BankFinancial Corporation


January 8, 2009

VIA EDGAR
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Christian Windsor, Esq.
Special Counsel
Division of Corporate Finance
Securities and Exchange Commission
Mail Stop 4561
100 F. Street, N.E.
Washington, D.C. 20549

Re:      BankFinancial Corporation
         Form 10-K/A for Fiscal Year Ended December 31, 2007
         Filed April 29, 2008
         File No. 000-51331

Dear Mr. Windsor:

     On behalf of BankFinancial Corporation (the "Company"), I am responding to
the letter from the Securities and Exchange Commission (the "Commission") dated
December 23, 2008 relating to the above-referenced annual report. Our responses
are named and numbered to correspond with the names and numbers of the comments
contained in the Commission's letter. We have included a copy of the text of the
comment above each of the responses.

Item 11. Executive Compensation
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Annual Cash Incentive Compensation, page 9
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1.   You state that the company's named executive officers received annual cash
     incentive awards based on the achievement of certain strategic, financial
     and management business plan objectives. In future filings, please disclose
     the specific objectives used to determine the annual awards. If you did not
     disclose the objectives because you determined that they were confidential
     due to the potential for competitive harm to the company, as contemplated
     by Instruction 4 to Item 402(b) of Regulation S-K, provide us with your
     confidentiality analysis supplementally and include in future filings
     detailed disclosure analyzing the level of difficulty necessary to reach
     each of the targets contemplated by the Instruction. For more information
     on the confidentiality of targets, please refer to the report of the
     Commission Staff regarding executive compensation disclosure, released
     October 9, 2007.



     The Company will revise future filings as requested by the comment.

Equity-Based Compensation, page 9
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2.   You disclose on page 10 that the vesting of certain restricted stock and
     stock option awards granted under the 2006 EIP is conditioned on the
     achievement of tangible capital ratios and asset quality ratios. In future
     filings, please disclose the specific target ratios. If you did not
     disclose the ratios because you determined that they were confidential,
     please refer to comment 1 above regarding the confidentiality analysis.

     The Company will revise future filings as requested by the comment.

Summary Compensation Table, page 15
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3.   We note your disclosure in footnote 2 to the Summary Compensation Table
     regarding stock and option awards. In future filings, please disclosure the
     assumptions made in the valuation by reference to a discussion of those
     assumptions in the company's financial statements, footnotes to the
     financial statements, or in management's discussion and analysis. Refer to
     the Instruction to Item 402(c)(2)(v) and (vi) of Regulation S-K.

     The Company will revise future filings as requested by the comment.

                                    * * * * *

     The Company acknowledges that:

     o    the Company is responsible for the adequacy and accuracy of the
          disclosure in the filing;

     o    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

     o    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.

     Please do not hesitate to call me at (630) 242-7700 if you have any further
comments or questions regarding this response.


                              Sincerely,

                              /s/ Paul A. Cloutier

                              Paul A. Cloutier
                              Executive Vice President & Chief Financial Officer