SecProbe.io

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April 6, 2005

Mail Stop 04-08

By U.S. Mail and facsimile to (315) 366-3709

Mr. Michael R. Kallet
President, Chief Executive Officer, and Director
Oneida Financial Corp.
182 Main Street
Oneida, NY 13421-1676

Re:	Oneida Financial Corp.
	Form 10-K for the fiscal year ended December 31, 2004
	Filed March 31, 2005
	File Number: 000-25101

Dear Mr. Kallet:

      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 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.

	Please understand that 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 comment or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-K filed on March 31, 2005

Exhibit 13

Report of Independent Registered Public Accounting Firm

1. We note inclusion of the opinion of your Independent Registered
Accounting Firm dated February 7, 2005. Please amend the filing to
have your Independent Registered Accounting Firm include the city
and
state of their office location in the opinion. Refer to Item 2-
02(a)(3) of Regulation S-X.

Notes to the Consolidated Financial Statements

Note 3. Investment Securities and Mortgage-Backed Securities

2. We note that you recorded a $1.1 million other-than-temporary
impairment relating to certain perpetual preferred stock
investments
in two government sponsored enterprises during 2004. Please
supplementally tell us the amount of unrealized losses for these
investments as of December 31, 2003, and if material, how you were
able to conclude that no other-than-temporary impairment relating
to
these securities existed as of December 31, 2003.  In your
response,
please provide quantification supporting how you determined the
recognized $1.1 million impairment.  Please refer to the specific
relevant guidance in SFAS No.115 and SAB Topic 5:M in your
response.

* * * * *

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* 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

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact John Spitz at (202) 824-5477 or me at (202)
942-1783 if you have questions.

Sincerely,

John P. Nolan
Accounting Branch Chief

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Mr. Michael R. Kallet
Oneida Financial Corp.
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