SecProbe.io

July 13, 2016
Mail Stop 4720

Via E -mail
Mr. Joseph Zanco
Chief Financial  Officer
Home Bancorp, Inc.
503 Kaliste Saloom Road
Lafayette, Louisiana 70508

Re: Home Bancorp, Inc.
 Form 10-K for the Fis cal Year Ended December 31, 2015
Filed March 14, 201 6
File No. 001 -34190

Dear Mr. Zanco :

We have reviewed your filing an d 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circums tances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Note 5 – Loans, page 59

1. We note your disclosure on page 62 that you have $20.0 million and $32.0 million of
acquired loans that were accounted for under ASC 310 -30 as of December 31, 2015 and
2014, respectively.   Please respond to the following:

 We note your disclosure on page 67 that states that nonaccrual acquired loans accounted
for under ASC 310 -30 totaled $4. 6 million and $11.8 million as of December 31, 2015
and 2014, respectively.   Please clarify whether you have ceased recognizing interest
income on these loans in accordance with ASC 310 -30.  If so, please explain your basis
for being unable to reasonably e stimate the cash flows for these loans.   Please refer to
ASC 310 -30-35-3 for guidance.

 Please tell us whether you have any loan pools under ASC 310 -30 that continue to have
loans, but no longer have any remaining accretable difference.   If so, please quan tify
those pools, and explain the factors driving zero accretable difference for these pools.

Mr. Joseph Zanco
Chief Financial  Officer
Home Bancorp, Inc.
July 13, 201 6
Page 2

 We note per page 56 of your disclosure that for two of your acquisitions, you show a
reclass from the accretable difference to the nonaccretable difference.   Please discuss
the basis for these transfers.

 We note per page 56 that for your GSFC acquisition, you show an accretable yield of
$0.05 million as of December 31, 2015, after a significant transfer of $1.2 million to
nonaccretable difference during 2015.   However, your disclosure also states that the
remaining weighted average contractual life of the loan portfolio with acquired
deteriorated credit quality for GSFC was 5.6 years.   Given the length of the remaining
life, please tell us why the accretable yi eld is so small.

Note 20 – Fair Value Disclosures, page 80

2. We note your disclosure  on page 82  that as of December  31, 2015 and 2014,  you have  $23.8
million and $39.0 million, respectively of assets recorded at fair value on a  non-recurring
basis and classified  as Level  3 measurements  in the fair value  hierarchy.   Included within
these totals, you have classified $19.9 million and $32.0 million of acquired loans with
deteriorated credit quality as of December 31, 2015 and 2014, respectively.   Please re spond
to the following:

 Tell us why you have categorized acquired loans with deteriorated credit quality as non -
recurring fair value measurements as of December 31, 2015 and 2014.   In this regard,
given that these loans are accounted for under ASC 310 -30, it is unclear why they would
be measured at fair value at these dates.

 Please tell us, and revise  future  filings  to disclose, the  quantitative  information  about  the
significant  unobservable  inputs used  in your Level 3  fair value measurement s as
required by ASC 820-10-50-2(bbb).

Item 11. Executive Compensation , page 88

Definitive Proxy Statement on Schedule 14A

Compensation Discussion and Analysis, page 13
Base Salary, page 14

3. In the last paragraph at the end of page 14 you state that the salaries of three named executive
officers, including Mr. Bordelon’s, the company’s President and Chief Executive Officer
were not adjusted in 2015.   Please explain this statement in light of M r. Bordelon’s salary
increase of over $100,000 in 2015.   In this regard, we note your Summary Compensation
Table disclosure on page 17.   In future filings please ensure that your disclosure explains
how the material factors considered by the compensation c ommittee resulted in actual
compensation decisions.

Mr. Joseph Zanco
Chief Financial  Officer
Home Bancorp, Inc.
July 13, 201 6
Page 3

 Incentive Bonuses, page 15

4. In future filings, please disclose the actual level of achievement for each applicable financial
target, and whether consideration of subjective individual performance evaluat ion impacted a
named executive officer’s ultimate bonus payment.   In addition, as these bonus amounts
appear to represent non -equity incentive plan compensation, in future filings please revise
your Summary Compensation Table to disclose them in accordance  with Item 402(c)(2)(vii)
of Regulation S -K.  Similarly, your Grants of Plan Based Awards table on page 18 should be
revised to reflect the threshold, target and maximum amount of estimated future payouts
under non -equity incentive plans in compliance with  Item 402(d)(2)(iii) of Regulation S -K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exc hange Act rules require.   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, pleas e provide  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 Commis sion 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.

You may contact  Cara Lubit  at 202-551-5909 or me at 202 -551-3512 if you have
questions regarding comments on the financial statements and related matters.  Please contact
Joshua Dilk at 202-551-3427 or Era Anagnosti  at 202-551-3369 with any other questions.

Sincerely,

 /s/ Stephanie L. Sullivan

Stephanie L. Sullivan
Senior Assistant Chief Accountant
Office of Financial Services