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CORRESP
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SOUTHERN
CALIFORNIA BANCORP

12265 El Camino Real, Suite 210

San
Diego, California 92130

April
6, 2023

VIA
EDGAR

Division
of Corporation Finance

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Attention:
    Shannon
    Davis

    Michael
    Volley

    Madeleine
    Mateo

    Susan
    Block

    Re:
    Southern
    California Bancorp

    Draft
    Registration Statement on Form 10

    Submitted
    March 2, 2023

    CIK
    0001795815

Ladies
and Gentlemen:

This
letter is the response of Southern California Bancorp (the “Company”) to the comments provided by the staff of the U.S. Securities
and Exchange Commission (the “Staff”) by letter dated March 31, 2023, concerning the Company’s draft Registration Statement
on Form 10 confidentially submitted on March 2, 2023 (the “Draft Registration Statement”).

We
are concurrently publicly filing our Registration Statement on Form 10, which reflects our responses to the Staff’s comments and
certain other updated information. We will also provide the Staff courtesy copies of the Registration Statement on Form 10 (the “Public
Form 10”) marked to reflect the changes from the Draft Registration Statement.

The
Staff’s comments are copied below in italicized, bold type. Our responses follow each of the comments. Except for page references
appearing in the headings and Staff comments below (which are references to the initial filing), all page references herein correspond
to the pages of the Public Form 10.

Draft
Registration Statement on Form 10 submitted March 2, 2023

General

 1. In
                                            light of recent market events and activities within the banking sector, please revise Business,
                                            Risk Factors, Management’s Discussion and Analysis and other sections, where appropriate,
                                            to address any material impact these events and activities have had on your financial condition,
                                            operations, customer base, liquidity, capital position and risk profile. Provide quantitative
                                            and qualitative disclosure as appropriate and clarify what actions management is undertaking
                                            in response to the market events and activities.

We
have added a discussion regarding recent market events and the impact these events have had on our consolidated financial condition,
consolidated results of operations, customer base, liquidity, capital position and risk profile, as well as actions we have taken in
response to these market events. Please see pages 54-56 of the Public Form 10.

 2. In
                                            this regard, examples of expanded disclosure may include but are not limited to the following:

 ● Provide
                                            an update on your liquidity management and capital position as of a more recent date. Include
                                            qualitative and quantitative information about your cash position, investment securities,
                                            deposits, borrowings and sources of available but unused borrowings. For example, we note
                                            that you had gross unrealized losses of $9.3 million on AFS securities and $6.4 million on
                                            HTM securities at December 31, 2022. Any such revised disclosures should include identifying
                                            and discussing material stress testing scenarios, metrics or measures that you have utilized
                                            to evaluate, monitor and manage your liquidity and capital position;

We
have provided an update on our liquidity management and capital position as of March 31, 2023, including information about our cash position,
investment securities, deposits, borrowings and sources of available but unused borrowings. Please see pages 54-56 of the Public Form
10.

 ● Discuss
                                            material trends and recent activities, as of a more recent date, in your deposits balance,
                                            such as deposit inflows, withdrawals, uninsured vs. insured deposits and average rates offered
                                            by type of deposit (e.g., demand deposits, time deposits, etc.);

We
have added a discussion regarding material trends and recent activities, as of March 31, 2023, in our deposits. Please see pages 54-56
of the Public Form 10.

 ● Disclose
                                            and discuss any significant market, industry or individual concentrations in your deposit
                                            balance and how you manage the concentration risk, if applicable. For example, revise to
                                            disclose if there are any significant industries or other concentrations within the population
                                            of depositors with any deposits in excess of the FDIC insurance limit of $250,000; and

We
have added a discussion regarding the lack of significant market, industry or individual concentrations in our deposit and loan portfolios
and how we manage concentration risk and exposure to depositors with deposits in excess of the FDIC insurance limit of $250,000. Please
see pages 54-56 of the Public Form 10.

    2

 ● In
                                            regard to your Quantitative and Qualitative Disclosures about Market Risk, expand your discussion
                                            of interest rate risk and interest rate sensitivity to help readers better understand and
                                            assess potential impacts for all interest rate sensitive assets and liabilities impacting
                                            your financial condition and results of operations.

We
have expanded our discussion of interest rate risk and interest rate sensitivity to help readers better understand and assess potential
impacts for all interest rate sensitive assets and liability impacting our consolidated financial condition and consolidated results
of operations. In addition, we have revised the risk factor regarding interest rates shifts to identify the current interest rate environment
and how this environment is affecting our business. Please see pages 31-32 and 84-86 of the Public Form 10.

Item
1. Business

General
Overview, page 3

 3. Please
                                            discuss the costs and effects of compliance with environmental laws at the federal, state
                                            and local level. See Item 101(h)(4)(xi) of Regulation S-K.

We
have added a discussion regarding the costs and effects of compliance with environmental laws at the federal, state and local level.
Please see page 24 of the Public Form 10.

 4. Please
                                            include a brief explanation of what you mean by small-to-medium-sized businesses.

We
have revised our disclosure to provide a brief explanation of what we mean by small- to medium-sized businesses. Please see page 4 of
the Public Form 10.

Construction
and Land Development Loans, page 8

 5. Please
                                            discuss the specific material risks discussed in this section in a separately captioned risk
                                            factor. Please also provide separate risk factors for risks unique to each of your categories
                                            of loans, as applicable.

We
have added a separately captioned risk factor addressing the material risks associated with construction and land development loans.
We have also added separately captioned risk factors addressing the material risks associated with commercial real estate, real estate,
commercial and industrial, Small Business Administration, and consumer loans. Please see pages 34-37 of the Public Form 10.

Real
Estate Loans, page 8

 6. We
                                            note your disclosure in this section discussing the risks of interest rates on real estate
                                            loans. We also note your disclosure on page nine discussing the number of commercial real
                                            estate loans contained in your loan portfolio and the effect the deterioration of one or
                                            a few of these loans could cause on your nonperforming assets. Please discuss these risks
                                            in a separately captioned risk factor and as appropriate in the management’s discussion
                                            and analysis of financial condition and results of operations.

We
have added separately captioned risk factors addressing the material risks associated with increasing interest rates on our real estate
loans and the effect of a deterioration of one or a few of our commercial real estate loans on our nonperforming assets. Please see page
35 of the Public Form 10. As our total non-performing assets decreased to $41 thousand or 0.002% of total assets at December 31, 2022
(see page 73 of the Public Form 10), we have not supplemented the management’s discussion and analysis of financial condition and
results of operations section to discuss the impact of these matters on our actual performance.

    3

Small
Business Administration (“SBA”) Loans, page 9

 7. Please
                                            briefly explain the designation of “Preferred Lender” and any material effect
                                            it may have on your business. To the extent the government may revoke your Preferred Lender
                                            status, please discuss any material adverse risks such action may have on your business in
                                            the Risk Factors section.

We
have expanded our disclosure regarding our “Preferred Lender” designation in this section and added a separately captioned
risk factor addressing the material risks associated with our SBA lending program. Please see pages 11 and 36 of the Public Form 10.

Consumer
Loans, page 10

 8. We
                                            note your disclosure that consumer loans are generally considered to have greater risk than
                                            first or second mortgages on real estate because they may be unsecured, or, if they are secured,
                                            the value of the collateral may be difficult to assess and more likely to decrease in value
                                            than real estate. Please include a separately captioned risk factor discussing such risks.

We
have added a separately captioned risk factor addressing the material risks associated with consumer loans. Please see page 37 of the
Public Form 10.

Deposit
Products, page 11

 9. Please
                                            briefly expand your disclosure regarding the Insured Cash Sweep deposit program, such as
                                            how it is described as insured and if government regulation is involved.

We
have expanded our disclosure regarding the Insured Cash Sweep deposit program. Please see page 13 of the Public Form 10.

Dividend
Restrictions Applicable to the Bank, page 18

 10. We
                                            note your disclosure on page 18 that the primary source of funds for the company is expected
                                            to be dividends paid by the bank, which is subject to certain restrictions. Please include
                                            a separately captioned risk factor in the risk factors section discussing such risks.

We
have added a separately captioned risk factor addressing the material risks associated with our reliance on dividends from the Bank as
our primary source of funds. Please see page 39 of the Public Form 10.

    4

Item
1A. Risk Factors

We
face risks related to pandemics, natural disasters, page 21

 11. Please
                                            revise to include a separate risk factor, with its own separate subheading, to discuss how
                                            natural disasters affect your target market and the type of loans you originate and / or
                                            hold for investment.

We
have added a separately captioned risk factor addressing the material risks associated with natural disasters and their affect on our
target market and the types of loans we originate and hold for investment. Please see page 30 of the Public Form 10.

Interest
rate shifts, page 22

 12. Please
                                            revise this risk factor subheading to address what cycle interest rate shifts currently are
                                            in, such as rising interest rates, so that investors can assess the risk. Please address
                                            more specifically in the risk factor how the current interest environment is affecting or
                                            may affect your business.

We
have revised this risk factor to identify the current interest rate environment and how this environment is affecting our business. Please
see pages 31-32 of the Public Form 10.

Regulatory
policies regarding loans secured by commercial real estate, page 23

 13. We
                                            note your disclosure that as of December 31, 2022, your CRE loans for purposes of the guidance
                                            represented 555.7% of your total risk-based capital. Please include a separately captioned
                                            risk factor to discuss the risk that your loans for purposes of the federal banking agencies
                                            guidance appear to be on the high end of concentration risk under the guidance, or advise.

We
have revised this risk factor to address the material risks associated with our concentration of commercial real estate loans and the
impact of federal banking agency guidance relative to such concentration. Please see pages 33-34 of the Public Form 10.

If
we do not manage our liquidity effectively, our business could suffer, page 24

 14. Please
                                            briefly expand your risk factor disclosure to describe what you mean by alternative funding
                                            and the availability of such alternative funding, as applicable, so that investors can assess
                                            the risk.

We
have revised this risk factor to describe what we mean by alternative funding sources and the availability of such alternative funding
sources. Please see pages 37-38 of the Public Form 10.

    5

New
lines of business, products, products enhancements, page 26

 15. Please
                                            revise in this risk factor to clarify if you have begun to implement the new lines of businesses
                                            you mention in the risk factor, as well as clarify where you are in the process of implementation.

Subsequent
to filing the Draft Registration Statement, we determined that we will not implement the new line of business mentioned in this risk
factor. We have therefore revised this risk factor to clarify that we have not begun to implement any new lines of business. Please see
page 40 of the Public Form 10.

Our
failure to comply with stringent capital requirements, page 28

 16. We
                                            note your disclosure that you are subject to capital ade