Mail Stop 4561
								January 23, 2006

Mr. Frank H. Sanfilippo
Chief Financial Officer
Enterprise Financial Services Corp
150 North Meramec
Clayton, MO 63105

Re:	Enterprise Financial Services Corp
	Form 10-K for the Fiscal Year Ended
	December 31, 2004
	Forms 10-Q for Quarterly Periods Ended
	March 31, 2005, June 30, 2005 & September 30, 2005
      File No.  001-15373

Dear Mr. Sanfilippo:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Please respond to these comments
and
be as detailed as necessary in your explanation.  In our comments,
we
may ask you to provide us with more 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-K For The Fiscal Year Ended December 31, 2004

Note 6 - Derivative Instruments and Hedging Activities, pages 61 -
63

1. We note you disclosure on page 62 that you use the shortcut
method
of assuming no ineffectiveness related to your fair value hedges
of
brokered CDs.  For these hedging relationships please tell us the
following:

* the specific terms of the brokered CDs and the hedging
instrument;


* identify the party that pays any broker placement fees for the
CDs;

* clarify whether the payment of the broker placement fees is
factored into the terms of the swap;

* the specific documented risk being hedged; and

* how you determined that these hedges meet each of the conditions
of
paragraph 68 of SFAS 133.

2. Please tell us the nature of any other hedging relationship for
which you apply the shortcut method or other abbreviated method
resulting in the recognition of no ineffectiveness.  Describe the
terms of the hedge item and hedging instrument and explain how
each
of these relationships meets the conditions of paragraphs 65 or 68
of
SFAS 133.


      Please respond to these comments within ten business days or
tell us when you will respond.  Please furnish a cover letter that
keys your response 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 response to our comment.

	 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 or me at (202)
551-3449 if you have questions regarding our comments on the
financial statements and related matters.



							Sincerely,


							Joyce Sweeney
							Accounting Branch Chief
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Mr. Frank H. Sanfilippo
Chief Financial Officer
Enterprise Financial Services Corp
January 23, 2006
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