Mail Stop 7010
      September 1, 2005

By U.S. Mail and Facsimile

Mr. Dean J. Brydon
Chief Financial Officer
Timberland Bancorp, Inc.
624 Simpson Avenue
Hoquiam, Washington 98550

Re:	Timberland Bancorp, Inc.
	Form 10-K for the Fiscal Year Ended September 30, 2004
Form 10-Q for the Fiscal Quarter Ended June 30, 2005
      	File No.  000-23333

Dear Mr. Brydon:

      We have reviewed your filings 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 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 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 Fiscal Quarter Ended June 30, 2005

1. Please demonstrate to us how you determined that audited
financial
statements and pro forma financial statements were not required to
be
filed in Form 8-K for your acquisition on October 9, 2004 of the
seven branches and related deposits of Venture Bank.


*	*	*

      Please respond to this comment within 10 business days, or
tell
us when you will provide us with a response.  Please provide us
with
a response letter that keys your response to our comment and
provides
any requested information.  Detailed letters greatly facilitate
our
review.  Please file your response on EDGAR as a correspondence
file.
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 to be certain that the
filings include 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 comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* 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.

     If you have any questions regarding these comments, you may
contact Dale Welcome, Staff Accountant, at (202) 551-3865, Anne
McConnell, Senior Staff Accountant, at (202) 551-3709 or, in their
absence, to the undersigned at (202) 551-3768.


      Sincerely,



      John Cash
								Accounting Branch Chief
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Mr. Dean J. Brydon
Timberland Bancorp, Inc.
September 1, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE