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Infinity Bancorp

6 Hutton Centre Drive, Suite 100

Santa Ana, CA 92707

657-223-1000

April 5, 2023

VIA EDGAR

Securities and Exchange Commission

Office of Trade & Services

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Robert Arzonetti

    Re:

    Infinity Bancorp

    Offering Statement on Form 1-A

    As amended on March 15, 2023

    File No. 024-12158

    REQUEST FOR ACCELERATION OF QUALIFICATION

Dear Mr. Arzonetti:

Pursuant to Rule 461 of the Securities and Exchange Commission
(the “Commission”) promulgated under the Securities Act of 1933, as amended, Infinity Bancorp (the “Registrant”)
hereby requests acceleration of the qualification date of its Offering Statement on Form 1-A (File
No. 024-12158), as amended (the “Offering Statement”), so that it may become qualified before 4:00 p.m. Pacific
Time on April 14, 2023, or as soon as practicable thereafter. There are no underwriters of the issuance of the
securities being registered to join this request for acceleration.

The Registrant hereby authorizes Richard E. Knecht,
the Registrant’s attorney, and Allison Duncan, the Registrant’s Executive Vice President and Chief Financial Officer, to orally
modify or withdraw this request for acceleration.

In your letter to us dated February 27, 2023, you asked us to
confirm that at least one state has advised us that it is prepared to qualify or register our offering. This will confirm that the Department
of Financial Protection and Innovation of the State of California, on March 30, 2023, accepted the Registrant’s filing of a
Notice of Transaction Pursuant to Corporations Code Section 25102(f), authorizing us to commence selling after March 30, 2023.
We will not, of course, begin selling until after the Offering Statement has been qualified by the Commission.

No participant in our offering is being paid any compensation in connection
with our offering, so no compensation arrangements must be cleared with FINRA.

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The Registrant hereby acknowledges that:

 (i) should the Commission or the staff, acting pursuant to delegated authority, qualify the Offering Statement, it does not
                                                               foreclose the Commission from taking an action with respect to the Offering Statement;

 (ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Offering Statement
                                                                effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Offering Statement; and

 (iii) the Registrant may not assert comments of the Commission or the staff and the declaration of qualifying the Offering Statement
                                                                 as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

The Registrant requests that it be notified of such qualification by
an email to Richard E. Knecht at rknecht@knechtlaw.com, with a copy to Allison Duncan at allisond@goinfinitybank.com.

    Infinity Bancorp

    By:
    /s/ Victor E. Guerrero II

    Victor E. Guerrero II,

    President and Chief Operating Officer

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