TERRITORIAL BANCORP INC.
                               1132 Bishop Street
                                   Suite 2200
                             Honolulu, Hawaii 96813

May 14, 2009

VIA FACSIMILE AND EDGAR
- -----------------------
(202) 772-9216

Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

     Re:  Territorial Bancorp Inc.
          Registration Statement on Form S-1 (Registration Number 333-155388)
          Request for Acceleration of Effectiveness

Ladies and Gentlemen:

     Territorial  Bancorp Inc., a Maryland  corporation (the "Company"),  hereby
requests  that the  Company's  Registration  Statement  on Form S-1 be  declared
effective on May 14, 2009 at 5:00 p.m., or as soon thereafter as is practicable.

     The Company hereby acknowledges that:

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

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

     o    the Company may not assert this action as a defense in any  proceeding
          initiated by the Commission or any person under the federal securities
          laws of the United States.

                                      Very truly yours,

                                      /s/ Vernon Hirata
                                      ------------------------------------------
                                      Vernon Hirata
                                      Vice Chairman, Co-Chief Operating Officer,
                                      General Counsel and Corporate Secretary