Mail Stop 6010

      July 25, 2005



VIA U.S. MAIL AND FAX (239) 263-4543

Mr. David P. Johnson
Chief Financial Officer
TIB Financial Corp.
599 9th Street North, Suite 101
Naples, Florida 34102-5624

	Re:	TIB Financial Corp.
		Form 10-K for the year ended December 31, 2004
		Filed March 16, 2005
		File No. 000-21329


Dear Mr. Johnson:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments. Where indicated, we think you should
revise your documents in response to these comments.  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 or may not
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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on 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 for the year ended December 31, 2004

Consolidated Financial Statements

Report of Independent Registered Public Accounting Firm

1. The audit report included in the Form 10-K filed in EDGAR is
not
signed. Please amend to include an audit report that includes the
conformed signature of your independent auditor.  Refer to
Regulation
S-X, Article 2.

2. We noted that your auditors did not refer to the United States
PCAOB in their audit opinion. Confirm to us that the audit was
performed in accordance with the United States PCAOB. In addition,
please amend your filing to include a revised audit opinion that
complies with PCAOB Standard No. 1.

      As appropriate, please amend your Form 10-K for the year
ending
December 31, 2004 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 that keys your
responses
to our comments and provides any requested supplemental
information.
Detailed cover letters greatly facilitate our review.  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 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 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.

      You may contact Kristin Lochhead, Staff Accountant, at (202)
551-3664 or me at (202) 551-3676 if you have any questions
regarding
these comments.  In this regard, do not hesitate to contact Martin
James, the Senior Assistant Chief Accountant, at (202) 551-3671



								Sincerely,



								Brian Cascio
								Accounting Branch Chief
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Mr. Johnson
TIB Financial Corp.
July 25, 2005
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