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April 4, 2024
Charles D. Schmalz
Chief Executive Officer
EWSB Bancorp, Inc.
109 West Second Street
Kaukauna, WI 02492
Re:EWSB Bancorp, Inc.
Registration Statement on Form S-1
Filed March 11, 2024
File No. 333-277828
Dear Charles D. Schmalz:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Registration Statement on Form S-1
General
1.Please provide us with supplemental 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,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications. Please contact Madeleine Mateo at (202) 551-3465 to discuss how to
submit the materials, if any, to us for our review.
Cover Page
2.We note your disclosure on page 6 and other sections of the prospectus that generally no
individual may purchase more than 15,000 shares of common stock. Please disclose the
maximum purchase amount on the cover page of the prospectus.

 FirstName LastNameCharles D. Schmalz
 Comapany NameEWSB Bancorp, Inc.
 April 4, 2024 Page 2
 FirstName LastName
Charles D. Schmalz
EWSB Bancorp, Inc.
April 4, 2024
Page 2
Summary, page 1
3.We note that based on your website, you appear to offer insurance products. If material to
an understanding of your business, please include disclosure about your insurance
products here, in the Management's Discussion and Analysis of Financial Condition and
Results of Operations and Business sections, and elsewhere as appropriate or advise.
Please refer to Item 101(h) of Regulation S-K.
4.Refer to page 110. We note your disclosure that depositors of East Wisconsin Savings
Bank are members of, and have voting rights in, Wisconsin Mutual Bancorp, MHC, as to
all matters requiring a vote of members. Upon completion of the conversion, depositors
will no longer have voting rights. Please disclose this in the summary section or include a
cross-reference to this section.
5.Please disclose here that you have incurred losses in the two most recent fiscal years.
Risk Factors, page 15
6.We note your disclosure on page 51 that deposits decreased $18.7 million, or 7.5% from
December 31, 2022 to December 31, 2023. Please include risk factor disclosure describing
material risks to investors as a result of the past, as well as possible future decreases in
deposits.
7.We note your disclosure on page 66 that 9% of your one- to four-family residential real
estate loans were jumbo loans. If material, please disclose risks to investors as a result of
originating a significant number of jumbo loans or advise.
The geographic concentration of our loan portfolio, page 16
8.If your local market area has experienced any material declines in real estate values during
the last year or a material increase in the number of foreclosures, please consider revising
the risk factor to include this information.
Inflationary pressures and rising prices may affect our results of operations, page 18
9.We note your risk factor indicating that inflation can have an adverse impact on your
business and on your customers. Please update this risk factor to discuss if recent
inflationary pressures have materially impacted your operations. In this regard, if
applicable, discuss how your business has been materially affected by the inflationary
pressures you are facing.

 FirstName LastNameCharles D. Schmalz
 Comapany NameEWSB Bancorp, Inc.
 April 4, 2024 Page 3
 FirstName LastName
Charles D. Schmalz
EWSB Bancorp, Inc.
April 4, 2024
Page 3
Risks Related to Our Business Strategy and Operational Matters, page 19
10.For each of the practices, conditions, and requirements in the memorandum of
understanding, please describe here or elsewhere, as appropriate, the actions you have
taken or plan to take to resolve each noted area, including a summary of your progress to
date.
Our Policy Regarding Dividends, page 37
11.We note your disclosure in the risk factor on page 20 that your net worth ratio was less
than 6% and you may be restricted from paying dividends while this ratio continues to be
less than 6%. Please revise this section to describe this limitation on payment of
dividends.
Provision for Credit Losses, page 53
12.We note your disclosure that the provision for 2023 was due to your adoption of the
CECL methodology. Please enhance your discussion to include the factors that influenced
management’s estimate of expected credit losses as of December 31, 2023, under the
CECL methodology.
Management of Market Risk, page 56
13.We note your references to the asset liability committee here. You also state that the
committee is "comprised of executive officers and certain other members of senior
management, and reports to the full board of directors on at least a quarterly basis." Please
disclose if this committee is a sub-committee of your board of directors and who serves on
the committee. Disclose if the board or the asset liability committee sets policies and
guidelines for managing interest rate risk and if so, whether the changes referenced in the
first paragraph below the two tables on page 58 were within the limits of such policies and
guidelines.
Off-Balance Sheet Arrangements and Aggregate Contractual Obligations, page 60
14.We note your disclosure on page F-12 that the allowance for credit losses (“ACL”) related
to your off-balance sheet credit exposures is estimated at each balance sheet date under
the CECL model. Please revise your discussion to include the amount of ACL that relates
to your off-balance sheet credit exposures as of each period presented.
Loan Approval Procedures, Loans to One Borrower Limit and Lending Authority, page 72
15.We note your references to the "loan committee" in this section. Please clarify if the
committee is comprised of your officers and directors and disclose who currently serves
on the committee.

 FirstName LastNameCharles D. Schmalz
 Comapany NameEWSB Bancorp, Inc.
 April 4, 2024 Page 4
 FirstName LastName
Charles D. Schmalz
EWSB Bancorp, Inc.
April 4, 2024
Page 4
Allocation of Allowance for Credit Losses, page 78
16.We note your tabular disclosure on page F-26 depicting changes in the allowance for
credit losses for the twelve months ended December 31, 2023. This disclosure indicates
that while the adoption of the CECL methodology under ASC 326 did not result in a
transition adjustment to the overall allowance for credit losses, it did result in adjustments
to the allowance associated with different segments and classes of loans receivable. Please
revise the discussion on page 78 to disclose how the adoption impacted the comparative
allocation of the allowance loan loss table, including noted increases and decreases in
allocated amounts, such as those associated with one-to four family real estate loans and
consumer loans, etc. Please also ensure that other filing disclosures associated with your
CECL adoption are consistent and complete, especially those associated with your
different loan segments and classes.
Internal Agreement with Regulators, page 95
17.We note your disclosure here that the MOU "places certain restrictions on [your]
operations." Please briefly describe material restrictions placed on your operations by the
MOU or advise.
The Business Background of Our Directors and Executive Officers, page 97
18.Please revise the biographical descriptions for Ms. Lisa Cruz, Mr. Kenneth Demerath, Ms.
Lori Hoersch, and Mr. Steve Tyink to disclose the period during which each such director
or executive officer has served in that position. In addition, please revise to provide each
officer's or director's principal occupation and employment during the past five years, the
dates they served in those roles and the name and principal business of any corporation or
other organization in which such occupation and employment was carried on. Refer to
Item 401(e) of Regulation S-K.
Transactions with Certain Related Persons, page 99
19.Please provide all the information required by Item 404(d) of Regulation S-K in this
section. As non-exclusive examples, we note your disclosure on page 51 that Old EWSB
Bancorp issued promissory notes to various directors and officers and that New EWSB
Bancorp will pay a fee to the Bank for the use of its premises on page 62. In addition,
refer to your disclosure regarding the "related party subordinated promissory notes" on
page F-34.
Benefits to be Considered Following Completion of the Stock Offering, page 104
20.Please remove the last paragraph on page 106 starting with "[t]he tables presented above
are provided for informational purposes only."

 FirstName LastNameCharles D. Schmalz
 Comapany NameEWSB Bancorp, Inc.
 April 4, 2024 Page 5
 FirstName LastName
Charles D. Schmalz
EWSB Bancorp, Inc.
April 4, 2024
Page 5
Approvals Required, page 109
21.We note that the affirmative vote of a majority of the total votes eligible to be cast by the
members of Wisconsin Mutual Bancorp, MHC (i.e., depositors and certain borrowers of
East Wisconsin Savings Bank) is required to approve the plan of conversion. Please revise
to disclose when you plan to conduct these votes, how the timing of the vote relates to the
timing of the effectiveness of the registration statement, and how this vote will be
conducted, such as with a proxy statement, or advise. Please also briefly describe what
types of matters currently require depositor approval under "Effect on Voting Rights of
Depositors" on page 110.
Note 13. Equity and Regulatory Matters, page F-38
22.We note your disclosure on page F-40 that at December 31, 2023, the Bank’s net worth
ratio was 4.1%. We also note your disclosure on pages 20, 33, 39 and 60 that the net
worth ratio was 4.5%. Please explain this apparent inconsistency and revise your
disclosure as necessary.
Exhibits
23.We note that you entered into an agreement with an unaffiliated broker as a source for
certain marine and recreational vehicles per your disclosure on page 71. If material, please
file the agreement as an exhibit to the registration statement and disclose its material
terms. Refer to Item 601 of Regulation S-K.
            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.
            Please contact Shannon Davis at 202-551-6687 or Ben Phippen at 202-551-3697 if you
have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at 202-551-3601 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Zachary A. Davis, Esq.