November 22, 2004

Mail Stop 0408

By U.S. Mail and facsimile to (202) 362-2902.

F. Morgan Gasior
Chairman of the Board
BankFinancial Corp.
15 W060 North Frontage Road
Burr Ridge, Illinois 60527

Re:	BankFinancial Corporation
	Form S-1, Amended November 10, 2004
	File No. 333-119217

Dear Mr. Gasior:

	We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your explanation.
In some of 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.

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.

Registration Statement on Form S-1

Business of BankFinancial, F.S.B.

Equity Securities - page 100
1. Refer to prior comment 3. Your supplemental response indicates
that you did not adopt SAB 59 until June 30, 2004.  SAB 59 was
required to be applied for all periods for which financial statements
are included in the registration statement.  Please supplementally
provide us with your impairment analysis of your Fannie Mae and
Freddie Mac floating rate preferred stock as of December 31, 2002 and
2003.  Additionally, please supplementally provide us an analysis of
the impact of incorporating SAB 59 into your impairment analysis as
of December 31, 2002 and 2003.
*	*	*

Closing Comments

As appropriate, please amend your registration statement in response
to these comments.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover letter
with your amendment 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 amendment and responses
to our comments.

You may contact Heidi Berg, Staff Accountant, at (202) 824-5463 or
Donald Walker, Senior Assistant Chief Accountant, at (202) 942-1799
if you have questions regarding comments on the financial statements
and related matters.  You may contact Christian Windsor, Staff
Attorney, at (202) 942-1974 or me at (202) 942-1772 any other
questions regarding this review.


						Sincerely,



						Christian Windsor
						Special Counsel


cc:	Via US MAIL AND FACSIMILE: (202) 362-2902
Edward Quint, Esquire
Robert Pomerenk, Esquire
Luse, Gorman Pomerenk & Schick
5335 Wisconsin Avenue, N.W.
Washington, D.C. 20016
(202) 274-2000
BankFinancial Corporation
F. Morgan Gasior
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