SecProbe.io

Mail Stop 4561

July 2, 2008

By U.S. Mail and Facsimile (202)347-2172

John W. Bordelon President and Chief Executive Officer Home Bancorp, Inc.  503 Kaliste Saloom Road Lafayette, LA 70508
Re: Home Bancorp, Inc.
Registration Statement on Form S-1
Filed June 6, 2008
 File No. 333-151492
Dear Mr. Bordelon:

We have reviewed your filing and have th e 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 commen t is inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry 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 or  may not raise additional comments.

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 welcome any
questions you may have about our comments or on any other aspect of our review.  Feel free to
call us at the telephone numbers lis ted at the end of  this letter.
 General

1. Please file all exhibits with your next amen dment; they are subject to staff review.
2. We note that your Employee Stock Ownership plan intends to purch ase shares in the
offering and then distribute them to employ ees as compensation; please include the Plan
as a Co-Issuer to your registration statement.

John W. Bordelon
Home Bancorp, Inc.
July 2, 2008 Page 2  Risk Factors

General

3. We note that several of your risk factors contemplate hypothetical risks as opposed to
known material risks.  For example, the second risk factor claims that your allowance for
loan losses may not be adequate but it is not clear whether th is is a known risk or merely
the nature of an allowance.  Revise the noted  risk factor, and all other risk factors to
clarify the likelihood of the noted risk occurr ing and discuss any specific concerns that
caused management to decide that  the noted risk was a material risk factor.  For example,
in the second risk factor on page 15, discuss any actual losses due to  Hurricanes during
the past few years.
4. Some of your risk factors c ontain language like: “no assu rance can be given” and “we
can not guarantee.”  The risk fact ors must discuss the nature of  the specific risk, not your
ability to provide assurance.  Please remove all such disclo sure from the risk factors
section and make sure that all risk factors address the particular risk rather than your
ability to offer assurance.
 Market Area and Competition, page 51

5. When providing statistical information, please disclose your source for such information.
 Transactions with Related Persons, page 89

6. Please provide the representations contemplat ed by Instruction 4(c)  of Item 404(a) of
Regulation S-K.

Proposed Management Purchases, page 90
7. Please disclose by footnote to the table how  each director qualif ies to exceed the
individual purchase limitation.

Subscription Offering and Subscription Rights, page 96
8. Please disclose the treatment of joint account holders as to eligibility to purchase shares.  In particular, please explain whether joint account holders will be able to purchase
independently or whether they will they be tr eated as one eligible account holder for the
purpose of purchase limitations.

John W. Bordelon
Home Bancorp, Inc.
July 2, 2008 Page 3  Tax Aspects, page 105

9. Revise the heading so that it is more desc riptive of the information contained in this
section.  For example, consider using th e heading “Material Federal Income Tax
Consequences of the Conversion.”
 Exhibit 8.1; Tax Opinion of Hunton & Williams

10. You can limit reliance on your opinion with re gard to purpose, but not person.  Please
revise the last paragraph.
*      *      *

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 direct your attention to Rules 460 and 461 regarding requesting acceleration of a
registration statement.  Please a llow adequate time after the fili ng 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.
  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 comp any and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.       Notwithstanding our comments, in the even t 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 purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission 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

John W. Bordelon
Home Bancorp, Inc.  July 2, 2008 Page 4
‚ 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 advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divisi on 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 accelerat ion are aware of their
respective responsibilitie s under the Securities Act of 1933 and the Securities Exchange Act of
1934 as they relate to the proposed public offeri ng of the securities specified in the above
registration statement.  We w ill act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.
 Please contact Kate McHale at (202) 551-3464 or me at (202) 551-3419 with any
questions.          S i n c e r e l y ,
        C h r i s t i a n  W i n d s o r
 cc: Raymond Tiernan
Hugh Wilkinson Elias, Matz, Tiernan & Herrick LLP 734 15
th Street, N.W.
12th Floor
Washington, DC 20005