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                              October 13, 2023

       Irene Oh
       Executive Vice President and Chief Risk Officer
       East West Bancorp, Inc.
       135 North Los Robles Ave., 7th Floor
       Pasadena, California 91101

                                                        Re: East West Bancorp,
Inc.
                                                            Quarterly Report on
Form 10-Q for the Fiscal Quarter Ended June 30, 2023
                                                            File No. 000-24939

       Dear Irene Oh:

            We have have conducted a limited review of your quarterly report
and have the following
       comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

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

       Quarterly Report on Form 10-Q for the Fiscal Quarter Ended June 30, 2023

       Interest Rate Risk Management, page 95

   1.                                                   We note the disclosure
on page 95 that the computation of prospective effects
                                                        of hypothetical
interest rate changes are based on various assumptions which are further
                                                        discussed in Item 7.
MD&A     Market Risk Management in your 2022 Form 10-K. These
                                                        assumptions include,
but are not limited to, the timing and magnitude of changes in
                                                        interest rates, the
yield curve evolution and shape, the correlation between various interest
                                                        rate indices, financial
instruments    future repricing characteristics and spread relative to
                                                        benchmark rates, and
the extent to which prepayment activity changes. Your disclosure
                                                        also states that while
the assumptions are inherently uncertain, you believe your
                                                        assumptions are
reasonable. Please revise your disclosure to fully describe and define the
                                                        various identified
assumptions supporting your market risk presentations, beginning with
                                                        your next report and
provide us with proposed disclosure in response to this comment.
                                                        Please clarify whether
you use proprietary or third-party data, how the data are used in
                                                        your modeling and any
unique facts and circumstances about them, such as how they have
                                                        or may respond to
unknown facts and circumstances, such as exogenous events.
 Irene Oh
East West Bancorp, Inc.
October 13, 2023
Page 2
         Additionally, please disclose changes in any assumptions used for any
comparative
         period, including changes to the data source used or significant
changes in the actual
         assumption itself due to, and for example, internal data, market
conditions or significant
         changes in the judgments and determinations made by management as you
refine your
         modeling over time. Please see Item 305(a)(1)(ii)(B) of Regulation
S-K.
2.       We note that in the first six months of 2023 deposit rates have
increased 279 basis points,
         increasing along with the increase in the federal funds target rate.
We also note that your
         non-interest bearing deposits appear to have shifted to interest
bearing accounts, including
         certificates of deposit. We also note that you describe at least one
factor as an increase in
         your funding costs is a rise in deposit referral fees. Please tell us,
and revise future filings
         to clarify, the assumptions made with respect to deposit products
re-pricing, and whether
         your assumptions have changed as customer preferences have changed
during the past two
         years. For example, it is unclear how, and the extent to which,
deposit prices are assumed
         to change in response to changes in market interest rates, referred to
as
            deposit beta.    Finally, to the extent that referral fees are paid
to attract brokered deposits,
         revise your disclosure to discuss the use of brokered deposits.
        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.

       Please contact William Schroeder at 202-551-3294 or Amit Pande at
202-551-3423 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Arzonetti at 202-551-8819 or Christian Windsor at 202-551-3419
with any other
questions.



FirstName LastNameIrene Oh                                       Sincerely,
Comapany NameEast West Bancorp, Inc.
                                                                 Division of
Corporation Finance
October 13, 2023 Page 2                                          Office of
Finance
FirstName LastName