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One Atlantic
Center

1201 West
Peachtree Street

Atlanta, GA
30309-3424

404-881-7000
| Fax: 404-881-7777

    David Park
    Direct Dial:  404-881-7411
    Email:  david.park@alston.com

September 4, 2019

Ms. Pamela Long
Assistant Director Office of Financial Services
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7561

    Re:

        MetroCity Bankshares, Inc.

        Draft Registration Statement on Form S-1

        Submitted August 2, 2019

        CIK No. 0001747068

Dear Ms. Long,

On behalf of MetroCity
Bankshares, Inc. (the “Company”), this letter sets forth the Company’s responses to the comments of the
staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission set forth in
its letter dated August 26, 2019 (the “Comment Letter”), regarding the above-referenced draft registration
statement on Form S-1 (the “Draft Registration Statement”). The Company has also revised the Draft Registration
Statement in response to the Staff’s comments and is publicly filing concurrently with this letter the Registration
Statement on Form S-1 (“Registration Statement”), which reflects these revisions and updates and clarifies
certain other information.

For the convenience of the Staff, each comment
from the Comment Letter is restated in italics prior to the response to such comment. Page references in the text of this letter
correspond to pages and captions in the Registration Statement. We are also sending, under separate cover, a marked copy of the
Registration Statement showing the changes from the Draft Registration Statement submitted on August 2, 2019.

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 communications.

September 4, 2019

Page 2

Response: The Company confirms that it will supplementally
provide the Staff with copies of all written communications, if any, that it, or anyone authorized to do so on its behalf, presents
to potential investors in reliance on Section 5(d) of the Securities Act.

Market Price of Common Stock, page 47

 2. Please revise to provide the range of high and low bid information for each full quarterly period within the two most recent
fiscal years and any subsequent interim period, and other information called for by Item 201(a) of Regulation S-K.

Response: In response to the Staff’s comments,
the Company has revised the disclosure on page 47 to provide the range of high and low bid information for each full quarterly
period within the two most recent fiscal years and the subsequent interim periods.

Noninterest Income, page 54

 3. We note your disclosure on pages 54, 60 and 65 that when selling the guaranteed portion of SBA loans, you are required by
GAAP to defer a portion of the gain on sale over the life of the unguaranteed portion of the loan which you hold. In order to better
understand your accounting related to your SBA loan sales, please provide us the following information related to a typical SBA
loan sale, including:

 · the fair value of the portion of the SBA loan sold and the portion retained,

 · how you allocate the previous carrying amount based on the relative fair values at the date of the transfer,

 · how you calculate of the gain on sale in accordance with ASC 860-20-40-1A, and

 · the journal entry recorded.

See ASC 860-20-55-46 for an example of the information
we requested.

Response: In calculating the gain on sale of
SBA loans, the Company’s investment in the loan is allocated among the unguaranteed portion of the loan retained and
the guaranteed portion of the loan sold, based on the relative fair market value of each portion. The gain on the sold
portion of the SBA loan is recognized based on the difference between the sale proceeds and the allocated investment in the
portion sold. The difference between the portion retained (i.e. participating interest) and its relative fair market value at
the date of sale based on the cash premium bid is recorded as a loan discount and accreted into interest income over
the remaining life of the loan as an adjustment to yield. We have included below a recent SBA loan sale calculation to
illustrate how we calculate the fair market value portion sold and portion retained, the gain on sale in accordance with ASC
860-20-40-1A, and the recorded journal entry.

September 4, 2019

Page 3

Gain on Sale of SBA
Loan

FASB 166 Calculation

    GopChang Story BBQ

    Month of sale
      6

    Year of sale
      2019

    Loan amount
    $ 5,000,000

    Term (months)
      300

    % sold
      75.00 %

    Loan sale price
      110.819

      15,356.25  to SBA

    Gross Premium
    $ 390,356.25

    Fair

    Basis

    Value

    Allocation
    Difference

    Gain on sale

    Interest sold
    $ 4,140,356
      76.81 %
    $ 3,840,522

      299,834  gain

    Interest retained
    $ 1,250,000
      23.19 %
    $ 1,159,478

      90,522  deferred

    $ 5,390,356
      100.00 %
    $ 5,000,000

    Gain on sale

    Proceeds

    $ 4,140,356

    Basis

    $ 3,840,522

    Gain

    $ 299,834

    Accounting entry

    Cash

    $ 390,356.25

    Deferred Gain on Sale

    $ 90,521.90

    Gain on Sale

    $ 299,834.35

    $ 390,356.25
    $ 390,356.25

 4. Please revise your accounting policy discussion to more accurately describe your accounting related to the sale of the guaranteed
portion of the SBA loans consistent with the terminology used in ASC 860-20-40-1A, if appropriate.

Response: The Company accounts for the sale of the guaranteed
portion of SBA loans in accordance with ASC 860-20-40-1A. The Company understands that the prior disclosures on pages 54, 60 and
65 and in Note 1 of the 2018 consolidated financial statements on page F-41 in the Draft Registration Statement could result in
confusion that the Company is not accounting for this sale in accordance with ASC 860-20-40-1A. As a result and in response to
the Staff’s comment, the Company has revised the disclosure in Note 1 on page F-41 accordingly. The Company has also removed
the related disclosure on pages 54, 60 and 65, as discussed in comment #3 above, to avoid any further confusion.

September 4, 2019

Page 4

Credit Quality, page 90

 5. We note your disclosure on pages 3 and 90 that, “A significant portion of our nonperforming assets, reserves and charge-offs
are attributable to auto loan pools that we purchased in prior years.” Based on quantitative information on page 49, it appears
that the auto loans pools had an immaterial impact on certain credit metrics as of June 30, 2019. Please review your disclosure
to more accurately describe the impact of the auto loan pools on credit metrics.

Response: In response to the Staff’s comments,
the Company has removed the disclosure on pages 3 and 90 due to the immaterial impact of the auto loan pools on the Company’s
credit metrics and to keep consistent with the quantitative disclosure on page 49.

September 4, 2019

Page 5

Please do not hesitate to contact the undersigned at 404-881-7411
if you should have any questions.

    Sincerely,

    /s/ David Park

    David Park

cc: Nack Paek, Chairman and Chief Executive Officer, MetroCity
Bankshares, Inc.