SecProbe.io

June 26, 2013

Via E -mail
James Ropella
Chief Financial Officer
First Business Financial Services, Inc.
401 Charmany Drive
Madison, WI 53719

Re: First Business Financial Services, Inc.
Form 10 -K for the period ended December 31, 2012
Filed March  8, 2013
File No. 00 1-34095

Dear M r. Ropella :

We have reviewed your filing and 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 this letter within ten business days  by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and ci rcumstances  please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

December 31, 2012 Form 10 -K

General

1. We note you present the non -GAAP measure core earnings throughout your filing and in
other documents included in Form 8 -K’s.  Please revise future filings to change the name
of this non -GAAP measure to more accurately reflect its content.  In this regard, the use
of the word “core” implies you are referring to  your most central or essential operations
and results.  Removal of the provision for loan losses and other credit costs from net
income to arrive at “core” earnings implies that credit losses are not an inherent part of
your core operations.  Thus, we bel ieve it would be appropriate to use a more descriptive
title to describe this non -GAAP measure, perhaps eliminating the use of the word "core"
in its entirety.

James Ropella
First Business Financial Services, Inc.
June 26, 2013
Page 2

 Note 17 – Fair Value, page 97

2. Considering the wide range of the unobservable inputs used for i mpaired loans disclosed
on page 98, please revise future filings to disclose the weighted average of the
unobservable inputs.  Refer to ASC 820 -10-55-103 for example disclosure.

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 Exchange 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, please 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 Commission 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 Mike Volley  at 202-551-3437 or me at 202-551-3423  if you have any
questions.

Sincerely,

 /s/ Amit Pande

Amit Pande
Accounting Branch Chief