SecProbe.io

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Document

March 9, 2026

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Attention:   Madeleine Joy Mateo

Re:      West Bancorporation, Inc.

Request for Acceleration of Effectiveness of Form S-3

                        SEC File No. 333-293844 (“Registration Statement”)

Dear Ms. Mateo:

On behalf of West Bancorporation, Inc., as registrant, the undersigned officer hereby requests that the effective date for the Registration Statement be accelerated so that it will become effective at 3:00 p.m. (Washington, D.C. time), or as soon as practicable thereafter, on Wednesday, March 11, 2026.

Feel free to telephone Joseph T. Ceithaml of Barack Ferrazzano Kirschbaum & Nagelberg LLP, the registrant’s legal counsel, at (312) 629-5143 with any questions or comments.

Very truly yours,

West Bancorporation, Inc.

 /s/ David D. Nelson

David D. Nelson

Chief Executive Officer and President

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 5, 2026

David D. Nelson
Chief Executive Officer
West Bancorporation, Inc.
3330 Westown Parkway
West Des Moines, IA 50266

 Re: West Bancorporation, Inc.
 Registration Statement on Form S-3
 Filed February 27, 2026
 File No. 333-293844
Dear David D. Nelson:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
We remind you
that the company and its management are responsible for the accuracy and
adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

 Please contact Madeleine Joy Mateo at 202-551-3465 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Joseph T. Ceithaml, Esq.
</TEXT>
</DOCUMENT>

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Document

March 27, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Attention:   Ms. Susan Block

Re:      West Bancorporation, Inc.

Request for Acceleration of Effectiveness of Form S-3

                        SEC File No. 333-269988 (“Registration Statement”)

Dear Ms. Block:

On behalf of West Bancorporation, Inc., as registrant, the undersigned officer hereby requests that the effective date for the Registration Statement be accelerated so that it will become effective at 3:00 p.m. (Washington, D.C. time), or as soon as practicable thereafter, on Wednesday, March 29, 2023.

Feel free to telephone Joseph T. Ceithaml of Barack Ferrazzano Kirschbaum & Nagelberg LLP, the registrant’s legal counsel, at (312) 629-5143 with any questions or comments.

Very truly yours,

West Bancorporation, Inc.

 /s/ David D. Nelson

David D. Nelson

Chief Executive Officer and President

United States securities and exchange commission logo
March 7, 2023
Jane Funk
Chief Financial Officer
West Bancorporation, Inc.
1601 22nd Street
West Des Moines, Iowa 50266
Re:West Bancorporation, Inc.
Registration Statement on From S-3
Filed on February 24, 2023
File No. 333-269988
Dear Jane Funk:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Susan Block at 202-551-3210 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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		Document

March 9, 2020

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C.  20549

Attention:  Julia Griffith

Re:    West Bancorporation, Inc.

Request for Acceleration of Effectiveness of Form S-3

SEC File No. 333-236740 (the “Registration Statement”)

Dear Ms. Griffith:

On behalf of West Bancorporation, Inc., as registrant, the undersigned officer hereby requests that the effective date for the Registration Statement be accelerated so that it will become effective at 3:00 p.m. (Washington, D.C. time), or as soon as practicable thereafter, on Wednesday, March 18, 2020.

Feel free to telephone Emily Henkel of Barack Ferrazzano Kirschbaum & Nagelberg LLP, the registrant’s legal counsel, at (312) 629-5191 with any questions or comments.

Very truly yours,

West Bancorporation, Inc.

/s/ Douglas R. Gulling

Douglas R. Gulling

Executive Vice President, Treasurer

& Chief Financial Officer

March 5, 2020
James W. Noyce
Chairman of the Board
West Bancorporation, Inc.
1601 22nd Street
West Des Moines, IA 50266
Re:West Bancorporation, Inc.
Registration Statement on Form S-3
Filed February 28, 2020
File No. 333-236740
Dear Mr. Noyce:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Julia Griffith at 202-551-3267 with any questions.

Sincerely,
Division of Corporation Finance
Office of Finance

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		Document

March 13, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C.  20549

Attention:  David Lin

Re:    West Bancorporation, Inc.

Request for Acceleration of Effectiveness of Form S-3

SEC File No. 333-216393 (the “Registration Statement”)

Dear Mr. Lin:

As registrant to the above-referenced public offering, we hereby request that the effective date for the Registration Statement be accelerated so that it will be declared effective at 3:00 p.m. (Washington, D.C. time) on Monday, March 20, 2017 or as soon as practicable thereafter.

The undersigned officer of the registrant, on behalf of the registrant, acknowledges that:

▪

 should the Securities and Exchange Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Securities and Exchange Commission from taking any action with respect to the filing;

▪

 the action of the Securities and Exchange Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

▪

 the registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Securities and Exchange Commission or any person under the federal securities laws of the United States.

The staff should feel free to telephone Donald L. Norman of Barack Ferrazzano Kirschbaum & Nagelberg LLP, the registrant’s legal counsel, at (312) 984-3100 with any questions or comments.

Very truly yours,

West Bancorporation, Inc.

/s/ Douglas R. Gulling

Douglas R. Gulling

Executive Vice President & Chief Financial Officer

Mail Stop 4720

March 7, 2017

Via E -mail
Douglas R. Gulling
Executive Vice President, Treasurer , and
Chief Financial Officer
West Bancorporation, Inc.
1601 22nd Street
West Des Moines, IA 50266

Re: West Bancorporation, Inc.
  Registration Statement on Form S-3
Filed  March 2, 2017
  File No.  333-216393

Dear Mr. Gulling :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please  contact Kate Donovan, Staff Attorney, at (202) 551 -8636  with any questions.

Sincerely,

/s/ David Lin

David Lin
Senior Staff Attorney
Office of Financial Services

cc: Donald L. Norman, Jr., Esq.

September  27, 2013

Via E -mail
Doug Gulling
Chief Financial Officer
West Bancorporation, Inc.
1601 22nd Street
West Des Moines , IA 50266

Re: West Bancorporation, Inc.
Form 10 -K for the  period ended December 31, 2012
Filed March  6, 2013
  Form 10 -Q for the period ended June 30, 2013
Filed July 26, 2013
File No. 00 0-49677

Dear M r. Gulling :

We have completed our review of your filings.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s 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.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of 1934 and a ll applicable rules require.

Sincerely,

 /s/ Amit Pande

Amit Pande
Accounting Branch Chief

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		WTBA 09-18-2013 Correspondence

Confidential Treatment Requested by West Bancorporation, Inc., Pursuant to 17 C.F.R. § 200.83

September 18, 2013

VIA EDGAR SUBMISSION

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Amit Pande, Accounting Branch Chief

Re:    West Bancorporation, Inc.

Form 10-K for fiscal year ended December 31, 2012

Filed March 6, 2013

Form 10-Q for the period ended June 30, 2013

Filed July 26, 2013

File Number 000-49677

Dear Mr. Pande:

We are writing in response to the requests contained in the comment letter from the staff (the “Staff”) of the United States Securities and Exchange Commission (the “SEC”) dated September 5, 2013 (the “Comment Letter”).  For the convenience of the Staff, we have set forth the comments contained in the Comment Letter along with the responses of West Bancorporation, Inc. (the “Company”).

The Company respectfully requests confidential treatment for certain omitted sections of this response letter indicated by bracketed asterisks (“[***]”) below pursuant to 17 C.F.R. § 200.83 (“Rule 83”).  Pursuant to Rule 83, the Company's omitted responses will be provided to the Staff in hard copy under separate cover.  We request that these omitted sections be maintained in confidence, not made part of any public record and not be disclosed to any person because of the commercially sensitive nature of the omitted information.  In the event that the SEC receives a request for access to the confidential sections herein, whether pursuant to the Freedom of Information Act or otherwise, the Company respectfully requests that it be notified immediately so that it may further substantiate this request for confidential treatment under Rule 83.  Please address any notification of a request for access to such information to the undersigned, Douglas R. Gulling, Executive Vice President and Chief Financial Officer, West Bancorporation, Inc., 1601 22nd Street, West Des Moines, Iowa 50266.

The Company has filed a separate letter with the Office of Freedom of Information and Privacy Act Operations in connection with the confidential treatment request pursuant to Rule 83.

June 30, 2013 Form 10-Q

Note 7. Fair Value Measurements, page 24

1.

 Please revise future filings to provide quantitative information about the significant unobservable inputs used in the fair value measurement for each class of your recurring and nonrecurring measurements categorized within level 3. Refer to ASC 820-10-50-2-bbb for guidance and ASC 820-10-55-103 for example disclosure.

Response:  In future filings, the Company will provide quantitative information about the significant unobservable inputs used in the fair value measurement for each class of the Company's recurring and nonrecurring measurements categorized within level 3 according to the guidance in ASC 820-10-50-2-bbb and the examples in ASC 820-10-55-103.

Management's Discussion and Analysis of Financial Condition and Results of Operations - Provision for Loan Losses and the Related Allowance for Loan Losses, page 37

2.

 We observe from Note 4 on page 22 that the allowance for loan losses collectively evaluated for impairment as a percentage of loans collectively evaluated for impairment increased from December 31, 2012 to June 30, 2013 while we note improving trends in credit quality. Please tell us in detail and revise future filings to comprehensively discuss the reasons for this trend and its relationship with observed changes in the credit quality of your collectively evaluated portfolio for each period presented.

Please be as specific and detailed as needed to provide an investor with a clear understanding of the observed change in the credit quality of your collectively evaluated loan portfolio and how this change, as well as other key drivers, impacted your collectively evaluated allowance for loan losses. For instance, discuss trends in the types of loans and related credit risk included in this portfolio, trends in historical losses incorporated in your allowance methodology, and trends observed in specific qualitative factors.

Response:  The allowance for loan losses collectively evaluated for impairment as a percentage of loans increased slightly from 1.17 percent at December 31, 2012, to 1.26 percent at June 30, 2013, for two reasons.  First, the Company did not make any significant adjustments to any economic or other factors used to evaluate the loans in the second quarter.  While headlines would seem to indicate that the economy is improving, interest rates went up dramatically in the latter half of the second quarter and first quarter gross domestic product (“GDP”) was revised lower.  After reviewing these events, the Company concluded that the rise in interest rates could cause the economy to slow.  That, coupled with the revised first quarter GDP number and slowing growth rates world-wide, caused the Company to refrain from further lowering its economic factors until the Company has more clarity on the direction of the economy.

Second [***].

In future filings the Company will provide a comprehensive discussion of the relationship of the allowance in conjunction with credit quality of the collectively evaluated portfolio for each period presented.

The Company acknowledges 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.

The Company believes that the foregoing provides a complete response to the Comment Letter.  If you have any questions regarding the foregoing or require any additional information, please contact the undersigned at 515-222-2309.

Sincerely,

/s/ Douglas R. Gulling

Douglas R. Gulling

Executive Vice President and Chief Financial Officer

West Bancorporation, Inc.

September  5, 2013

Via E -mail
Doug Gulling
Chief Financial Officer
West Bancorporation, Inc.
1601 22nd Street
West Des Moines , IA 50266

Re: West Bancorporation, Inc.
Form 10 -K for the period ended December 31, 2012
Filed March  6, 2013
  Form 10 -Q for the period ended June 30, 2013
Filed July 26, 2013
File No. 00 0-49677

Dear M r. Gulling :

We have reviewed your filing s 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 advi sing us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances  please tell us why in your response.

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

June 30, 2013 Form 10 -Q

Note 7. Fair Value Measurements, page 24

1. Please revise future filings to provide quantitative information about the significant
unobservable inputs used in the fair value measurement for each class of your r ecurring
and nonrecurring measurements categorized within level 3.  Refer to ASC 820 -10-50-2-
bbb for guidance and ASC 820 -10-55-103 for example disclosure.

Doug Gulling
West Bancorporation, Inc.
September  5, 2013
Page 2

 Management’s Discussion and Analysis of Financial Condition and Results of Operations –
Provision  for Loan Losses and the Related Allowance for Loan Losses, page 37

2. We observe from Note 4 on page 22 that the allowance for loan losses collectively
evaluated for impairment as a percentage of loans collectively evaluated for impairment
increased from De cember 31, 2012 to June 30, 2013 while we note improving trends in
credit quality.  Please tell us in detail and revise future  filing s to comprehensively discuss
the reasons for this trend and its relationship with observed changes in the credit quality
of yo ur collectively evaluated portfolio for each period presented .

Please be as specific and detailed as needed to provide an investor with a clear
understanding of the observed change in the credit quality of your collectively evaluated
loan portfolio and how this change, as well as other key drivers, impacted your
colle ctively evaluated allowance for loan losses.  For instance, discuss trends in the types
of loans and related credit risk included in this portfolio, trends in historical losses
incorporated in your allowance methodology, and trends observed in specific qua litative
factors.

             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 A ct 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
questions .

Sincerely,

  /s/ Amit Pande

Amit Pande
Accounting Branch Chief

January 7, 2011

By U.S. Mail and facsimile: (515) 222-2346

Mr. David D. Nelson
Chief Executive Officer and President West Bancorporation, Inc. 1601 22
nd Street
West Des Moines, IA 50266
Re: West Bancorporation, Inc.
        Form 10-K for fiscal year ended December 31, 2009  Form 10-Q for the period ended September 30, 2010  File Number 000-49677

Dear Mr. Nelson:
We have completed our review of your fili ngs and do not have any further comments at
this time.
Sincerely,

Michael Clampitt Attorney- Advisor

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		WebFilings | EDGAR view

January 6, 2011

Mr. Michael Clampitt

Attorney-Advisor

Securities and Exchange Commission

Washington, D.C. 20549

Re:    West Bancorporation, Inc.

Form 10-K for fiscal year ended December 31, 2009

File Number 000-49677

Dear Mr. Clampitt:

I am writing in response to your letter dated November 17, 2010, to provide further explanation of the 2009 management structure of West Bancorporation, Inc. (the Company) and its subsidiary West Bank and the related disclosure of named executive officers.

In its Form 10-K for fiscal year 2009, the Company disclosed four named executive officers in the summary compensation table.  Messrs. Stanberry and Milligan had both served, not concurrently, as the joint chief executive officer of the Company and West Bank.  They had ultimate management control and responsibility for both companies and were substantially involved in the day-to-day operation of West Bank.  Mr. Winterbottom worked for and reported to them, even though his title was President of West Bank.  Mr. Winterbottom served as the chief lending officer and was intermediately responsible for all branch operations.  I was the Chief Financial Officer for both the Company and West Bank.  No other officer performed policy making functions for the Company or West Bank.  This management structure, although perhaps not typical for financial institutions the size of the Company and West Bank, has been a West Bank hallmark for many years.  West Bank has historically been recognized as one of the most efficient community banks in the country.

In addition to our historic lean management structures, I wish to highlight that in July 2009 the positions of chairman of the board and chief executive officer of the Company were separated.  Mr. Wahlig became Chairman of West Bancorporation's Board of Directors and, as a director, provided substantial day-to-day policy making input to both the Company and West Bank through April 2010.  A new permanent chief executive officer was named in April 2010 (David D. Nelson), and he subsequently created a new chief risk officer position.  Mr. Olafson was hired to fill that position and assumed policy making functions during the second half of 2010.  He will be included in the 2010 Form 10-K summary compensation table.  The Company will continue to separate the board chair and chief executive officer positions, at least for the foreseeable future.

I hope this additional information substantiates the Company's belief that the disclosure of named executive officers in its 2009 Form 10-K summary compensation table satisfied the requirements of Item 402(a)(3)(iii). Thank you for your further consideration of this matter.

Sincerely,

/s/ Douglas R. Gulling

Douglas R. Gulling

Executive Vice President and Chief Financial Officer

November 17, 2010
By U.S. Mail and facsimile: (515) 222-2346

Mr. David D. Nelson
Chief Executive Officer and President West Bancorporation, Inc. 1601 22
nd Street
West Des Moines, IA 50266
Re: West Bancorporation, Inc.         Form 10-K for fiscal year ended December 31, 2009  Form 10-Q for the period ended September 30, 2010  File Number 000-49677

 Dear Mr. Nelson:
 We have reviewed your filing and your res ponses dated June 7, 2010 to our letter of May
21, 2010 and we have the following comment:

Form 10-K for the year ended December 31, 2009

Item 11.  Executive Compensation
Summary compensation table, page 16
 1. We note your response to comment 12 of your letter dated June 7, 2010.  We cannot
agree with your conclusion that no one ot her than Mr. Winterbottom serves in an
executive officer capacity as defined by Rule 3b-7 of the Exchange Act.  Please revise
your Form 10-K to satisfy the requ irements of Item 402(a)(3)(iii).
 Please contact Eric Envall at (202) 551- 3234 or me at (202) 551-3434 with any other
questions.
Sincerely,
     Michael Clampitt
Attorney- Advisor

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June 7, 2010

VIA EDGAR SUBMISSION

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Michael Clampitt, Senior Counsel

Re:          West Bancorporation, Inc.

Form 10-K for fiscal year ended December 31, 2009

File Number 000-49677

Dear Mr. Clampitt:

We are writing in response to the request contained in the Staff’s comment letter dated May 21, 2010, (the “Comment Letter”) with respect to the Form 10-K of West Bancorporation, Inc. (the “Company”), as filed with the SEC on March 12, 2010.

For the convenience of the Staff, we have set forth the comments contained in the Comment Letter along with the responses of the Company.

Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations

Loan Portfolio, page 18

1. We note that your real estate - construction, land and land development loan portfolio totaled $148.5M as of December 31, 2009 which represented about 15% of your total loan portfolio.  We also note that it appears that this portfolio has a relatively high amount of credit risk.  Please tell us and revise future filings to disclose the following information related to loan portfolio with interest reserves, as applicable:

·

Disclose the amount of such loans and the accompanying interest reserves as of each period-end;

·

Disclose how you monitor such projects throughout their lives to make sure the properties are moving along as planned such that it is appropriate to continue to capitalize the interest on the loan;.

·

Disclose whether you have ever extended, renewed or restructured terms of the related loans. and the reasons for the changes;

·

Describe your underwriting process for loans with interest reserves, and any specific differences in how your underwrite loans with interest reserves, and loans that do not have interest reserves; and

·

Disclose whether any of your loans with interest reserves are currently on nonaccrual status.

Response:

We do not utilize interest reserves as part of our construction lending activities.  We allow borrowers to fund interest payments directly via the line of credit related to the project, but do not set aside specific cash deposits (bank or borrower funded) to make interest payments during the construction phase.  Our lines of credit would be subject to the loan to value restrictions outlined in Part 365 of the FDIC Rules and Regulations.  The guidelines are provided below.  We monitor construction projects routinely to ensure that funds advanced have been invested in the project being financed, and that our loan to value is being maintained throughout the construction of the project.

1

Part 365 LTV Guidelines

Loan Category

Loan-to-value limit (percent)

Raw land

65

Land development

75

Construction:

Commercial, multifamily (1), and other nonresidential

80

1 to 4 family residential

85

Improved property

85

Owner-occupied 1 to 4 family and home equity

(1)

(1)  A loan-to-value limit has not been established for permanent mortgage or home equity loans on owner-occupied, 1 to 4 family residential property. However, for any such loan with a loan-to-value ratio that equals or exceeds 90 percent at origination, an institution should require appropriate credit enhancement in the form of either mortgage insurance or readily marketable collateral.

Risk Elements, page 21

2. We note your disclosure on page 21 that outstanding loans of $46.727M were placed on nonaccrual during 2009.  We also note your disclosure of the ending balance of nonaccrual loans and the amount of charge-offs recorded during the year related to nonaccrual loans.  Please tell us and revise future Form 10-K filings to provide a tabular roll forward of your nonperforming loans and assets, which include nonaccrual loans, similar to that provided on page 30 of your Form 10-Q for the period ended March 31,2010.

Response:

The following table sets forth the activity within each category of nonperforming assets for the year ended December 31, 2009.

(dollars in thousands)

Nonaccrual

Loans Past Due 90 Days and Still Accruing Interest

Troubled

Debt Restructured

Total Nonperforming Loans

Other Real Estate Owned (OREO)

Nonaccrual lnvestment Securities

Total Nonperforming Assets

Balance at beginning of period

$
21,367

$
92

$
7,376

$
28,835

$
4,352

$
2,575

$
35,762

Change in fair market value

-

-

-

-

-

(831
)

(831
)

Additions

39,768

1,150

13,952

54,870

144

183

55,197

Transfers:

Past due to nonaccrual

92

(92
)

-

-

-

-

-

Restructured to nonaccrual

7,466

-

(7,466
)

-

-

-

-

Nonaccrual to OREO

(26,032
)

-

-

(26,032
)

26,032

-

-

Upgrade in classification

(253
)

-

(211
)

(464
)

-

-

(464
)

Sales

-

-

-

-

(5,095
)

(250
)

(5,345
)

Charge-offs

(16,791
)

-

-

(16,791
)

-

-

(16,791
)

Subsequent writedowns

-

-

-

-

(83
)

-

(83
)

Other than temporary impairment

-

-

-

-

-

(346
)

(346
)

Payments

(13,267
)

-

(834
)

(14,101
)

-

(49
)

(14,150
)

Balance at end of period

$
12,350

$
1,150

$
12,817

$
26,317

$
25,350

$
1,282

$
52,949

Future Form 10-K filings will disclose this same level of detail for all categories of nonperforming assets.

2

3. As a related matter, please revise future filings to present your nonperforming loans included within your nonperforming assets table disaggregated by each loan type.  Please also provide us this information as of March 31, 2010 and December 31, 2009.

Response:

The nonperforming assets table for the requested periods has been updated to include the breakdown by loan category as requested:

(dollars in thousands)

March 31, 2010

December 31, 2009

Change

Nonaccrual loans:

Commercial

$
7,125

$
9,846

$
(2,721
)

Real estate:

Construction, land and land development

296

1,399

(1,103
)

1-4 family residential

505

863

(358
)

Commercial

2,306

214

2,092

Consumer and other loans

1,218

28

1,190

Total nonaccrual loans

11,450

12,350

(900
)

Loans past due 90 days and still accruing interest:

Commercial

-

-

-

Real estate:

Construction, land and land development

-

-

-

1-4 family residential

169

-

169

Commercial

-

-

-

Consumer and other loans

4

1,150

(1,146
)

Total past due 90 days and still accruing interest

173

1,150

(977
)

Troubled debt restructured loans:

Commercial

6,271

6,168

103

Real estate:

Construction, land and land development

81

84

(3
)

1-4 family residential

667

523

144

Commercial

9,375

6,024

3,351

Consumer and other loans

160

18

142

Total troubled debt restructured loans

16,554

12,817

3,737

Total nonperforming loans

28,177

26,317

1,860

Other real estate owned

26,974

25,350

1,624

Nonaccrual investment securities

1,310

1,282

28

Total nonperforming assets

$
56,461

$
52,949

$
3,512

Nonperforming loans to total loans

2.84
%

2.58
%

0.26
%

Nonperforming assets to total assets

3.34
%

3.36
%

-0.02
%

Future filings will contain this same level of detail for nonperforming assets.

3

Item 8. Financial Statements and Supplementary Data

Note 1. Organization and Nature of Business and Summary of Significant Accounting Policies, Loans, page 43

4. We note your disclosure that a loan is classified as restructured when the interest rate is materially reduced or the term is extended beyond the original maturity date because of the inability of the borrower to service the loan at market terms.  We also note that restructured loans have increased from $12.8M as of December 31, 2009 to $16.6M as of March 31, 2010.  We also note disclosure in Exhibit 99.2 of your Form 8-K filed on April 30, 2010 that you are currently earning interest on these restructured loans and that 90% are current less than 30 days past due.  Please address the following:

·

Clearly label these restructurings as troubled-debt restructurings (TDRs) pursuant to ASC 310-40;

Response:

We will label these restructurings as troubled-debt restructurings in all future reports.

·

Tell us whether at the time the loan is restructured you continue to accrue interest.  If so, tell us all of the factors you consider in making this determination so as to be reasonably assured of repayment and performance according to the modified terms;

Response:

To this point in time we have continued to accrue interest on loans that are restructured.  The terms of the restructuring are based on a cash flow analysis of the customer.  The terms of the restructuring are set so that the probability of the borrower meeting those terms is high.  Subsequent to restructuring, we monitor troubled-debt restructurings in the same manner as performing loans.  Should payments be late or missed, or other factors come to our attention that may indicate the borrower will not be able to perform on the restructured contractual terms; the loan would be placed on nonaccrual status in accordance with our policy.

·

For your restructurings that accrue interest at the time the loan is restructured, please tell us in detail and disclose how you determine that the loan has been restructured so as to be reasonably assured of repayment and of performance according to the modified terms and is supported by a current, well-documented credit assessment of the borrower's financial condition and prospects for repayment under the revised terms;

Response:

The payment history of the customer along with a current analysis of its cash flow is used to determine the restructured terms.  Underwriting procedures are similar to those of new loan originations and renewals of performing loans in that current financial statements and tax returns are obtained and analyzed.  A current assessment of collateral is performed.  The approval process for restructured loans is the same as that of performing loans.  We will add this explanation to future Form 10-K filings.

·

For your restructurings that accrue interest at the time the loan is restructured, tell us and disclose whether you have charged-off any portion of the loan.  If you have, please tell us how you concluded that repayment of interest and principal contractually due on the entire debt is reasonably assured;

Response:

The current restructured loans have had no portion of the loan charged off.  A table later in this letter shows the break down of TDRs between those due to extension of term and those due to rate reduction.  The vast majority of TDRs are due to term extension.  There is one TDR as a result of rate reduction for $4,152,000.  This loan is collateral dependent with a loan-to-value based on a recent appraisal of approximately 79%.  We will add this explanation to future Form 10-K filings.

4

·

Disclose how you determine whether the borrower has demonstrated repayment performance with modified terms.  Specifically disclose how many payments the borrower needs to make before returning a loan to accrual status;

Response:

We place restructured loans on accrual status at the time of restructuring.  The terms of the restructuring are predicated on data that indicate the borrower is capable of making payments based on the new terms.  If a loan has been placed on nonaccrual status at some point during its life, the loan may generally be returned to an accrual status after six months of payment performance.  We will add this explanation to future Form 10-K filings.

·

Quantify the types of concessions made (i.e. reduction in interest rate, extensions of the loan's maturity, or other actions) distinguishing between each loan product along with a discussion of your success with these different types of concessions.

Response:

The following table summarizes all loans designated as TDRs as of March 31, 2010, along with the concession made.

Number

Amount

(dollars in thousands)

of Loans

Outstanding

Concessions made:

Lengthened amortization:

Commercial

11

$
6,246

Real estate:

Construction, land and land development

1

81

1-4 family residential

3

667

Commercial

2

5,223

Consumer and other loans

2

160

19

12,377

Reduced interest rate:

Commercial

2

25

Real estate:

Construction, land and land development

-

-

1-4 family residential

-

-

Commercial

1

4,152

Consumer and other loans

-

-

3

4,177

Total

22

$
16,554

Lengthening the amortization period to lessen the strain on cash flow to service debt has been our preferred method of restructuring debt.  This has improved our likelihood of repayment while maintaining loan yields.  We have been successful in affecting repayment under modified terms for loans that we have designated as TDRs.  All TDRs as of March 31, 2010, are performing and remain on accrual status.  The vast majority of the debt is less than 30 days past due, consistent with Exhibit 99.2 of our Form 8-K filed on April 30, 2010.  We have not charged off losses on any of the above loans.  For the commercial real estate loan where the interest rate was reduced, the loan is collateral dependent and based on a recent appraisal has a loan-to-value of approximately 79%.

5

Note 3. Securities, page 48

5. We note your disclosure on page 50 that during 2009 you recognized $2.267M in other-than-temporary impairment relating to five single-issuer trust preferred securities, four of which were subsequently sold.  We also note disclosure on page 8 that you liquidated these securities during the second half of 2009 in order to reduce credit risk in your portfolio.  As a result, please compare and contrast how you determined which securities to sell as compared to the pooled trust preferred security with a fair value and unrealized loss of $1.136M and $3.475M as of December 31, 2009, respectively, and the other two single-issuer trust preferred securities that you decided to retain.

Response:

The four trust preferred securities that were sold were issued by IBC Capital, Irwin Financial, Capitol Bancorp and Old Second Bancorp, Inc.  Old Second was sold only to reduce our exposure to that issue.  We sold 50 percent of our holdings in that issue.  The IBC issue was sold because the company was reporting losses and is located in Michigan, a state that is more distressed than most of the other states.  The other two companies were extremely distressed.  Irwin Financial had entered into agreements with their regulators.  Capitol Bancorp had been selling off subsidiary banks.

Except for Old Second, we sold the other trust preferred issues because, in our opinion, there was rapid deterioration in their condition and we saw no reasonable probability of improvement.  We sold them so we could get something, rather than waiting and potentially getting nothing.

Our analysis of the pooled trust preferred security shows we should receive a significant portion of our investment if we hold it to maturity.  We certainly believe it is other than temporarily impaired and have accounted for it accordingly, but we do not believe it is a prudent business decision to realize a $3.5 million loss when the current analysis indicates we should get a significant portion of our money back.

We decided to keep the other two single issue trust preferred securities (Old Second Bancorp., Inc. and Heartland Financial USA, Inc.) because our analysis indicates those two companies are viable entities that should survive the current environment and return to normalized profitability levels.

6. We note your disclosure that as a result of the adoption of a new accounting pronouncement (ASC 320-10-35) you recorded a cumulative effect adjustment to increase beginning retained earnings by $2.622M, which represents 100% of the other-than-temporary impairment recorded during quarter ended December 31, 2008 related to a pooled trust preferred security.  Please tell us in detail how you determined that the entire amount of other-than-temporary impairment was not credit-related.  Additionally, please tell us if there were any differences in the assumptions/inputs used in the cash 

May 21, 2010
By U.S. Mail and facsimile: (515) 222-2346
Mr. David D. Nelson
Chief Executive Officer and President West Bancorporation, Inc. 1601 22
nd Street
West Des Moines, IA 50266
Re: West Bancorporation, Inc.         Form 10-K for fiscal year ended December 31, 2009  File Number 000-49677

 Dear Mr. Nelson:

We have reviewed the above referenced filing and related materials and have the
following comments.  Where indicated, we thin k your documents should be revised.  If you
disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In other
comments, where indicated, we think you should revise your document in response to these
comments in future filings.  In your response, pleas e indicate your intent to include the requested
revision in future filings and pr ovide us a draft of your proposed disclosures.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosures.  After reviewing this info rmation, we may have additional comments.
             The purpose of our review process is to assist you in your comp liance with the applicable
disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to
working with you in these respects.  We we lcome 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
listed at the end of this letter.  Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Loan Portfolio, page 18

1. We note that your real estate – construction, land and land devel opment loan portfolio totaled
$148.5M as of December 31, 2009 which represented about 15% of your total loan portfolio.
We also note that it appears that this portfolio  has a relatively high amount of credit risk.
Please tell us and revise future filings to disc lose the following information related to loan
portfolio with interest reserves, as applicable:

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 2
• Disclose the amount of such loans and the accompanying interest re serves as of each
period-end;
• Disclose how you monitor such projects throughout their lives to make sure the properties are moving along as planned such that it is appropriate to c ontinue to capitalize
the interest on the loan;
• Disclose whether you have ever extended, rene wed or restructured terms of the related
loans, and the reasons for the changes;
• Describe your underwriting process for loans with interest reserves, and any specific
differences in how your underwrite loans with in terest reserves and loans that do not have
interest reserves; and
• Disclose whether any of your loans with interest reserves  are currently on nonaccrual
status.
 Risk Elements, page 21

 2. We note your disclosure on page 21 that outstanding loans of $46.727M were placed on non-accrual during 2009. We also note your disclosu re of the ending balance of non-accrual loans
and the amount of charge-offs recorded during th e year related to non-acc rual loans. Please
tell us and revise future Fo rm 10-K filings to provide a tabular roll forward of your
nonperforming loans and assets, which include non- accrual loans, simila r to that provided on
page 30 of your Form 10-Q for the period ended March 31, 2010.
 3. As a related matter, please revise future f ilings to present your nonperforming loans included
within your nonperforming assets table disaggregated by each lo an type. Please also provide
us this information as of March 31, 2010 and December 31, 2009.
 Item 8.  Financial Statements and Supplementary Data

 Note 1. Organization and Nature of Business and Summary of Signifi cant Accounting Policies

Loans, page 43
 4. We note your disclosure that a lo an is classified as restructur ed when the interest rate is
materially reduced or the term is extended beyond the original maturity date because of the inability of the borrower to service the loan at market terms. We also note that restructured
loans have increased from $12.8M as of December 31, 2009 to $16.6M as of March 31,
2010. We also note disclosure in Exhibit 99.2 of  your Form 8-K filed on April 30, 2010 that
you are currently earning interest on these restructured loans and that 90% are current less
than 30 days past due. Please address the following:

• Clearly label these rest ructurings as troubled-debt restru cturings (TDRs) pursuant to ASC
310-40;

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 3
• Tell us whether at the time the loan is restru ctured you continue to accrue interest. If so,
tell us all of the factors you consider in making this determin ation so as to be reasonably
assured of repayment and performance according to the modified terms;
• For your restructurings that accrue interest at the time the loan is restructured, please tell
us in detail and disclose how you determine that the loan has been restructured so as to be
reasonably assured of repayment and of perf ormance according to the modified terms and
is supported by a current, well-documented cred it assessment of the borrower’s financial
condition and prospects for repayment under the revised terms;

• For your restructurings that accrue interest at the time the loan is restructured, tell us and
disclose whether you have charged-off any porti on of the loan.  If you have, please tell us
how you concluded that repayment of intere st and principal contractually due on the
entire debt is reas onably assured;
• Disclose how you determine whether the borrower has demonstrated repayment
performance with modified terms.  Specifically disclose how many payments the borrower needs to make before retu rning a loan to accrual status; and
• Quantify the types of concessions made (i.e. re duction in interest rate, extensions of the
loan’s maturity, or other actions) distingui shing between each loan product along with a
discussion of your success with thes e different types of concessions.
 Note 3. Securities, page 48

 5. We note your disclosure on page 50 that dur ing 2009 you recognized $2.267M in other-than-
temporary impairment relating to five single-issu er trust preferred secu rities, four of which
were subsequently sold. We also note disc losure on page 8 that you liquidated these
securities during the seco nd half of 2009 in order to reduce cr edit risk in your  portfolio. As a
result, please compare and contra st how you determined which secu rities to sell as compared
to the pooled trust preferred security with a fair value and unrealized loss of $1.136M and
$3.475M as of December 31, 2009, respectively, and the other two si ngle-issuer trust
preferred securities that you decided to retain.

6. We note your disclosure that as a result of  the adoption of a new accounting pronouncement
(ASC 320-10-35) you recorded a cumulative effect adjustment to increa se beginning retained
earnings by $2.622M, which represents 100% of  the other-than-temporary impairment
recorded during quarter ended December 31, 2008 re lated to a pooled trust preferred security.
Please tell us in detail how you determined th at the entire amount of other-than-temporary
impairment was not credit-related. Additionally, pleas e tell us if there were any differences in
the assumptions/inputs used in the cash flow analysis for your calculation of the cumulative
effect adjustment and your discounted cash flow s calculation used to determine whether there
was an adverse change in estimated cash flows as of December 31, 2008, which is prior to
your adoption of the provisions of ASC 320-10-65. If  there were differenc es, please identify
them, explain why you believe the differences we re appropriate and identify any accounting
guidance that supports your position.

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 4   7. We note that as of December 31, 2009, you had thr ee trust preferred secu rities with current
unrealized losses that have existed for longe r than one year. Considering the significant
judgment required to determine if a security is other than temporarily impaired and the focus
users of financial statements have placed on this  area, we believe comprehensive and detailed
disclosure is required to meet the disclosure  requirements in ASC 310-20-50 and Item 303 of
Regulation S-K for your material loss exposure.   Therefore, for each individual and pooled
trust preferred security with at least one rati ng below investment grade, please revise future
filings to disclose the following information as of the most recent period end: single-issuer or
pooled, class, book value, fair valu e, unrealized gain/loss, lowest  credit rating a ssigned to the
security, number of banks curre ntly performing, actual deferrals and defaults as a percentage
of the original collateral, expected deferrals and defaults as a percentage of the remaining
performing collateral and excess subordination as a percentage  of the remaining performing
collateral.  Please also clearly disclose how  you calculate excess subordination and discuss
what the excess subordination percentage signi fies, including relati ng it to other column
descriptions, to allow an investor to unde rstand why this information is relevant and
meaningful. Additionally, please provide us with this inform ation as of March 31, 2010 and
December 31, 2009.

8. We note disclosure that you engage d an independent consulting firm  to assist in the valuation
of your pooled trust preferred security as of December 31, 2009. Please provide us with a
detailed description of the other-than-temporar y impairment analysis you performed on these
securities as of December 31, 2009. In your response, please address your consideration of
the following:

• Discount rate: tell us and disclose in future filings how you determine the discount rate to
use in your calculation.
• Deferrals and defaults:
a. Please tell us in detail how you develop your esti mate of future deferrals and defaults.
b. Tell us and disclose in future filings if you treat actual deferrals the same as defaults.
c. Tell us and disclose in future filings your recover rate assumption and how you
determine it.  Specify if you have different recovery rates for actual defaults as
compared to actual or estimated future deferrals.
• Prepayment rate: Tell us how you determined  no prepayments of the underlying debt is a
reasonable assumption. Otherwise, please provide us with a sensitivity analysis of the change in credit loss at December 31, 2009 if you used a 1% prepayment assumption.
 9. For your two single-issuer trust preferred securities for which you disclose on page 50 that the unrealized losses are due to reduced demand along with interest rate fluctuations and
illiquid markets, not estimated cash flows, pl ease provide us a detaile d description of the
other-than-temporary impairment analysis  you performed as of March 31, 2010 and
December 31, 2009.  Please identify all of the ev idence you considered, explain the relative
significance of each piece of evidence, and iden tify the primary evidence on which you relied
to support a realizable va lue equal to or greate r than the carry ing value of the investment.

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 5    Note 16. Fair Value Measurements, page 62

 10. We note disclosure on page 64 that for collat eral-dependent impaired loans fair value is
determined based on appraisals by qualified licensed appraisers. We also note that appraised and reported values may be discounted based on historical knowledge, changes in market conditions from the time of valuation, and/or your expertise and knowledge of the client and
their business. As it relates to these loans, please tell us and revise your future filings, to
include the following enhanced disclosures:
• The approximate amount or percentage of im paired loans for which the Company relied
on current third party appraisals of the collatera l to assist in measuring impairment versus
those for which current apprai sals were not available;
• The typical timing surrounding the recogni tion of a collateral dependent lending
relationship and respective loans as nonpe rforming, when you order and receive an
appraisal, and the subsequent recognition of any provision or related charge-off. In this
regard, tell us if there have been any significant time lapses during this process;
• In more detail, the procedures you perform to  monitor these loans be tween the receipt of
an original appraisal and the updated appraisal;
• Whether you have charged-off an amount differe nt from what was determined to be the
fair value of the collateral as presented in the appraisal for any pe riod presented.  If so,
please tell us the amount of the difference and corresponding reasons for the difference,
as applicable;
• How you account for any partially charged-off loans subsequent to receiving an updated
appraisal. In this regard, specifically tell us your policies regarding whether or not these
loans return to performing or remain non-performing status, in additi on to whether or not
any of the terms of the original  loans have been modified (e .g. loan extension, changes to
interest rates, etc);
• In the event that you do not use external appraisals to fair value the underlying collateral
for impaired loans or in cases where the appr aisal has not been updated to reflect current
market conditions, please provide us with  a comprehensive response which discusses
your process and procedures for estimating the fa ir value of the collat eral for these loans;
and
• For those loans you determined that no speci fic valuation allowance was necessary, the
substantive reasons to su pport this conclusion.

Item 11.  Executive Compensation

Compensation Committee Report, page 9
 11. We note that you have not included any disclosure  in response to Item 402(s) of Regulation
S-K.  Please advise us of the basis of your c onclusion that disclosure is not necessary and
describe the process you undertook to reach that conclusion.

Mr. David D. Nelson
West Bancorporation, Inc.
May 21, 2010 Page 6   Summary Compensation Table, page 16

 12. We note that you have provided disclosures for only one named executive officer (Mr. Winterbottom) that may be considered a covered person in accordance with Item
402(a)(3)(iii) rather than three such individuals  as the rule requires.  Please revise your Form
10-K to satisfy the requirements of Item 402(a)(3)(iii).
    *  *  *  *  *
  Please respond to these comments within 10 business days or tell us when you will
provide us with a response.  Please submit all correspondence and supplemental materials on
EDGAR.  Please furnish a cover letter that ke ys your response to our comments, provide any
requested information and provide us drafts of pr oposed revisions to future filings in response to
our comments.  Please understand that we may have additional comments after reviewing any
amendment and your response to our comments.    We urge all persons who are responsible fo r the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny 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.     In connection with responding to our comme nts, please provide, in writing, a statement
from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with res

Mail Stop 4561

         December 22, 2008

Douglas R. Gulling
Chief Financial Officer West Bancorporation, Inc. 1601 22
nd Street
West Des Moines, Iowa 50266
Re: West Bancorporation   Preliminary Proxy Statement on Schedule 14A  Filed October 28, 2008  File No. 0-49677
 Dear Mr. Gulling:
We have completed our review of your  preliminary proxy statement on Schedule
14A and have no further comments.          S i n c e r e l y ,             William Friar         Senior Financial Analyst

CORRESP
1
filename1.htm

    November
      18, 2008

    VIA
      EDGAR
      SUBMISSION

    Securities
      and Exchange Commission

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

    Attention:
      Mr. William Friar

            Re:

              West
                Bancorporation, Inc.

    Preliminary
      Proxy Statement on Schedule 14A

    Filed
      November 12, 2008

    File
      No.
      0-49677

    Ladies
      and Gentlemen:

    We
      are
      writing with respect to the preliminary proxy statement on Schedule 14A of
      West
      Bancorporation, Inc. (the “Company”), as filed with the SEC on November 12, 2008
      (the “Proxy Statement”). Concurrently with the filing of this letter, the
      Company is filing a revised preliminary Proxy Statement (the “Revised Proxy
      Statement”).

    Following
      our discussion with the staff on November 14, the Company has included in the
      Revised Proxy Statement condensed pro forma statements of income that show
      the
      pro forma impact assuming the Company received TARP proceeds at the minimum
      level and at the level for which the Company applied, which is slightly less
      than the maximum allowable amount. For both of these scenarios, pro forma data
      is shown for the year ended December 31, 2007 and the nine months ended
      September 30, 2008. The Company has also included in the Revised Proxy Statement
      the information called for by Item 13(a) of Schedule 14A. As permitted, the
      information required under Item 13(a)(1) through (5) has been incorporated
      by
      reference to Company filings with the SEC.

    The
      pro
      forma information begins on page 6 of the Revised Proxy Statement and continues
      through page 9. The incorporation by reference to Company filings is on pages
      12
      and 13.

    The
      Company recognizes that, because of the incorporation by reference to Company
      filings with the SEC, it is necessary to have a 20 business day time period
      between the mailing of the Definitive Proxy Statement and the Special
      Shareholders’ Meeting. The actual date of the Special Shareholders’ Meeting will
      be determined when the staff has completed its review of the Revised Proxy
      Statement, but we hope to hold the meeting around December 18, 2008. The record
      date for the meeting will remain November 7, 2008.

    If
      you
      have any questions regarding the foregoing or the Revised Proxy Statement,
      please contact the undersigned at 515-222-2309.

    Sincerely,

    /s/
      Douglas R. Gulling

    Douglas
      R. Gulling

    Executive
      Vice President and Chief Financial Officer

CORRESP
1
filename1.htm

    November
      12, 2008

    VIA
      EDGAR
      SUBMISSION

    Securities
      and Exchange Commission

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

    Attention:
      Mr. William Friar

              Re:

              West
                Bancorporation, Inc.

              Preliminary
                Proxy Statement on Schedule 14A

              Filed
                October 28, 2008

              File
                No. 0-49677

    Ladies
      and Gentlemen:

    We
      are
      writing in response to the comments contained in the Staff’s comment letter
      dated November 7, 2008 (the “Comment Letter”) with respect to the preliminary
      proxy statement on Schedule 14A of West Bancorporation, Inc. (the “Company”), as
      filed with the SEC on October 28, 2008 (the “Proxy Statement”). Concurrently
      with the filing of this letter, the Company is filing a revised preliminary
      Proxy Statement (the “Revised Proxy Statement”).

    For
      the
      convenience of the Staff, we have set forth the comments contained in the
      Comment Letter along with the responses of the Company.

    Impact
      of the Capital Purchase Program

    1.
      Please
      revise to clarify how you expect to use the proceeds of your proposed sale
      of
      securities to the Treasury Department.

    Response:
      The
      Company has added a disclosure of its expected use of any proceeds from the
      sale
      of securities to the Treasury Department on page 4 of the Revised Proxy
      Statement under the caption “Proposal to Amend Restated Articles of
      Incorporation.”

    2.
      Please
      discuss how your participation in the Capital Purchase Program
      may

              ·

              require
                you to expand your board of directors to accommodate Treasury Department
                appointments to it;

              ·

              require
                you to register for resale securities you have issued to the Treasury
                Department; and

              ·

              impact
                how you operate your Company, for example, how the terms of participation
                will require you to restructure your executive compensation
                arrangements.

    Response:
      In
      response to the comment regarding the board of directors, the Company has added
      disclosure on page 4 of the Revised Proxy Statement under the caption “Proposal
      To Amend Restated Articles Of Incorporation” that describes the circumstances
      under which the Company would be required to expand its board of directors
      to
      accommodate the right of the holders of the senior preferred shares sold to
      Treasury to elect two directors.

    In
      response to the comment regarding the Company’s requirement to register
      securities issued to the Treasury Department, the Company has added disclosure
      on page 4 of the Revised Proxy Statement under the caption “Proposal to Amend
      Restated Articles of Incorporation” that describes that
      requirement.

    In
      response to the comment regarding the impact that participation in the Capital
      Purchase Program would have on the Company’s operations, the Company notes that
      the Proxy Statement includes disclosure regarding the fact that if senior
      preferred shares were sold to the Treasury Department, the Company would not
      be
      able to increase its dividend rate on common stock or make certain repurchases
      of its common stock for three years, without the consent of the Treasury
      Department. The Company does not believe that participation in the Capital
      Purchase Program would have any other material impact on the operations of
      the
      Company. The Company has added disclosure on page 4 of the Revised Proxy
      Statement under the caption “Proposal To Amend Restated Articles Of
      Incorporation” to the effect that if it sells senior preferred shares under the
      Capital Purchase Program, it will not need to modify any plans or contracts
      to
      comply with limits on executive compensation established by Section 111 of
      the
      Emergency Economic Stabilization Act of 2008.

    3.
      Disclose,
      if true, that the Treasury Department is not obligated to accept your
      application to participate in the Capital Purchase Program and that the
      estimated proceeds of your proposed sale of securities to the Treasury
      Department are not guaranteed.

    Response:
      The
      Company has added a disclosure on page 4 of the Revised Proxy Statement under
      the caption “Proposal To Amend Restated Articles Of Incorporation” to the effect
      that the Treasury Department is not obligated to accept the Company’s
      application to participate in the Capital Purchase Program and that the Treasury
      Department may decide not to purchase any senior preferred shares from the
      Company

    4.
      Disclose
      any material effect on your liquidity, capital resources or results of
      operations if the proposal is approved and the Treasury Department denies your
      application.

    Response:
      The
      Company believes that there would be no material effect on the Company’s
      liquidity, capital resources or results of operation if the Company’s
      application to participate in the Capital Purchase Program is denied. As noted
      in the Proxy Statement, at September 30, 2008, the Company and its principal
      subsidiary, West Bank, had capital ratios in excess of those required to be
      considered well-capitalized under banking regulations. The Company has applied
      for participation in the Capital Purchase Program because additional capital
      under the program would provide additional flexibility to meet future capital
      needs that may arise and because it believes the cost of capital available
      through the program appears favorable. It is not applying to participate in
      the
      program because of any current need for capital. Accordingly, the Company has
      not made any changes to the Proxy Statement in response to this
      comment.

    5.
      Disclose
      the company’s common stock market price as of a recent date, or disclose the
      market price using a 20-day trailing average.

    Response:
      The
      Company has added a disclosure of the 20-day trailing average of the Company’s
      common stock price as of November 7, 2008 on page 4 of the Revised Proxy
      Statement under the caption “Proposal to Amend Restated Articles of
      Incorporation.”

    6.
      Disclose
      whether you will modify any plans or contracts to comply with limits on
      executive compensation established by Section 111 of the Emergency Economic
      Stabilization Act of 2008.

    Response:
      The
      Company has added a disclosure on page 4 of the Revised Proxy Statement
      under the caption “Proposal To Amend Restated Articles Of Incorporation” to the
      effect that it will not need to modify any plans or contracts to comply with
      limits on executive compensation established by Section 111 of the Emergency
      Economic Stabilization Act of 2008.

    Financial
      Statements

    7.
      Item
      13 of Schedule 14A requires you to include financial information in your proxy
      statement if you are seeking authorization to issue common or preferred stock
      under certain circumstances. We note that you have not included financial
      information in your proxy statement. Please explain to us why you believe
      financial statements are not material in connection with issuing the warrants
      to
      purchase common stock. See Note A to Schedule 14A and Instruction 1 to Item
      13(a) of Schedule 14A.

    If
      you expect the proceeds of the sale of securities to the Treasury Department
      to
      have a material impact on your financial statements, you may provide a
      discussion of the pro forma effect rather than pro forma financial statements.
      In your discussion, please address the impact of both the minimum and maximum
      estimated proceeds.

    Response:
      Instruction 1 to Item 13 of Schedule 14A provides that the information required
      by paragraph (a) of Item 13 (i.e. the financial statements and related financial
      information) may be omitted if not "material for the exercise of prudent
      judgment in regard to the matter to be acted upon." It further provides that
      "in
      the usual case the information is deemed material to the exercise of prudent
      judgment where the matter to be acted upon is the authorization ... of a
      material amount of senior securities, but the information is not deemed material
      where the matter to be acted upon is ... the authorization of preferred stock
      without present intent to issue or the authorization of preferred stock for
      issuance for cash in an amount constituting fair value." Here, the Company
      is
      seeking the authorization of a class of preferred stock without the intent
      to
      issue, except possibly under the Capital Purchase Program, and if it does issue
      shares under the Capital Purchase Program, it will be for cash in an amount
      constituting fair value. In any event, the Company believes that the information
      required by paragraph (a) of Item 13 is not material to shareholders in deciding
      on how to vote on the proposal to amend the Restated Articles of Incorporation
      of the Company. The possible sale of securities to the Treasury Department
      (which will not exceed $36 million in proceeds) will not have a material impact
      on the Company’s financial statements so we believe that no pro forma
      information is required. The Company estimates that, assuming the sale of $36
      million of senior preferred shares to the Treasury and a warrant exercise price
      equal to the 20-trading day trailing average of the Company’s Common Stock as of
      November 7, 2008, the number of shares of Common Stock that would be issued
      upon
      exercise in full of the warrants would be approximately three percent of the
      current Common Shares outstanding. Further, the estimated annualized impact
      on
      net income available to common shareholders based on such assumptions would
      be
      approximately $0.04 per common share. We further note that, if the Staff were
      to
      disagree with the Company’s position as set forth in this paragraph, the Company
      would be able to incorporate by reference the financial information otherwise
      required by paragraph (a) of Item 13.

    The
      Company has set a record date for the special meeting of its shareholders of
      November 7 and would like to mail the definitive Proxy Statement on November
      14
      so it can hold a special meeting of its shareholders on December 10. We would
      appreciate your efforts to allow us to meet this schedule.

    If
      you
      have any questions regarding the foregoing or the Revised Proxy Statement,
      please contact the undersigned at 515-222-2309

    Sincerely,

    /s/
      Douglas R. Gulling

    Douglas
      R. Gulling

    Executive
      Vice President and Chief Financial Officer

    November
      12, 2008

    VIA
      EDGAR
      SUBMISSION

    Securities
      and Exchange Commission

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

    Attention:
      William Friar

              Re:

              West
                Bancorporation, Inc.

              Preliminary
                Proxy Statement on Schedule 14A

              Filed
                November 10, 2008

              File
                No. 0-49677

    Ladies
      and Gentlemen:

    We
      are
      writing in response to the request contained in the Staff’s comment letter dated
      November 7, 2008 (the “Comment Letter”) for a written statement with respect to
      the preliminary proxy statement on Schedule 14A of West Bancorporation, Inc.
      (the “Company”), as filed with the SEC on October 28, 2008 (the “Proxy
      Statement”). In this regard, we acknowledge that:

              ·

              the
                Company is responsible for the adequacy and accuracy of the disclosure
                in
                the Proxy Statement as filed with the Securities and Exchange Commission
                (the “Commission”);

              ·

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

              ·

              the
                Company may not assert staff comments as a defense in any proceedings
                initiated by the Commission or any person under the federal securities
                laws of the United States.

                Sincerely

                WEST
                  BANCORPORATION, INC.

                By:

                /s/
                  Douglas R. Gulling

                Name:

                Douglas
                  R. Gulling

                Title:

                Executive
                  Vice President and Chief Financial
                  Officer

CORRESP
1
filename1.htm

    July
      11,
      2008

    By
      U.S.
      Mail and Facsimile to (202) 772-9208

    Christian
      Windsor

    Special
      Counsel

    Securities
      and Exchange Commission

    Mail
      Stop
      4561

    Washington,
      D.C. 20549

            RE:

              West
                Bancorporation, Inc.

              Form
                10-K for the year ended December 31, 2007

              Filed
                March 7, 2007

              File
                No. 0-49677

    Dear
      Mr.
      Windsor:

    I
      am
      writing to respond to your letter dated June 9, 2008. My numbered responses
      correspond to the numbered items in your letter.

              1.

              In
                future filings, we will identify all members of the peer groups used
                in
                the process to consider executive officer
                compensation.

              2.

              We
                included the annual report to security holders in the exhibit list
                included in Form 10-K as Exhibit 10.23. The exhibit was incorrectly
                numbered.

              3.

              We
                do not consider the language from our investor relations website
                quoted in
                paragraph 3 of your letter as limiting or releasing any of the company’s
                responsibilities under the federal securities laws. We have added
                the
                following sentence to the “NO LIABILITY”
                paragraph:

    THE
      AGREEMENT CREATED IN THIS PARAGRAPH IS NOT INTENDED TO LIMIT OR RELEASE
      LIABILITY INDEPENDENTLY EXISTING UNDER THE FEDERAL SECURITIES LAWS.

    Christian
      Windsor

    Securities
      and Exchange Commission

    July
      11,
      2008

    Page
      2

    We
      acknowledge 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 defense in any proceeding
                initiated by the Commission or any person under the federal securities
                laws of the United States.

    If
      you
      have additional comments, please contact me. Thank you.

    Sincerely,

            /s/ Thomas
              E.
              Stanberry

              Thomas
                E. Stanberry

              Chairman,
                President and Chief Executive Officer

Mail Stop 4561

June 9, 2008

By U.S. Mail and Facsimile to (515) 225-8032
Thomas E. Stanberry  Chairman, President and Chief Executive Officer West Bancorporation, Inc. 1601 22
nd Street
West Des Moines, Iowa 50266
Re: West Bancorp, Inc.
 Form 10-K for the year ended December 31, 2007  Filed March 7, 2007  File No. 0-24611
Dear Mr. Stanberry:

We have reviewed your filing and have the 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 comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary 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 look forward to working with you in these respects.  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 listed at the end of this letter.
Form 10-K

1. You note several times in this section that salaries and overall compensation are based to a considerable extent on information regarding peer institutions.  In future filings, please revise to identify all members of the peer group or groups used in this process.

John Sifonis
Trulite, Inc.
January 25, 2006 Page 2

General
 2. You incorporate most of the information required by Part 1 and 2 of your 10-K to an appendix to your proxy statement.  Please advise the staff how you determined that you did not need to include the annual report as exhibit 13 to the Form 10-K.  Please refer to General Instruction G(2) of Form 10-K and Item 601(b)(13) or Regulation S-K
 3. We note that in order to access your investor relations website referred to in this section, you require the user to agree to a general release from liability “for any damages of any nature arising out of or in connection with” the use of the site, although the site includes, in addition to your corporate governance documents referred to in the filing, your SEC filings.  Please tell the staff how requiring this general release accords with your responsibilities under the federal securities laws.

*      *      *
 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 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 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 connection with responding to our comments, please provide, in writing, a 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 defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
  In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in connection with our review of your filing or in response to our comments on your filing.

John Sifonis
Trulite, Inc. January 25, 2006 Page 3

  You may contact Gregory Dundas at (202) 551-3436 or me at (202) 551-3419 with any other questions.          S i n c e r e l y ,
Christian Windsor Special Counsel

October 10, 2006

Mail Stop 4561

By U.S. Mail and facsimile to (515) 225-8032

Mr. Thomas E. Stanberry
Chairman, President and Chief Executive Officer
West Bancorporation, Inc.
1601 22nd Street
West Des Moines, Iowa  50266

Re: West Bancorporation, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2005
 Definitive Proxy Statement on  Schedule 14A filed March 7, 2006
 File No. 0-49677

Dear Mr. Stanberry:

We have completed our review of your Fo rm 10-K and related filings and have no
further comments at this time.

        S i n c e r e l y ,

                              John P. Nolan
        A c c o u n t i n g  B r a n c h  C h i e f

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>
May 4, 2006

John P. Nolan, Accounting Branch Chief
Mail Stop 4561
Division of Corporation Finance
United States Securities and Exchange Commission
Washington, D.C. 20549

                                  Re:   West Bancorporation, Inc.
                                        Form 10-K for the Fiscal Year Ended
                                                December 31, 2005
                                        Definitive Proxy Statement on
                                                Schedule 14A filed March 7, 2006
                                        File No. 0-49677

Dear Mr. Nolan:

I am writing in response to your letter of April 26, 2006. We have reviewed your
questions with our accounting and legal advisors, and our audit committee. The
following are our responses to your comments:

Note 1 -- Organization and Nature of Business and Summary of Significant
Accounting Policies, page 35

Investors Management Group, Ltd. ("IMG") is a wholly-owned subsidiary of West
Bancorporation, Inc. (the "Company"). The Company purchased 100 percent of the
common stock of IMG from an unaffiliated company on December 30, 2005, through a
competitive-bidding, arms-length transaction.

The IMG purchase price of $10,000,000 was based upon an internal rate of return
analysis done by the Company using the projected cash flows and net income of
IMG. The Company engaged a third-party valuation firm to determine the fair
value of the identifiable intangible assets associated with the purchase. The
recorded goodwill is the difference between the purchase price and the sum of
the estimated fair value of the identifiable intangible assets and the acquired
tangible assets. IMG is a registered investment advisor. There are minimal
amounts of tangible assets associated with this

<PAGE>

John P. Nolan, Accounting Branch Chief
Mail Stop 4561
United States Securities and Exchange Commission
Washington, D.C. 20549
Page 2

type of business. Therefore, goodwill tends to be a substantial portion of the
market value.

Note 13 -- Commitments and Contingencies and Related-Party Leases, page 53

Note 13 to the Company's Consolidated Financial Statements dated December 31,
2005 describes the process our wholly-owned subsidiary, West Bank, uses to
evaluate the issuances of standby letters of credit.

The fair value of our obligation related to standby letters of credit at
December 31, 2005, was approximately $33,000 and is recorded in Other
Liabilities. The fair value was equal to the unamortized fee received. Because
of the immaterial amount, no additional disclosure was considered necessary.

The Company acknowledges that:

     -    the Company is responsible for the adequacy and accuracy of the
          disclosure in the filings;
     -    staff comments or changes to disclosure in response to staff comments
          in the filings reviewed by the staff 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.

Thank you for your consideration of our responses to your comments. If you have
any questions or comments please contact me at 515-222-2308.

Sincerely,

Thomas E. Stanberry
Chairman, President and Chief Executive Officer

</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                    April 26, 2006

Mail Stop 4561

By U.S. Mail and facsimile to (515) 225-8032

Mr. Thomas E. Stanberry
Chairman, President and Chief Executive Officer
West Bancorporation, Inc.
1601 22nd Street
West Des Moines, Iowa  50266

Re:	West Bancorporation, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2005
	Definitive Proxy Statement on Schedule 14A filed March 7,
2006
	File No. 0-49677

Dear Mr. Stanberry:

	We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments.  If you disagree with a comment, we
will
consider your explanation as to why our comment is inapplicable.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

      Please understand that 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
filings.
We look forward to working with you in these respects.  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
listed
at the end of this letter.

*    *    *    *    *    *    *

Definitive Proxy Statement on Schedule 14A filed March 7, 2006
Appendix to the Proxy Statement
Consolidated Financial Statements

Note 1 - Organization and Nature of Business and Summary of
Significant Accounting Policies, page 35

1. We note your disclosures on page 38 that you recognized
approximately $8.4 million of goodwill associated with your
acquisition of Investors Management Group, Ltd (IMG).  Please tell
us
whether IMG is an affiliate, related party or unaffiliated third
party.  Please also tell us how you determined the fair value of
IMG
as of the date of purchase and the primary factors which led to a
purchase price that resulted in such a proportionately significant
amount of goodwill.

Note 13 - Commitments and Contingencies and Related-Party Leases,
page 53

2. We note your disclosure on page 54 that no amounts have been
recorded as liabilities for your potential obligations under $23
million of standby letters of credit as of 12/31/05.  Please tell
us
how you determined the fair value of your guarantees related to
standby letters of credit at inception.  Refer to paragraphs 9-12
of
FIN 45.

*    *    *    *    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a detailed letter that keys your responses to our
comments and provides any requested supplemental information.
Please
understand that we may have additional comments after reviewing
your
responses to our comments.

        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.
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 connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

      	In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

	You may contact Lisa Haynes, Staff Accountant at (202) 551-
3424
or me at (202) 551-3492 if you have questions.

								Sincerely,

	                        	John P. Nolan
					Accounting Branch Chief

Mr. Thomas E. Stanberry
West Bancorporation, Inc.
April 26, 2006
Page 3

</TEXT>
</DOCUMENT>