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





Mail Stop 4561
      March 28, 2006

Ron Dobyns
Chief Financial Officer
Riverview Bancorp, Inc.
900 Washington Street, Suite 900
Vancouver, Washington 98660

      Re:	Riverview Bancorp, Inc.
      Form 10-K for Fiscal Year Ended March 31, 2005
Forms 10-Q for Fiscal Quarters Ended June 30, 2005, September 30,
2005 & December 31, 2005
File No.  000-22957


Dear Mr. Dobyns:

   We have reviewed your filings and have the following comments.
We
have limited our review to only your financial statements and
related
disclosures and will make no further review of your documents.
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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-Q for the Quarterly Period Ended December 31, 2005

Management`s Discussion and Analysis of Financial Condition and
Results of Operations







Provision for Loan Losses, page 28

1. Please tell us and revise future filings to clearly disclose
whether the increase in provision for loan losses to $1.3 million
for
the nine months ended December 31, 2005 compared to $260,000 for
the
nine months ended December 31, 2004 was solely attributable to the
higher loan loss rates quantified in your discussion.  Further
describe the reasons for the higher loss factors applied to each
of
the loan categories and provide us your proposed disclosures.

Form 10-Q for the Quarterly Period Ended June 30, 2005

Note 9 - Allowance for Loan Losses, page 11

2. We note that $1.8 million was recorded to the allowance for
loan
losses related to the acquisition of American Pacific Bank (APB)
during the quarter ended June 30, 2005.  We further note in
footnote
3 to the pro forma financials presented in your Form 8-K/A filed
July
1, 2005, that you recorded a purchase accounting adjustment of
$800,000 related to the APB acquisition.  Please tell us the
authoritative accounting literature you relied upon, including
your
consideration of SAB Topic 2.A.5, in recording the purchase
accounting adjustment.

3. Tell us if you acquired any loans in the APB acquisition that
were
under the scope of SOP 03-3.  For those applicable loans, tell us
whether the historical allowance was carried over at the
acquisition
date and provide the disclosures required by paragraphs 14-16 of
SOP
03-3.


* * *


   Please respond to these comments within 10 business days or
tell
us when you will provide us with a response.  Please file your
response on EDGAR.  Please understand that we may have additional
comments after reviewing your response to our comments.



   We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing 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 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.

      Please contact Chris Harley, Staff Accountant, at (202) 551-
3695 or me at (202) 551-3423 if you have questions.

   								Sincerely,



      Amit Pande
      Assistant Chief Accountant

??

??

??

??

Mr. Ron Dobyns
Chief Financial Officer
Riverview Bancorp, Inc.
March 28, 2006
Page 3 of 3






</TEXT>
</DOCUMENT>
