SecProbe.io

October 3, 2018
Michael J. Quinn
President and Chief Executive Officer
Rhinebeck Bancorp, Inc.
2 Jefferson Plaza
Poughkeepsie, NY 12601
Re:Rhinebeck Bancorp, Inc.
Registration Statement on Form S-1
Filed September 10, 2018
File No. 333-227266
Dear Mr. Quinn:
            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.
Form S-1 filed September 10, 2018
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.
How We Determined the Offering Range and the $10.00 per Share Offering Price, page 5
2.It appears the valuation of peer group companies in the first table on page 6 is shown on a
fully-converted basis.  If so, please revise to clarify in the table and in the disclosure

 FirstName LastNameMichael J. Quinn
 Comapany NameRhinebeck Bancorp, Inc.
 October 3, 2018 Page 2
 FirstName LastName
Michael J. Quinn
Rhinebeck Bancorp, Inc.
October 3, 2018
Page 2
preceding the table that only the selected pricing ratios for Rhinebeck Bancorp are
presented on a non-fully converted basis.  Also, please discuss the impact of full or partial
conversion on the comparability of the peer group information to the information about
the company.  If you have made adjustments to the earnings or book values of the peer
group companies for purposes of this comparison, please clarify.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Delinquent Loans , page 66
3.Please disclose delinquent information for the indirect automobile lending program given
its significance and your future plans to grow this lending.
Allowance for Loan Losses, page 69
4.Please disclose indirect automobile loan charge-offs and recoveries for the periods
presented.

            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Marc Thomas at 202-551-3452 or Gus Rodriguez at 202-551-3752 if
you have questions regarding comments on the financial statements and related matters.  Please
contact David Gessert at 202-551-2326 or Pam Long at 202-551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services
cc:       Scott A. Brown, Esq.