September 19, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (309) 743-7705

Douglas M. Hultquist
Chief Executive Officer
QCR Holdings, Inc.
3551 7th Street, Suite 204
Moline, IL 61265

	Re:	QCR Holdings, Inc.
		Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 18, 2005
		File No. 0-22208

Dear Mr. Hultquist:

	We have reviewed the above referenced filing, and have the
following comments. We have limited our review to only the issues
raised in our comments.   Where indicated, we think you should
amend
your filings in response to these comments.  If you disagree, we
will
consider your explanation as to why our comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your explanation.  In our comments, we may ask you to provide us
with
supplemental 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 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.

Financial Statements

Note 1 - Nature of Business and Summary of Significant Accounting
Policies, page 40
1. Please tell us how your policy for determining when receivables
are classified as held for investment meets the criteria set forth
in
paragraph 8(a) and 8(b) of SOP 01-6.  Please tell us how you
considered the related effects of this policy on your statement of
cash flows, as far as whether such amounts are considered
operating
or investing cash flows.  Revise your financial statements and
Note 1
to more clearly reflect that your policy complies with SOP 01-6.



Note 3 - Investment Securities, page 43
2. Please revise Note 5 and similar disclosures elsewhere in your
filing to separately disclose your investments in government
sponsored entities (such as Freddie and Fannie) from U.S.
Government
agencies.  We do not believe that it is appropriate to aggregate
given the difference in risk profiles.

Note 17 - Commitments and Contingencies, page 55
3. Please provide us with your analysis by which you concluded
that
no provision for bankcard chargebacks was required during 2004.
Address the following regarding your bankcard chargebacks:

* Revise to disclose the rollforward of this liability in your
notes
to the financial statements for all periods presented.

* Tell us the authoritative literature that you relied upon in
making
your determination.

* Revise to quantify your maximum exposure in the periods
presented
and discuss your continuing exposure as it relates to disposition
of
certain card processing activities.

*    *    *    *

      As appropriate, please respond to these comments within 15
business days or tell us when you will provide us with a response.
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 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 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 Isa Farhat at (202) 551-3485 or me at (202)
551-3494 if you have questions regarding our comments.



      Sincerely,


						Kevin W. Vaughn
						Accounting Branch Chief


Douglas M. Hultquist
QCR Holdings, Inc.
September 19, 2005
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