July 7, 2005


Mail Stop 4561


Hans R. Ganz
President
First PacTrust Bancorp, Inc.
610 Bay Boulevard
Chula Vista, California 91910

Re:	First PacTrust Bancorp, Inc.
	Form 10-K for the fiscal year ended December 31, 2004
      Filed March 16, 2005
	File No. 000-49806

Dear Mr. Ganz:

	We have limited our review of your filing to the issue we
have
addressed in our 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.

      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.

Report Of Independent Registered Public Accounting Firm, page 49

1. Please file a signed report of the independent registered
public
accounting firm in an amendment to the Form 10-K.  Refer to Rule
2-02
of Regulation S-X.



					*	*	*






Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 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 comments 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
comments.

	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 Chris Harley at (202) 551-3695 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3449 with any other
questions.



						Sincerely,


						Joyce Sweeney
						Accounting Branch Chief
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Hans R. Ganz
First PacTrust Bancorp, Inc.
July 7, 2005
Page 1