IBT Bancorp, Inc.
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BY FACSIMILE AND EDGAR
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June 30, 2005

Mr. Don  Walker
Senior Assistant Chief  Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 0408
Washington D.C. 20549

Dear Mr. Walker,

     I am writing on behalf of IBT Bancorp,  Inc. (the "Registrant") in response
to the staff's  second letter of comment dated June 16, 2005.  Our responses are
numbered so as to correspond with the numbering in the comment letter.

Form 10-K
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Nonperforming and Problem Assets - page 8
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1.   No specific  reserves  were  recorded for loans  included in the 90 days or
     more past due category. Our methodology for calculating the adequacy of the
     reserve  includes a percentage  allocation  of certain  classifications  of
     homogeneous pools of loans. Of the loans classified as 90 days or more past
     due our  calculations  indicated  that an  amount  of  $169,605  should  be
     included in the  determination of the adequacy of the loss reserve for that
     classification of loans.

2.   The two mortgages  charged off in 2004 were not included in mortgage  loans
     accounted  for on a  non-accrual  basis as of December 31,  2003.  The loan
     secured  by the  multi-family  residential  and part  retail  building  was
     included in loans  classified as 90 days or more delinquent at December 31,
     2003.   This  loan  was  charged  off  in  December  2004.  The  facts  and
     circumstances  related to that charge-off are as follows: The borrower is a
     real estate investor who, we believe, became over extended.  Because of his
     poor business acumen and absentee  landlord status the borrower allowed the
     property to become run-down.  As a result tenants began leaving,  resulting
     in a decline  in cash  flow,  which  lead to an  inability  to make  timely
     mortgage payments.  Beginning in December 2002 the loan began to be 15 days
     delinquent. As the year progressed the loan became delinquent 30 to 45 days
     on a continuous  basis.  Serious  delinquency  began in late 2003. The last
     payment  received was in January 7, 2004, but was returned NSF.  Collection
     efforts in January  2004  produced  no  results.  On  January  21,  2004 we
     enforced the assignment of rents. We received notice from the  municipality
     claiming  extreme  conditions  existed at the  building  that  required the
     tenants to be evicted.  The borrower  notified us in February  2004 that he
     was  relinquishing   management  of  the  property.  We  began  foreclosure
     proceedings. A


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               309 Main Street - Irwin, PA 15642 o (724) 863-3100


     fire in the building in March 2004 resulted in the fire department evicting
     the tenants. In April 2004 we secured the property to prevent  unauthorized
     occupation of the building.  In July 2004 it was found that the furnace was
     inoperable  with an  estimated  cost of $100,000  to repair or replace.  In
     October 2004 we were the  successful  bidder at the Sheriff's sale and paid
     $725 in costs to acquire the  property.  In December  2004,  several  water
     pipes froze and subsequently burst within concrete walls. The broken boiler
     in the furnace also caused significant water damage. The original principal
     balance of the loan was $488,000.  The loan was originated on July 31, 2002
     at a  fixed  rate  of 7%.  Because  of the  condition  of the  property  an
     appraisal  indicated a market  value of  $100,000,  $90,000 was recorded as
     Real Estate Owned and $409,651,  which included the remaining principal and
     other costs  associated  with this loan,  was charged off in December 2004.
     The  property  was sold at a price of $118,413  net of selling  expenses in
     January 2005.

     The loan secured by the motel was charged off in June 2004 in the amount of
     $777,916. This was a commercial real estate loan secured by a motel located
     in New Stanton Pennsylvania. The original amount of the loan was $1,900,000
     at 7.75 % recorded on November 22, 2002.  Falling operating revenues caused
     a reduction in cash flow,  which caused  postponing  required  maintenance,
     loss of franchise and delaying  debt service.  We also believe the borrower
     diverted profits from this property to fund other operations. Loan payments
     were  habitually 30 days late beginning in early 2004. The last payment was
     received on February 6, 2004 for the due date of December 1, 2003.  Between
     December 2003 and March 2004 routine  collection  efforts were applied.  On
     March 25, 2004 payment in full was demanded. In April 2004 an agreement was
     made with the borrower to workout the loan.  The borrower did not honor the
     agreement. In May we initiated foreclosure  proceedings.  In June 2004, the
     borrower  surrendered  the  property  to the  bank  via a deed  in  lieu of
     foreclosure.  An appraisal indicated that the value of the property,  based
     on a Net  Operating  Income  approach,  was  significantly  less  than  the
     original  appraisal.  Naturally,  the Net Operating Income approach reduced
     the  appraised  value  because  of the  negative  impact  of the  declining
     operating  revenues of the motel. The deteriorated  physical condition also
     reduced the  appraised  value.  It is our policy to record,  as real estate
     owned 90% of the appraised value of the foreclosed property, the balance of
     the loan was  charged  off.  The  property  was  appraised  at  $1,300,000,
     $1,170,000  was recorded as real Estate Owned and $777,916 was charged off.
     In July 2004 we secured the services of a hotel  management firm to operate
     the property for the bank,  until the motel could be sold.  The property is
     currently  under  an  agreement  to  sell  at  $1,348,500,  net of  selling
     expenses.

Allocation of the Allowance for Loan Losses, page 11
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3.   As of December 2003 there were $7.1 million in commercial  loans classified
     as  substandard.   At  December  2004,   commercial   loans  classified  as
     substandard


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     were  only  $865,000.   The  decline  in  commercial  loans  classified  as
     substandard  reduced the  allocation  of the loan loss reserve  assigned to
     commercial loans.

     Delinquent  mortgages  increased from $704,000 to $3.6 million from 2003 to
     2004.  The  classifications  (watch,  substandard,  or  doubtful)  of these
     delinquent  loans would have  increased the  allocation  of the  calculated
     reserve for these loans.

Exhibit 13
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2004 Annual Report
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Results of Operations
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Provision for Loan Losses, page 5
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4.   Prior to charging  off the loan  secured by the motel there was no specific
     amount included in the allowance for loan losses attributable to this loan.
     For the loan secured by the multi-family apartment/retail building $287,286
     was  included in the  calculation  regarding  the adequacy of the loan loss
     reserve as of November 30, 2004. There were no allocations made to the loan
     loss reserve in 2003 regarding either of these loans.

5.   As of December 31, 2004 $352,205 of the reserve for loan losses was applied
     to specific loans, the balance, $2,241,437 was formula driven. For December
     31, 2003 100% of the amount in the reserve was formula driven.


We are  pleased to be able to provide  the  information  you  requested.  If you
require anything further regarding this matter, please do not hesitate to call.

Sincerely,

/s/ Charles G. Urtin


Charles G. Urtin
President and CEO



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