SecProbe.io

April 5, 2019
Garry Kleer
Chairman of the Board, President and Chief Executive Officer
Richmond Mutual Bancorporation, Inc.
31 North 9th Street
Richmond, IN 47374
Re:Richmond Mutual Bancorporation, Inc.
Registration Statement on Form S-1
Filed March 11, 2019
File No. 333-230184
Dear Mr. Kleer:
            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.
Registration Statement on Form S-1
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.
Summary, page 1
2.Please provide a summary of the risks related to your business and this offering.

 FirstName LastNameGarry Kleer
 Comapany NameRichmond Mutual Bancorporation, Inc.
 April 5, 2019 Page 2
 FirstName LastNameGarry Kleer
Richmond Mutual Bancorporation, Inc.
April 5, 2019
Page 2
Business Strategy
Lending, page 3
3.In order to provide investors with a more balanced picture of your strategy, briefly discuss
the relatively unseasoned nature of your loan portfolio and the percentage of commercial
loans and loans in the Columbus, Ohio market.
How We Intend to Use the Proceeds from the Offering, page 7
4.For balance, disclose here or elsewhere in the summary that as a result of the one-time
termination fee to terminate the Pentegra DB Plan, you expect to report a net loss for the
fiscal year ending December 31, 2019.
Risk Factors
Risks Related to Our Business
Non-compliance with the USA PATRIOT Act, Bank Secrecy Act, or other laws and regulations
could result in fines or sanctions, page 25
5.Please revise to clarify whether you have been subject to fines or other penalties, or have
suffered business or reputational harm, as a result of money laundering activities in the
past.
We will have broad discretion in using the proceeds, page 28
6.Revise this risk factor to disclose your current return on equity, your current equity
position, and your expected equity position after the offering.
Pro Forma Data, page 44
7.Please tell us how the adjustments related to the termination of the Pentegra Defined
Benefit Plan gives effect to events that are (i) directly attributable to the transaction, (ii)
expected to have a continuing impact on the company, and are (iii) factually supportable
pursuant to Rule 11-02(b)(6) of Regulation S-X.  Also, please include a footnote related to
these adjustments as required by Rule 11-02(b)(6) of Regulation S-X in your next
amendment.
            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.

 FirstName LastNameGarry Kleer
 Comapany NameRichmond Mutual Bancorporation, Inc.
 April 5, 2019 Page 3
 FirstName LastName
Garry Kleer
Richmond Mutual Bancorporation, Inc.
April 5, 2019
Page 3
            You may contact David Irving at 202-551-3321 or John Nolan at 202-551-3492 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jessica Livingston at 202-551-3448 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services