April 14, 2006



Mail Stop 4561

Mr. F. Scott Dueser
President and Chief Executive Officer
First Financial Bankshares, Inc.
400 Pine Street
Abilene, Texas 79601


Re:	First Financial Bankshares, Inc.
	Form 10-K for Fiscal Year Ended December 31, 2005
	Filed February 28, 2006
	Form 10-K/A for Fiscal Year Ended December 31, 2005
	Filed March 2, 2006
	File Number: 000-07674


Dear Mr. Dueser:

      We have limited our review of your filings to the issue we
have
addressed in our comment. Where indicated, we think you should
revise
your document in response to this comment.

	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
filings.
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.

* * * * *









Form 10-K/A, filed March 2, 2006

1. We note that you have filed an amended Form 10-K to correct
your
Section 302 certifications. We also note that the dates of the
corrected certifications included in your amended filing are the
same
as the dates of your originally filed certifications included in
your
Form 10-K filed on February 28, 2006. Please amend your filing to
include certifications updated to coincide with the date of your
filing. When you amend your filing, please also note that this
information is required to be filed as exhibits in EDGAR, not just
labeled as exhibits.

* * * * *

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your response to our
comment.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
response to our comment.

	 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 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 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 comment on your filing.



      You may contact John Spitz, Staff Accountant at (202) 551-
3484,
or me at (202) 551-3492, if you have questions regarding this
comment.


      Sincerely,


      John P. Nolan
      Accounting Branch Chief
Mr. F. Scott Dueser
First Financial Bankshares, Inc.
April 14, 2006
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