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                            December 16, 2021

       Larry J. Helling
       Chief Executive Officer
       QCR Holdings, Inc.
       3551 7th Street
       Moline, IL 61265

                                                        Re: QCR Holdings, Inc.
                                                            Form 10-K for the
fiscal year ended December 31, 2020
                                                            Filed March 12,
2021
                                                            Form 10-Q for the
quarterly period ended September 30, 2021
                                                            Filed November 5,
2021
                                                            File No. 000-22208

       Dear Mr. Helling:

               We have limited our review of your filings to the financial
statements and related
       disclosures and have the following comment. In our comment, we may ask
you to provide us
       with information so we may better understand your disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 10-K for the fiscal year ended December 31, 2020

       Notes to Consolidated Financial Statements
       Note 7. Derivatives and Hedging Activities, page 114

   1.                                                   We note your disclosure
on page 116 that you enter into interest rate swaps with
                                                        customers while at the
same time entering into offsetting interest rate swaps with third
                                                        party financial
institutions. Your disclosure also states that you receive an upfront fee
                                                        from the counterparty,
dependent upon pricing, that is recognized upon receipt from the
                                                        counterparty. We note
that you recognized swap fee income totaling $74.8 million, $28.3
                                                        million, and $10.8
million for the years ended December 31, 2020, 2019, and 2018,
                                                        respectively,
representing 102%, 39%, and 21% of net income before income taxes for the
                                                        respective periods.
Please respond to the following:
 Larry J. Helling
QCR Holdings, Inc.
December 16, 2021
Page 2
                Tell us in more detail how pricing for the interest rate swap
transactions with
              customers is determined and the typical length of the interest
rate swaps.
                Explain in more detail why swap fee income relative to the
increase in notional
              amount of the non-hedging interest rate swap contracts varies so
significantly from
              year to year. For example, it appears that swap fee income
relative to the increase in
              the notional amount of non-hedging interest rate derivatives,
calculated based on
              amounts disclosed in your derivatives and hedging activities
footnote over the
              periods, has ranged from 5.0% in 2018, to 8.3% in 2019, and 9.9%
in 2020. If other
              factors impact this calculation, please tell us how, and expand
your disclosure in
              future filings to disclose those factors given the significant
impact this fee income has
              on your results of operations.
                Provide a representative example showing how swap fee income is
determined for
              one of these transactions.
                Tell us why you changed the line item name to swap fee
income/capital markets
              revenue on your consolidated statement of income beginning with
your Form 10-Q
              for the quarter ended June 30, 2021. Explain whether there are
different items
              included within this line item over the respective periods.
                Explain the drivers of the fluctuation of swap fee
income/capital markets revenue
              relative to the increase in the notional amount of non-hedging
derivatives during
              2021. For example, we note that swap fee income/capital markets
revenue relative to
              the increase in the notional amount of non-hedging derivatives
was 5.4% during the
              three months ended September 30, 2021, but 2.3% for the nine
months ended
              September 30, 2021. If other factors impact the amount of swap
fee income/capital
              markets revenue, tell us those factors and expand your disclosure
in future filings to
              disclose them.

       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Michelle Miller at 202-551-3368 or Mark Brunhofer at
202-551-3638
with any questions.



FirstName LastNameLarry J. Helling                              Sincerely,
Comapany NameQCR Holdings, Inc.
                                                                Division of
Corporation Finance
December 16, 2021 Page 2                                        Office of
Finance
FirstName LastName