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 May 9, 2025

Mark D. Mordell
Chief Executive Offcier
Avidbank Holdings, Inc.
1732 North First Street
6th Floor
San Jose, CA 95112

 Re: Avidbank Holdings, Inc.
 Draft Registration Statement on Form S-1
 Submitted April 11, 2025
 CIK No. 0001443575
Dear Mark D. Mordell:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration on Form S-1
Financial Performance & Positioning, page 3

1. We note your statement on page 3 that during 2023 you faced significant
challenges
 due to several high-profile bank failures but "quickly navigated these
challenges by
 implementing strategic measures to fortify our balance sheet and
maintain our clients
 confidence." Please revise to quantify the impact on growth and
profitability to
 provide context and further clarify the measures you implemented.
Growing Foundation of Core Deposits, page 10

2. We note your disclosure that brokered deposits totaled $70.8 million as
of December
 31, 2024, down from $96.1 million in 2023. However, you also disclose
that, due to
 May 9, 2025
Page 2

 exceeding the 20% cap on reciprocal deposits under FDIC regulations, an
additional
 $470 million of deposits were classified as brokered. Please revise your
disclosure to
 clarify the total amount of deposits classified as brokered under
applicable FDIC
 rules. Additionally, discuss the potential implication of these
classifications, if
 material, on your liquidity position. In this regard, please revise the
first risk factor on
 page 39 to quantify your qualifying reciprocal deposits as of the most
recent
 practicable date, which will provide context regarding the reference to
amounts that
 exceed the FDIC's 20% regulation.
Summary of Risk Factors, page 25

3. We note that your risk factors exceed 15 pages. Please revise the
summary risk factors
 to be no more than two pages. Refer to Item 105(b) of Regulation S-K.
Risk Factors
Our business and operations are concentrated in California, page 28

4. We note from your disclosure that a significant portion of your loan
portfolio is
 concentrated in the San Francisco Bay Area. Please revise your
disclosure to include a
 more detailed discussion of the risks associated with this geographic
concentration. In
 particular, consider discussing regional economic trends and declines in
commercial
 real estate values and office-occupancy that could materially impact
property values.
Our largest deposit relationships currently, page 39

5. We note your risk factor disclosure that your 10 largest deposit
relationships represent
 approximately $440 million or 23% of total deposits. Please revise here
or where
 appropriate to provide additional disclosure regarding these depositors,
such as
 whether they are concentrated in a particular industry or geography and
whether their
 deposit relationships are contractual or relationship based.
Management's Discussion and Analysis of Financial Condition
Results of Operations, page 71

6. We note the statement in Use of Proceeds that you may engage in
repositioning of a
 substantial portion of your available-for-sale securities portfolio.
Please revise to
 address the reasonably likely impact to your balance sheet. It appears
that it may
 reasonably likely result in a material event or uncertainty that is
reasonably likely to
 cause reported financial information not to be necessarily indicative of
future
 operating results or of future financial condition. See Item 303(a) of
Regulation S-K.
7. We note references to your low-cost of deposits and funding. Please
revise here or
 where appropriate to provide, in a tabular form, information regarding
average
 balances of loans and borrowings and effective interest yields and cost
of funds rates.
 To the extent material, clarify differences in costs among sources of
funding,
 including from the reciprocal deposit network and One-Way Buy deposits.
Loans, page 76

8. We note your disclosure on page 77 that Venture loans totaled $263.4
million as of
 December 31, 2024 and represented 14% of your total loan portfolio, and
that
 repayment of these loans may be dependent upon receipt by borrowers of
additional
 May 9, 2025
Page 3

 equity financing from venture firms or others, or in some cases, a
successful sale to a
 third party, public offering or other form of liquidity event. We further
note disclosure
 on page 69 that Venture loans are made to companies with modest or
negative cash
 flows and no established record of profitable operations. Please revise
your filing,
 where appropriate, to disclose in detail: (i) your origination policies
and procedures
 for your Venture loans; (ii) typical loan terms, including when receipt
of equity
 warrants may occur; and (iii) how you monitor the borrower s
performance and the
 collection of these loans subsequent to origination.
Risk Framework, page 87

9. We note the statement on page 4 that a key initiative started in 2023 was
bolstering
 your treasury management team, which was involved in responding to these
recent
 industry-wide deposit liquidity challenges. Please revise the ALCO
discussions on
 page 88, 90 or where appropriate to clarify whether and how the treasury
management
 team was made a part of the ALCO, and if not, how the treasury management
team's
 role relates to the ALCO. Additionally, clarify the steps you took in
2023 and 2024 to
 bolster the treasury management team.
Financial Performance & Positioning, page 93

10. We note your statement on page 13 and elsewhere that you reduced
uninsured
 deposits from 85% as of December 31, 2022 to 33% as of December 31, 2024
through
 expanded insurance solutions. However, we note your statement on page 93
that you
 decreased your uninsured deposits to 33% as of December 31, 2023. Please
reconcile
 these statements and also revise to describe the nature of your insurance
solutions, any
 material terms or limitations, associated costs, and any risks these
arrangements may
 present.
11. Please revise to clarify how in your experience "venture relationships
traditionally
 generate higher deposit balances relative to loan demand" and explain the
extent to
 which this impacts your risk profile. For example, please address
material impacts
 of Venture Lending, which appears to be approximately 16% of your loan
portfolio,
 contributing approximately 36% of your deposit funding.
12. Please revise here and page 15 or where appropriate to explain how you
define a
 "venture-backed technology" company. In this regard, it is unclear if the
venture-
 backed technology companies constitute all of your borrowers with
"negative cash
 flows and no established record of profitable operations."
Scalable Business Model and Expense Management, page 104

13. We note your statement that you "intend to selectively incorporate
artificial
 intelligence ( AI ) to enhance employee efficiency by automating
routine tasks and
 streamlining workflows." If material, revise to describe in greater
detail your specific
 plans to implement AI, including the anticipated timing and any material
steps you
 have already taken or plan to take toward implementation.
 May 9, 2025
Page 4

Business
Competition, page 107

14. We note the references to your venture lending and specialty finance
teams and how
 they compete nationally and in the Bay Area. Please revise to address
 your competitive position in these industries and clarify the methods of
competition.
Securities Ownership of Certain Beneficial Owners and Management, page 146

15. Please disclose the natural persons who have voting and dispositive
control over the
 shares owned by all entities listed as greater than 5% shareholders in
the
 beneficial ownership table.
 Please contact John Spitz at 202-551-3484 or Cara Lubit at 202-551-5909
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Robert Arzonetti at 202-551-8819 or James Lopez at 202-551-3536 with any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Craig Miller
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