005
	File No. 333-123909

Dear Mr. Ruh:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document 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 be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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.

Pro Forma Financial Information, page 52

1. If White River Inc. now expects to consummate the creditor
buyout
in advance of the share exchange and the subscription offering
using
bridge funding to be provided by Castle Creek private equity funds
instead of an advance from Coastal Credit, please revise the
headnote
to the pro forma information and the order of the pro forma
columns
to reflect the new plan. In addition, all other related changes
should be made to the filing.

Exhibits
Bridge Loan Agreement

2. File the bridge loan agreement as an exhibit.

Consents

3. File currently dated consents of the independent public
accountants.

					*	*	*

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental 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 filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert this action as 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

      You may contact Chris Harley at (202) 551-3695 or Don
Walker,
Senior Assistant Chief  Accountant, (202) 551-3490 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3491 with any other
questions.

						Sincerely,

						Todd K. Schiffman
						Assistant Director

cc:	Eric R. Moy, Esq.
	Julie A. Russell, Esq.
	Barnes & Thornburg LLP
	11 South Meridian Street
	Indianapolis, Indiana 46204

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Mark R. Ruh
White River Capital, Inc.
June 21, 2005
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