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October 16, 2023

Via Edgar

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

Washington, DC 20549

Attention: Madeleine Mateo

    Re:
    Bancorp 34, Inc.

    Draft Registration Statement on Form S-4

    Filed on August 11, 2023

    CIK No. 0001668340

    File No. 333-273901

Dear Sir or Madam:

On behalf of Bancorp 34, Inc. (“Bancorp
34”), we hereby submit responses to the comments provided by the Staff of the Division of Corporation Finance (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) set forth in your letter dated September 7,
2023 (the “Comment Letter”) with respect to the above-referenced filing (the “Registration Statement”).

For your convenience, we have set forth each comment
from the Comment Letter in italics and bold typeface and have included our response below it. The numbered paragraphs in this letter correspond
to the numbered paragraphs of the Comment Letter.

For S-4 filed August 11, 2023

What is the vote required to approve each proposal at the
Bancorp 34 special meeting, page 3

 1. Please disclose here the percentage of shares subject to voting and support agreements.

Response: In response
to the Staff’s comment, we have included the following additional disclosures on pages 4 and 5 of the Registration Statement, which
includes the percentage of Bancorp 34 and CBOA shares, as applicable, subject to voting and support agreements:

Additional disclosure on page 4:

A total of 868,149 shares of Bancorp 34 common stock,
representing approximately 23.7% of the outstanding shares of Bancorp 34 common stock entitled to vote at the Bancorp 34 special meeting
are subject to voting and support agreements among Bancorp 34, CBOA and the holders of such shares. In exchange for these agreements,
the only consideration provided to the holders of such shares was the execution of the merger agreement by CBOA.

Additional disclosure on page 5:

A total of 1,684,899 shares of CBOA common stock, representing
approximately 16.2% of the outstanding shares of CBOA common stock entitled to vote at the CBOA special meeting are subject to voting
and support agreements among CBOA, Bancorp 34 and the holders of such shares. In exchange for these agreements, the only consideration
provided to the holders of such shares was the execution of the merger agreement by Bancorp 34.

Summary, page 9

 2. Please include organizational charts depicting the organizational structure of CBOA and Bank 34
both prior to and after the consummation of the transaction.

Response: In response to the Staff’s
comment, we have included the following additional disclosure on page 10 of the Registration Statement, which includes a diagram of the
organizational structure of CBOA and Bancorp 34 both prior to and after the consummation of the merger:

The following graphic depicts Bancorp 34’s
and CBOA’s organizational structure* immediately prior to the merger and the bank merger:

The following graphic depicts Bancorp 34’s
organizational structure* immediately after the consummation of the merger, in which CBOA will be merged with and into Bancorp 34, and
the consummation of the bank merger, in which Commerce Bank of Arizona will be merged with and into Bank 34:

*The graphics above do not depict non-operating and immaterial subsidiaries
of Bancorp 34 or CBOA, including CBOA Financial Statutory Trust 1, which was formed by CBOA in connection with certain trust preferred
securities issued to investors and does not engage in any other business or activities, nor do they include subsidiaries of Bank 34.

Bancorp 34 Voting and Support Agreements, page 11

 3. We note that Bancorp 34's directors, Castle Creek and Brush Creek, and CBOA's directors have entered
into voting and support agreements. Please disclose here and elsewhere as appropriate any consideration exchanged for these agreements.

Response: In response to
the Staff’s comment, in addition to the revisions to pages 4 and 5 of the Registration Statement provided in our response to Comment
1 above, we have included the following additional disclosure on pages 14, 66 and 72 of the Registration Statement, which includes a disclosure
that the only consideration provided to Bancorp 34’s directors, Castle Creek, Brush Creek or CBOA’s directors in exchange
for the voting and support agreements was the execution of the merger agreement by the other party:

In exchange for these agreements,
the only consideration provided to the holders of such shares was the execution of the merger agreement by the other party.[1]

[1]
We note that with regard to the disclosures on pages 66 and 72 the clause “the other party” is replaced with the actual party
name.

      2

Information About the Companies, page 16

 4. Please clarify here what you mean by small-to-medium-size businesses. Please also clarify what
you mean by high net worth individuals on page 178.

Response: In response to
the Staff’s comment, we have revised the disclosures on pages 19 and 210 of the Registration Statement, to include a disclosure
to clarify what Bancorp 34 means by small-to-medium size businesses and a disclosure to clarify what CBOA means by high net worth individuals.

Risk Factors, page 27

 5. We note your disclosure on page 88 that, by virtue of Bancorp 34 becoming subject to Section 15(d)
(as opposed to registering its common stock under Section 12), Bancorp 34 (and its directors, officers, and principal stockholders) will
not be subject to compliance with Sections 16, 13(d) and 13(f). Similarly, Bancorp 34 will not have to comply with the tender offer and
proxy rules. Please discuss this in a risk factor and address any material effects this may have on investors.

Response: In response to
the Staff’s comment, we have included the following additional summary risk factor on page 29 of the Registration Statement and
an additional risk factor on page 63 of the Registration Statement, which includes a disclosure describing registration of Bancorp 34’s
common stock under Section 15(d) (as opposed to registration under Section 12) and addresses any material effects this may have on investors:

Additional summary risk factor on page
29 (Summary of Material Risks – Risks Related to Bancorp 34 Common Stock):

 · As a reporting issuer under
Section 15(d) of the Exchange Act, we file more limited reports with the SEC than other companies registered under Section 12 of the Exchange
Act.

Additional risk factor on page 63:

As a reporting issuer under Section 15(d) of the Exchange
Act, we file more limited reports with the SEC than other companies who are registered under Section 12 of the Exchange Act. This lack
of transparency may make it more difficult for investors in our securities to make informed investment decisions, and there may be a less
active trading market for our common stock.

While we are subject to Section 15(d) of the
Exchange Act, and accordingly will file annual, quarterly, and current reports on Forms 10-K, 10-Q, and 8-K with the SEC on the SEC’s
website at http://www.sec.gov, we do not have a class of securities registered under Section 12 of the Exchange Act. Consequently, we
will file more limited reports with the SEC than other companies whose shares are registered under Section 12. For example, as a filer
subject to Section 15(d) of the Exchange Act, the company is not required to prepare proxy or information statements; our common stock
is not subject to the protection of the going private regulations; the company is subject to only limited portions of the tender offer
rules; our officers, directors, and more than ten (10%) percent stockholders are not required to file beneficial ownership reports about
their holdings in our company; such persons are not subject to the short-swing profit recovery provisions of the Exchange Act; and stockholders
of more than five percent (5%) are not required to report information about their ownership positions in the securities. As a result,
investors will have less visibility as to the company and its financial condition than they would if the company had a class of securities
registered under Section 12 of the Exchange Act.

      3

While we believe that the disclosure requirements
of SEC regulations applicable to us will collectively provide transparency to the investment community and allow informed investment decisions
to be made by investors in our securities, there is no assurance that the reduced transparency afforded to registrations under Section
15(d) will not also reduce the information available to investors and make investment decisions in our securities more difficult. If some
investors find Bancorp 34’s common stock less attractive because Bancorp 34 may rely on these reduced disclosure obligations, there
may be a less active trading market for our common stock and our stock price may be more volatile.

Recent events impacting the financial services, page 31

 6. We note your disclosure that recent events and developments have, and could continue to, adversely
impact the market price and volatility of Bancorp 34's and CBOA's common stock. Please expand your disclosure to discuss how the market
price and volatility of the companies' stock may have been adversely impacted by recent events.

Response: In response to
the Staff’s comment, we have included additional disclosures in the applicable risk factor on page 39 of the Registration Statement,
which includes a disclosure discussing how the market price and volatility of the companies’ stock may have been adversely impacted
by recent events.

Our business may be adversely affected by economic conditions,
page 32

 7. Please further discuss whether your primary markets of Arizona and New Mexico are currently experiencing
any of the economic conditions listed in this risk factor and any material effects this has had on your business, if any.

Response: In response to
the Staff’s comment, we have included additional disclosure in the applicable risk factor on pages 40 – 41 of the Registration
Statement, which includes a disclosure discussing economic trends for the Arizona and New Mexico markets.

The Federal Reserve has implemented significant economic
strategies, page 33

 8. We note your disclosure that these strategies have had, and will continue to have, a significant
impact on your business and on many of your clients. Please further discuss how the strategies discussed in this risk factor may materially
affect your business and any material risks to your investors, so that investors may assess the risks. For instance, discuss how the raising
of short term rates affects your business.

Response: In response to
the Staff’s comment, we have included the following paragraph in the applicable risk factor on page 42 of the Registration Statement,
which includes a disclosure discussing how Federal Reserve strategies may materially affect Bancorp 34’s business and any material
risks to investors:

These increases in interest rates may have significant
and adverse effects upon our business as well as the business of many of our customers. For example, the raising of short-term interest
rates: (i) increases our cost of funds due largely to overall increases in the cost of our deposits which may decrease our net interest
margin; (ii) increases the cost of our other funding sources such as borrowings from the Federal Home Loan Bank which we utilize for liquidity
which may further decrease our net interest margins; (iii) may cause a decline in the value of our investment portfolio which could result
in unrealized or realized losses if the investments are sold; (iv) may cause a decline in the demand for our products if borrowers are
no longer able to afford our loans or if our competitors offer more attractive rates for loans or deposits; and (v) may cause an increase
in the number of customers who default on their loans or obligations to us as they may not be able to fund higher loan payments on floating
interest rate loans or have the ability to refinance maturing loans at higher interest rates. Risks associated with interest rates and
the yield curve and their potential effects on financial institutions are further discussed in these Risk Factors under the Caption Lending
and Interest Rate Risks.

      4

A failure in our breach of our operational or security
systems or infrastructure, page 39

 9. Please add a risk factor to disclose the nature of your board of director's role in overseeing
your cybersecurity risk management, the manner in which the board administers this oversight function and any effect this has on the board’s
leadership structure.

Response: In response to
the Staff’s comment, we have included the following risk factor on pages 50 – 51 of the Registration Statement, which includes
a disclosure of Bancorp 34’s board of directors’ role in overseeing cybersecurity risk management and the manner in which
the board administers this oversight function. The board of directors’ role in overseeing cybersecurity risk management will not
have an effect on the board’s leadership structure.

Additional Risk Factor on pages 50 – 51:

Our board and its committees oversee our cybersecurity,
disaster recovery and business continuity risk management framework. Our governance oversight of cybersecurity, disaster recovery and
business continuity risk management framework may not be effective in mitigating risks and/or losses.

Our board of directors oversees our
cybersecurity, disaster recovery and business continuity risk management framework. The board of directors reviews and approves our cybersecurity,
disaster recovery and business continuity risk management framework on an annual basis. The board has delegated the primary review of
our cybersecurity, disaster recovery and business continuity risk management framework and related policies and procedures to the risk
committee of the board of directors, which committee reports and makes recommendations to the board of directors. Senior management is
responsible for establishing, implementing, maintaining and testing our policies and procedures related to cybersecurity, disaster recovery
and business continuity and provides reports on these matters to the risk committee. The risk committee reports its activities to the
full board of directors.

While we have implemented a cybersecurity,
disaster recovery and business continuity risk management framework to mitigate our loss and risk exposure, there is no assurance that
such framework will be effective under all circumstances. Failures in our governance oversight of cybersecurity, disaster recovery and
business continuity risk management framework could cause us to be more vulnerable to cyber attacks and disruptions to our systems supporting
customer activities, such as our online banking and mobile application which could result in disruptions to our business, result in the
disclosure or misuse of confidential proprietary information, damage our reputation, increase our costs and cause losses. Risks associated
with cybersecurity and disruptions to our operations are further addressed in these Risk Factors under the Caption Operational Risks.

Background of the Merger, page 61

 10. We note that the CBOA board of directors and Bancorp 34 board of directors engaged in reviews
and discussions of long-term strategies and objectives, including merging with another financial institution or acquiring other financial
institutions. Please discuss, if applicable, whether any other acquisition targets were identified by either CBOA or Bancorp 34. We also
note your disclosure that from time to time CBOA and Bancorp 34 each considered different strategic options, including a merger. Please
expand the background section to explain why both CBOA and Bancorp 34 chose to do this merger at this time, as opposed to other merger
opportunities or other strategic options in the past.

Response: In resp