Mail Stop 4561



February 28, 2006



By U.S. Mail and facsimile to (818) 223-9531.


Larry B. Faigin
Chief Executive Officer
Beverly Hills Bancorp Inc.
23901 Calabasas Road, Suite 1050
Calabasas, CA 91302

Re:	Beverly Hills Bancorp Inc.
Form 8-K
	Filed February 27, 2006
	File No. 000-21845

Dear Mr. Faigin:

      We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in
response
to this comment.  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 more information
so
we may better understand your disclosure.  After reviewing this
information, we may 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 comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.
1. In the fourth paragraph, you state that the deferred tax asset
was
overstated by $1.6 million at December 31, 2004, March 31, 2005,
June
30, 2005 and September 30, 2005.  However, you disclose that you
are
only restating your financial statements for the year ended
December
31, 2004.  Please tell us why you believe that the quarterly
financial statements for fiscal year 2005 should not be restated.
2. Please specifically tell us when and how you will file your
restated financial statements.


* * * * *


       As appropriate, please amend your filing and respond to
this
comment within five business days or tell us when you will provide
us
with a response.  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 comment and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comment.

	 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 all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

      You may contact Rebekah Moore, Staff Accountant, at (202)
551-
3463 or me at (202) 551-3423 if you have questions.

Sincerely,



Amit Pande
Assistant Chief Accountant
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Larry B. Faigin
Beverly Hills Bancorp Inc.
February 28, 2006
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