SEC Division of Corporation Finance no-action letter: First Ottawa Bancshares, Inc.

BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP
200 WEST MADISON STREET, SUITE 3900
CHICAGO, ILLINOIS 60606
Joseph T. Ceithaml
(312) 629-5143 Telephone (312) 984-3100
Voice Mail Ext. 5143 Facsimile (312) 984-3150 joseph.ceithaml@bfkn.com
Section 15(d) of the Securities Exchange Act of 1934
Rule 12h-3 under the Securities Exchange Act of 1934 VIA ONLINE SUBMISSION (https://www.sec.gov/forms/corp_fin_noaction) Office of the Chief Counsel 100 F. Street N.E. Washington, DC 20549 Re: First Ottawa Bancshares, Inc. (Commission File No. 000-30495) Ladies and Gentlemen:
On behalf of First Ottawa Bancshares, Inc., a Delaware corporation (the “Company”), we hereby request that the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) confirm that it concurs with the Company’s view that it should not be precluded from using Rule 12h-3 (“Rule 12h-3”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), to suspend its duty to file with the Commission the reports required by Section 15(d) of the Exchange Act (“Section 15(d)”) and the rules and regulations promulgated thereunder, that will revive once the Company’s reporting obligation under Section 12(g) of the Exchange Act has been terminated. On May 11, 2012, the Company filed a Form 15 with the Commission to deregister its common stock, $1.00 par value per share (the “Common Stock”), under Section 12(g)(4) of the Exchange Act. Pursuant to Section 12(g)(4) of the Exchange Act, the Section 12(g) registration will be terminated in 90 days (August 9, 2012), or such shorter period as determined by the Commission. Subject to the Staff’s concurrence with the requests set forth in this letter, the Company intends to file a Form 15 pursuant to Rule 12h￾3(b)(1)(i) to suspend its reporting obligations under Section 15(d) following the end of this 90- day period and prior to the August 14, 2012 filing deadline for its Form 10-Q for the quarter ended June 30, 2012. 1 1 Assuming the Staff grants the relief requested in this letter, the Company will include in the Form 15 an explanatory note indicating that the Company is relying on a no-action letter issued by the Staff addressing the Company’s ability to rely on Rule 12h-3(b)(1)(i) to suspend its reporting obligations under Section 15(d).