[Letterhead of Luse Gorman Pomerenk & Schick, P.C.]



(202) 274-2007                                               nquint@luselaw.com

May 14, 2009

VIA EDGAR

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.  20549

Attn.:    Christian Windsor, Esq.
          Mail Stop 4561

         Re:      Territorial Bancorp Inc. (Registration No. 333-155388)
                  Registration Statement on Form S-1

Dear Mr. Windsor:

     On behalf of  Territorial  Bancorp Inc. (the  "Company")  and in accordance
with  Rule 101 of  Regulation  S-T,  we are  hereby  transmitting  Pre-effective
Amendment  No.  4 to the  Company's  Registration  Statement  on Form  S-1  (the
"Amended  S-1").  Set forth  below are the  Company's  responses  to the staff's
comments  received  by  letter  dated May 14,  2009.  The  Amended  S-1 has been
blacklined to reflect changes from the original filing.

     1. The  referenced  table in Risk  Factors  has been  revised  to include a
column entitled "excess  subordination."  In addition,  text disclosure has been
added to the same  risk  factor  with  respect  to  defaults  required  to cause
other-than-temporary impairment.

     2. As discussed  with the staff,  the requested  cash flow analysis will be
submitted supplementally.

     3. The Recent  Developments and Critical  Accounting Policies sections have
been revised, as requested.

     4. The requested disclosure has been added to Critical Accounting Policies.

                                    * * * * *



Securities and Exchange Commission
May 14, 2009
Page 2

     We trust the foregoing is responsive to the staff's  comments.  The Company
wishes  to  have  the  registration  statement  declared  effective  as  soon as
possible.  We therefore  request that the staff advise the  undersigned at (202)
274-2007  or  Lawrence  Spaccasi  of this  office at (202)  274-2037  as soon as
possible if it has any further comments.

                                                      Respectfully,

                                                      \s\ Ned Quint
                                                      ----------------------
                                                      Ned Quint
Enclosures
cc:      David Lyon, Esq.
         Michael Volley, CPA
         Kevin Vaughn, CPA
         Allan S. Kitagawa, Chairman of the Board,
            President and Chief Executive Officer
         Lawrence Spaccasi, Esq.