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CORRESP
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    correspondence.htm

                   LAW
      OFFICES

                  CORRESP.

      Elias,
Matz, Tiernan & Herrick L.L.P.

      11TH
FLOOR

      734 15TH
STREET, N.W.

      WASHINGTON,
D.C. 20005

      _______

      TELEPHONE:  (202)
347-0300

      FACSIMILE:   (202)
347-2172

      WWW.EMTH.COM

      August
11, 2008

      VIA
FAX AND EDGAR

      Christian
Windsor

      U.S.
Securities and Exchange Commission

      Division
of Corporation Finance

      Mail Stop
4561

      100 F
Street, N.E.

      Washington,
D.C. 20549

      Re:       Home
Bancorp, Inc.

      Registration
Statement on Form S-1

      File No.
333-151492

      Dear Mr.
Windsor:

      Pursuant
to my recent conversation with you and Kate McHale, this is to confirm on behalf
of Home Bancorp, Inc. (the “Company”) that any loans which are outstanding from
Home Bank to any director, executive officer or other related person, as such
term is defined in Item 404 of Regulation S-K:

                (i)

                were
      made in the ordinary course of
business;

                (ii)

                were
      made on substantially the same terms, including interest rates and
      collateral, as those prevailing at the time for comparable loans with
      persons not related to the Bank;
and

                (iii)

                did
      not involve more than the normal risk of collectibility or present other
      unfavorable features.

      Attached
is a proposed change page to the prospectus clarifying the above which will be
included in the Companys’ prospectus filed pursuant to Rule 424(b).

      Christian
Windsor

      August 11, 2008

      Page 2

      We
believe that the enclosed responds sufficiently to the staff’s
comment.  Please do not hesitate to call me at the above-listed number
if there are any further questions or if I can be of assistance in any
way.

      As
always, the staff’s cooperation is greatly appreciated.

                  Very
      truly yours,

                  /s/Hugh
      T. Wilkinson

                  Hugh
      T. Wilkinson

                  cc:        Kate
      McHale

                  John
      W. Bordelon

                  Raymond A. Tiernan, Esq.

      the
conversion, no individual officer or employee may receive more than 25% of the
shares granted under the plan and non-employee directors may not receive more
than 5% individually, or 30% in the aggregate of the shares granted under the
stock recognition and retention plan.  Applicable Office of Thrift
Supervision regulations provide that, in the event such plan is implemented
within one year after the conversion, shares granted under the plan generally
are required to vest over at least a five year period at no faster than 20% per
year.  In addition, applicable regulations of the Office of Thrift
Supervision require that if the stock recognition and retention is adopted
within twelve months after the conversion, it must be approved by a majority of
the total votes eligible to be cast by shareholders.  If the stock
recognition and retention plan is implemented more than one year after the
conversion, the plan must be approved by a majority of the shares of the Company
present and voting at the meeting of shareholders.  The Company
intends that the stock recognition and retention plan will comply with all then
applicable regulation of the Office of Thrift Supervision.

      The stock
recognition and retention plan will be administered by a committee of the
Company’s board of directors, which will have the responsibility to invest all
funds contributed to the trust created for the stock recognition and retention
plan.  We will contribute sufficient funds to the trust so that it can
purchase, following the receipt of shareholder approval, a number of shares
equal to an aggregate of 4.0% of the common stock issued in the conversion,
which would be 229,500 shares or 357,075 shares based on the minimum and 15%
above the maximum of the offering range, respectively.  Shares of
common stock granted pursuant to the stock recognition and retention plan
generally will be in the form of restricted stock vesting as described
above.  For accounting purposes, compensation expense in the amount of
the fair market value of the common stock at the date of the grant to the
recipient will be recognized pro rata over the period during which the shares
are payable.  A recipient will be entitled to all voting and other
shareholder rights, except that the shares, while restricted, may not be sold,
pledged or otherwise disposed of and are required to be held in the
trust.  Under the terms of the stock recognition and retention plan,
recipients of awards will be entitled to instruct the trustees of the stock
recognition and retention plan as to how the underlying shares should be voted,
and the trustees will be entitled to vote all unallocated shares in their
discretion.  If a recipient’s employment is terminated as a result of
death or disability, all restrictions will expire and all allocated shares will
become unrestricted.  We will be able to terminate the stock
recognition and retention plan at any time, and if we do so, any shares not
allocated will revert to the Company.  Recipients of grants under the
stock recognition and retention plan will not be required to make any payment at
the time of grant or when the underlying shares of common stock become vested,
other than for certain recipients, payment of withholding taxes.

      Transactions With Related Persons

      Loans and
Extensions of Credit.  The Bank offers mortgage
loans to its directors, officers and employees as well as members of
their immediate families for the
financing of their primary residences and certain other loans.  These
loans areand others who are
considered “related persons” under Item 404 of Regulation S-K of the
SEC.  Any loans by the Bank to related persons were made in the
ordinary course of business on substantially the same terms, including interest
rates and collateral, as those prevailing at the time for comparable
transactions with non-affiliated
persons
not related to the Bank.  These loans neitherdid not
involve more than the normal risk of collectibility noror present
other unfavorable features to the
Bank.

      Section
22(h) of the Federal Reserve Act generally provides that any credit extended by
a savings institution, such as the Bank, to its executive officers, directors
and, to the extent otherwise permitted, principal stockholder(s), or any related
interest of the foregoing, must be on substantially the same terms, including
interest rates and collateral, as those prevailing at the time for comparable
transactions by the savings institution with non-affiliated parties; unless the
loans are made pursuant to a benefit or compensation program that (i) is widely
available to employees of the institution and (ii) does not give preference to
any director, executive officer or principal stockholder, or certain affiliated
interests of either, over other employees of the savings institution, and must
not involve more than the normal risk of repayment or present other unfavorable
features.

      The aggregate amount of
loans by the Bank to its executive officers and directors was approximately
$830,000 at March 31, 2008, or approximately 1.62% of total equity at such
date.  These loans were performing according to their original terms
at March 31, 2008.  None of the Bank’s loans to any of its directors,
executive officers or any of their immediate family members were non-accrual,
past due, restructured or deemed potential problem loans at December 31, 2007 or
March 31, 2008.