SecProbe.io

Mail Stop 4720
June 29, 2016

Jill Gutierrez
Chief Executive Officer
Bancorp  34, Inc.
500 East 10th Street
Alamogordo, NM 88310

Re: Bancorp 34, Inc.
Registration Statement on Form S -1
Filed June  3, 2016
  File No. 333 -211820

Dear Ms. Gutierrez :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell  us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

General

1. Please supplementally provide us with copies of all written communications, as defined
in Rule  405 under the Securities Act, that you, or anyone authorized to do so on your
behalf, present to potential investors in reliance on Section  5(d) of the Securities Act,
whether or not they retain copies of the comm unications.

Prospectus Cover Page

2. Please revise your disclosure in the fifth paragraph to indicate that the orders are subject
to a maximum limit, in addition to a minimum order limited.  In this regard, we note your
“Limits on How Much Common Stock You May Purchase” disclosure on page 10.

Jill Gutierrez
Bancorp 34, Inc.
June 29, 2016
Page 2

 Summary, page  1

General

3. We note that the plan of conversion filed as Exhibit 2 to the reg istration statement
contemplates two mergers as part of the conversion plan: the MHC Merger and the Mid -
Tier Merger (as the ter ms are defined in the plan).  Please revise your disclosures where
applicable to properly capture the corporate restructuring and tell us whether you plan to
file the Articles of Merger as exhibits to the registration statement.

Terms of the Offering, page 5

4. You disclose that if you extend the offering beyond the extension date, you will notify
subscribers of the extension time.  Please explain, and to the extent necessary revise your
disclosure to describe, how you will notify your subscribers.

Risk Factors, page  18

Because we intend to increase our commercial real estate and commercial business loan
originations … , page  18

5. We note that your commercial real estate and commercial loans may involve relatively
large loan balances to individual borrowe rs or groups of related borrowers.  In light of
your page 84 disclosure, further revise your disclose to state that your ten largest
commercial real estate loans had an average balance of $3.1  million at March  31, 2016,
representing approximately 31% of yo ur commercial real estate loans.

We are an emerging growth company … , page  27

6. We note your disclosure that you have elected to comply with new or amended
accounting pronouncements in the same manner as a private company .  Please revise
your risk facto rs and other parts of the filing as applicable to clearly disclose the
following:

 You have elected to use the extended transition period for complying  with new or
revised accounting standards.

 Explain that this election allows you to delay the adoption  of new or revised
accounting standards that have different effective dates for public and private
companies until those standards apply to private companies.

 Include a statement indicating that your financial statements may not be comparable
to companie s that comply with  public company effective dates. Provide a similar
statement in your c ritical accounting policy disclosures in MD&A .

Jill Gutierrez
Bancorp 34, Inc.
June 29, 2016
Page 3

Management’s Discussion and Analysis of Financial Condition and Results of Operations,
page  48

Comparison of Financial Condition at March  31, 2016 and December  31, 2015, page  57

7. We note that you attribute the decline in cash and cash equivalents during this period to
“the variability in the timing of deposits.”  Based on your “Liquidity and Capital
Resources” disclosure o n page  79, it appears that you are referring to  the variability in the
timing of  “interest-earning  deposits with  other  banks .”  If true, please revise your
disclosure accordingly, or otherwise advise.

Comparison of Stockholders’ Rights for Existing Stockholders of Alamogordo Financial Corp.,
page 141

Special Meeting of Stockholders, page 143

8. Given that the right to call a special meeting of the stockholders represents a significant
change for the public stockholders of Alamogordo Financial, Corp., a risk factor
highlighting any material differences appears appropriate.  Please advise or revise your
disclosures as necessary.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   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 a dequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement , please provide  a written statement from the company
acknowledging that:

 should t he Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Jill Gutierrez
Bancorp 34, Inc.
June 29, 2016
Page 4

 Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of  1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date o f the
registration statement.

You may contact William Schroeder, Staff Accountant,  at (202) 551 -3294,  or Amit
Pande, Accounting Branch Chief,  at (202) 551 -3423  if you have questions regarding comments
on the financial statements and re lated matters.  Please contact William H. Dorton, Staff
Attorney,  at (202) 551 -3107  or me at (202) 551 -3369  with any other questions.

Sincerely,

/s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Services