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 Suite 2200

1201 Third Avenue

Seattle, WA 98101-3045

Marcus J. Williams

206.757.8170 tel

206.757.7170 fax

marcwilliams@dwt.com

September 29, 2014

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street NE

Washington, D.C. 20549-4561

Attention:    Mr. Gus Rodriguez

Re:

 HomeStreet, Inc.

 Form 10-K for the Fiscal Year Ended December 31, 2013 (the “Report”)

 File No. 001-35424

On behalf of our client, HomeStreet, Inc. (the “Company”), and pursuant to the applicable provisions of the Securities Exchange Act of 1934, as amended, and the rules promulgated thereunder, set forth below are responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “SEC” or “Commission”) that were set forth in the Staff’s letter dated September 16, 2014, regarding the Report. We have carefully reviewed and considered each comment contained in that letter, and would respectfully submit the proposed responses and actions as indicated below. For ease of reference, the text of each of the Staff’s comments is set forth below followed in each case by our response.

General

Staff Comment No. 1: Please provide us and revise future filings to include a complete description of your loan underwriting policies and procedures for each loan category and for each major loan type within each category, as appropriate. Also, please expand the footnotes to the financial statements to discuss the risks characteristics surrounding your receivables. Refer to ASC 310-10-50-11B (a) 2.

Attached as Annex A is a more complete description of the Registrant’s loan underwriting policies and procedures for each loan category and for each major loan type within each category. The Registrant also includes herewith a discussion of the material risk characteristics pertaining to its receivables. In future quarterly reports on Form 10-Q and annual reports on Form 10-K, and subject to further review and input

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from the Staff, the Registrant will include a more complete discussion of loan underwriting policies and procedures in the Credit Risk Management section of the Company’s Management’s Discussion and Analysis and an expanded discussion of the risk characteristics of our receivables in the footnotes to its financial statements similar to the attached.

Staff Comment No. 2: You classify dividends received from your banking subsidiary of $19,600 in 2013 as cash flows from financing activities. Please tell us why you classified these cash inflows to the parent company as financing cash flows as opposed to operating cash flows. Please refer to ASC 230-10-45-16(b) for specific guidance on how to classify dividends received on a statement of cash flows.

Upon further review the Registrant acknowledges that the parent company condensed cash flows disclosure included in Note 21 to the financial statements of the Annual Report on Form 10-K for the year ended December 31, 2013 did not accurately classify the dividends received from our banking subsidiary within the Parent Company Condensed Statement of Cash Flows for the subject periods. While the nature of this parent company condensed cash flows was transparently disclosed in a separate condensed cash flows line item as Dividend from banking subsidiary, such was inaccurately classified within cash flows from financing activities instead of within the net cash used in operating activities.  However, with the separate condensed cash flows line item, we believe the information disclosed provided the users with sufficient information to evaluate the nature of the parent company’s cash flows and meets the standards’ objectives of providing relevant information about the cash receipts and cash payments of an entity during the period. This information appears only in the notes to the Registrant’s financial statements filed with the Report, and is not addressed in the Liquidity and Capital Management section of Management’s Discussion and Analysis. The Registrant has concluded that this error is not material, and because the parent company condensed statement of cash flows is an annual disclosure item, the Registrant respectfully submits that corrective disclosure of this immaterial misstatement be made in the Registrant’s notes to the financial statements for the fiscal year ending December 31, 2014. In addition, the Registrant evaluated the related control deficiency and concluded that such did not represent a material weakness in the design and operating effectiveness of its internal controls over financial reporting and disclosure controls and procedures. The Registrant respectfully offers as Annex B disclosure that the Registrant would, subject to the Staff’s review, expect to include with its Annual Report on Form 10-K for the period ended December 31, 2014. The Registrant respectfully submits that the additional information set forth on Annex B transparently discloses the correction of the error, nature of the error and the effect on the related parent company condensed statements of cash flow line items.

The Company acknowledges that:

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 the Company is responsible for the adequacy and accuracy of the disclosure in its filings;

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 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to such filings; and

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 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.

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Thank you for providing the Company with the opportunity to respond to your comments. Please do not hesitate to contact Marcus J. Williams at (206) 757-8170 if you have any questions or concerns, or if you would like to discuss the substance of this letter or the documents referred to herein.

Very truly yours,

Davis Wright Tremaine LLP

/s/ Marcus J. Williams

Marcus J. Williams

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ANNEX A

The excerpt below is our current disclosure on loan underwriting policies and procedures, found on page 94 of the Credit Risk Management section of the Company’s Annual Report on Form 10-K for the year ended December 31, 2013:

Our underwriting standards for single family and home equity loans require evaluating and understanding a borrower’s credit, collateral and ability to repay the loan. Credit is determined based on how well a borrower manages their current and prior debts, documented by a credit report that provides credit scores and the borrower’s current and past information about their credit history. Collateral is based on the type and use of property, occupancy and market value, largely determined by property appraisals. A borrower's ability to repay the loan is based on several factors, including employment, income, current debt, assets and level of equity in the property. We also consider loan-to-property value and debt-to-income ratios, loan amount and lien position in assessing whether to originate a loan. Single family and home equity borrowers are particularly susceptible to downturns in economic trends that negatively affect housing prices and demand and levels of unemployment.

For commercial, multifamily and construction lending, we consider the same factors with regard to the borrower and the guarantors. In addition, we evaluate liquidity, net worth, leverage, other outstanding indebtedness of the borrower, an analysis of cash expected to flow through the borrower (including the outflow to other lenders) and prior experience with the borrower. We use this information to assess financial capacity, profitability and experience. Ultimate repayment of these loans is sensitive to interest rate changes, general economic conditions, liquidity and availability of long-term financing.

Below is a more complete description of the Company's underwriting policies and procedures to be included in the Company's future filings:

Our underwriting standards for single family and home equity loans require evaluating and understanding a borrower’s credit, collateral and ability to repay the loan. Credit is determined based on how well a borrower manages their current and prior debts, documented by a credit report that provides credit scores and the borrower’s current and past information about their credit history. Collateral is based on the type and use of property, occupancy and market value, largely determined by property appraisals. A borrower's ability to repay the loan is based on several factors, including employment, income, current debt, assets and level of equity in the property. We also consider loan-to-property value and debt-to-income ratios, loan amount and lien position in assessing whether to originate a loan. Single family and home equity borrowers are particularly susceptible to downturns in economic trends that negatively affect housing prices and demand and levels of unemployment.

For commercial, multifamily and construction loans, we consider the same factors with regard to the borrower and the guarantors. In addition, we evaluate liquidity, net worth, leverage, other outstanding indebtedness of the borrower, an analysis of cash expected to flow through the borrower (including the outflow to other lenders) and prior experience with the borrower. We use this information to assess financial capacity, profitability and experience. Ultimate repayment of these loans is sensitive to interest rate changes, general economic conditions, liquidity and availability of long-term financing.

Additional considerations for commercial permanent loans secured by real estate:

Our underwriting standards for commercial  permanent loans generally require that the loan-to-value ratio for these loans not exceed 75% of appraised value or discounted cash flow value, as appropriate, and that commercial properties attain debt coverage ratios (net operating income divided by annual debt servicing) of 1.25 or better.

Our underwriting standards for multifamily residential permanent loans generally require that the loan-to-value ratio for these loans not exceed 80% of appraised value, cost, or discounted cash flow value, as appropriate, and that multifamily residential properties attain debt coverage ratios of 1.2 or better. However, underwriting standards can be influenced by competition and other factors. We endeavor to maintain the highest practical underwriting standards while balancing the need to remain competitive in our lending practices.

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Additional considerations for commercial construction loans secured by real estate:

We originate a variety of real estate construction loans. Underwriting guidelines for these loans vary by loan type but include loan-to-value limits, term limits, loan advance limits and pre-leasing requirements, as applicable.

Our underwriting guidelines for commercial real estate construction loans generally require that the loan-to-value ratio not exceed 75% and stabilized debt coverage ratios of 1.25 or better.

Our underwriting guidelines for multifamily residential construction loans generally require that the loan-to-value ratio not exceed 80% and stabilized debt coverage ratios of 1.2 or better.

Our underwriting guidelines for single family residential construction loans to builders generally require that the loan-to-value ratio not exceed 85%.

As noted above, underwriting standards can be influenced by competition and other factors. However, we endeavor to maintain the highest practical underwriting standards while balancing the need to remain competitive in our lending practices.

The excerpt below is our current disclosure on risk characteristics surrounding our receivables, found in Note 6 Loans and Credit Quality of the Company’s Annual Report on Form 10-K at and for the year ended December 31, 2013:

Credit Quality Indicators

Management regularly reviews loans in the portfolio to assess credit quality indicators and to determine appropriate loan classification and grading in accordance with applicable bank regulations. The Company’s internal AQR grading scale is comprised of 10 grades. Each individual loan is given an internal risk rating scale from 1 through 10. A brief description of these grades is as follows:

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 Pass. We have five pass classification grades which represent a level of credit quality that ranges from no well-defined deficiency or weakness to some noted weakness, however the risk of default on any loan classified as pass is expected to be remote.

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 Watch. A loan graded as watch has a remote risk of default, but is exhibiting deficiency or weakness that requires monitoring by management.

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 Special Mention. A special mention loan does not currently expose us to a sufficient degree of risk to warrant an adverse classification, but does possess a correctable deficiency or potential weakness deserving management’s close attention.

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 Substandard. A substandard loan is inadequately protected by the current secured worth and paying capacity of the borrower or of collateral pledged on the loan, if any. Loans so classified must have a well-defined weakness or weaknesses that jeopardize the liquidation of the debt, such as a high probability of payment default and are characterized by the distinct possibility that the institution will sustain some loss if deficiencies are not corrected.

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 Doubtful. A loan classified as doubtful has all of the weaknesses inherent in those classified substandard, with the added characteristic that the weaknesses make collection or liquidation in full, on the basis of currently existing facts, conditions and values, highly questionable or

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improbable. Doubtful is considered to be a temporary classification until resolution of pending weaknesses enables us to more fully evaluate the potential for loss.

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 Loss. That portion of a loan classified as loss is considered uncollectible and of so little value that its characterization as an asset is not warranted. A loss classification does not mean that an asset has absolutely no recovery or salvage value, but rather it is not reasonable to defer charging off all or that portion of the asset deemed uncollectible even though partial recovery may occur in the future.

Below is a more complete description of the Company's risk characteristics surrounding our receivables to be included in the Company's future filings:

Credit Quality Indicators

Management regularly reviews loans in the portfolio to assess credit quality indicators and to determine appropriate loan classification and grading in accordance with applicable bank regulations. The Company's risk rating methodology assigns risk ratings ranging from 1 to 10, where a higher rating represents higher risk. The Company differentiates its lending portfolios into homogeneous loans and non-homogeneous loans. The 10 risk rating categories can be generally described by the following groupings for non-homogeneous loans:

Pass. We have five pass risk ratings which represent a level of credit quality that ranges from no well-defined deficiency or weakness to some noted weakness, however the risk of default on any loan classified as pass is expected to be remote. The five pass risk ratings are described below:

Minimal Risk. A minimal risk loan, risk rated 1-Exceptional, is to a borrower of the highest quality. The borrower has an unquestioned ability to produce consistent profits and service all obligations and can absorb severe market disturbances with little or no difficulty.

Low Risk. A low risk loan, risk rated 2-Superior, is similar in characteristics to a minimal risk loan. Balance sheet and operations are slightly more prone to fluctuations within the business cycle; however, debt capacity