August 26, 2005 Mail Stop 4561 VIA U.S. MAIL AND FAX 1-314-506-5560 Mr. Eric H. Brunngraber Chief Financial Officer Cass Information Systems 13001 Hollenberg Drive Bridgeton, Missouri 63044 RE: Cass Information Systems Form 10-KSB for the year ended December 31, 2004 Form 10-QSB for the quarter ended March 31, 2005 File no. 333-44497 Dear Mr. Brunngraber: We have reviewed your response letter dated August 2, 2005 and have the following additional comments. These comments should be addressed in all future filings with the Commission, if indicated. Supplementally provide to us the information requested if indicated and please be as detailed as necessary in your explanation. Form 10K for the fiscal year ended December 31, 2004 Consolidated Statements of Income, page 25 1. We have considered your response to comment 1 and question your classification of other income items (i.e. gain on sales of investment securities) within revenues. These amounts should be presented below net interest income after the provision for loan losses pursuant to Rule 9-04 of Regulation S-X. Please advise or revise future filings accordingly to reclassify these amounts. Note 7 - Equity Investments in Non-Marketable Securities, page 36 2. We have reviewed your response to our prior comment 3. Given the investee has "performed poorly during the past few years", it is unclear why you believe the extension of a credit line does not create some level of dependence on your Company as the investor. This combined with your board representation appears to indicate you may have significant influence over this investee. Further, majority ownership interest by another investor does not necessary preclude the ability to exercise significant influence. Please further advise us your consideration of the facts and circumstances that lead you to believe that you have no significant influence over this investee. * * * * Please respond to these comments within ten business days. Please file your response on EDGAR. You may contact Kelly McCusker, Staff Accountant, at (202) 551- 3433 or the undersigned at (202) 551-3413 if you have questions. Sincerely, Cicely D. Luckey Branch Chief ?? ?? ?? ?? Mr. Brunngraber Cass Information Systems, Inc. August 26, 2005 Page 1