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Old
Glory Holding Company

3401
NW 63rd Street, Suite 600

Oklahoma
City, OK 73116

  December 13,
  2024

Mr.
Robert Arzonetti

US
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Finance

    Re:
    Old
    Glory Holding Company

    Offering
    Statement on Form 1-A

    File
    No. 024-12512

Dear
Robert:

Thank
you for your letter dated December 12, 2024, relating to our issuance of Class B Common Stock in Old Glory Holding Company, a Delaware
Corporation (the “Company”), pursuant to our Amended Form 1-A, dated November 25, 2024. As always, we appreciate the
thorough work by you and your colleagues.

Accompanying
this letter is a red-line of our Amended Form 1-A, dated December 13, 2024, that is compared to our November 25, 2024 Amendment.

In
response to your questions and comments, here are our responses, which follow the same number sequence in your letter. The pages numbers
referenced below align with the accompanying red-line.

Form
1-A

 1. We
                                            made these requested changes to page 4.

 2. We
                                            made this requested change to page 4.

 3. In
                                            Section 5.3 of the Subscription Agreement, we deleted the “Waiver of Jury Trial.”
                                            Thus, on page 30 (previously 31), we deleted the applicable disclosure about waiving a jury
                                            trial.

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 4. Management
                                            does not take the view that Old Glory Bank is competing with any particular bank, in any
                                            given business line or market, including the State of Oklahoma. Old Glory Bank has customers
                                            in all 50 states and, thus, Management believes it is impossible to explain the differences
                                            in our business lines (deposit accounts, CDs, home loans, business loans, etc.) against the
                                            4,577 banks available across America, including the 50-state mega banks. Management continues
                                            to believe that because of the rapid ascent of online banking services, customers frequently
                                            consider banking services to be a commodity, indistinguishable among the various 50-state
                                            banks, which is why Old Glory Bank always talks to customers about brand, values and customer
                                            service. Old Glory Bank does not promote interest rates, because we do not make interest
                                            rates a distinguishing factor. Old Glory Bank does not promote “mortgage rates,”
                                            because mortgage rates are driven by the secondary market and are not a distinguishing factor.
                                            Old Glory Bank does not promote interest rates for SBA loans, because SBA loans are primarily
                                            driven by the SBA, and are not a distinguishing factor. Instead, while every 50-state mega
                                            bank generally has capable technology to compete with Old Glory Bank, Management believes
                                            the actual competition to Old Glory Bank is from the “friction” of a customer
                                            opening a new bank account, plus the ensuing journey of setting up direct deposit and becoming
                                            top of wallet. We believe we properly describe this within our Offering Circular, including
                                            on page 46 (previously 47). For example, the reason why we created and launched Old Glory
                                            Cash-IN, was not to compete with any particular bank, but to remove a “friction”
                                            point of customers depositing cash via an online bank. In summary, we believe our primary
                                            competitor is not actually from other banks (even the mega banks), but competition for the
                                            “time and attention” required from a “busy” customer to open a new
                                            account and then start using Old Glory Bank. This is why we focus our attention on products
                                            and customer service, and not on other banks.

 5. Our
                                            previous response was intended to comment on the restriction relating to dividends, bonuses,
                                            etc., not the 14% Tier 1 Leverage Ratio. There is no express regulatory requirement for a
                                            14% Tier I Leverage Ratio. 12 CFR 324.10 requires a 4% leverage ratio and the CBLR requires
                                            a 9% leverage ratio. Old Glory Bank is currently bound to 14% leverage ratio because Old
                                            Glory Bank was contractually committed to such 14% in 2022, as a pre-condition to obtaining
                                            approval to purchase First State Bank. Such 14% commitment was then re-affirmed in the Consent
                                            Order. While this was mentioned on Page 101 (previously, page 104), Management recognizes
                                            that its discussion did not perfectly clarify that such 14% leverage ratio actually first
                                            originated from a contractual commitment made in 2022, not the Consent Order, so we have
                                            made those updates therein. Both Management and our Board of Directors, including Mr. Joe
                                            Meade, believe that once Old Glory Bank is profitable (and assuming then in compliance with
                                            applicable rules and regulations), there will be no continuing justification for the regulators
                                            to require such a high leverage ratio. Instead, we believe Old Glory bank will be successful
                                            in having a typical leverage ratio that is typical for a comparably sized bank, which Management
                                            and our Board believes in their experience, to be 7% - 9%.

For
context, many people confuse risk weighted leverage ratios with this tier 1 leverage ratio. A risk weighted leverage ratio is
different than a tier 1 leverage ratio. Old Glory Bank has no special commitments relating to risk weighted ratios and, thus, no special
limitation on loans, etc.

Long-term,
Management does not believe there will be any impact from this 14% Tier 1 Leverage Ratio, which originated in 2022, because Management
does not believe that this high leverage ratio will exist long-term for the reasons described above. In the short-term, this 14% Tier
1 Leverage Ratio is a burden on capital raising and does require Old Glory Holding Company to raise additional capital by issuing additional
shares (which other banks of a comparable size may not have to raise). These additional shares from this additional capital does create
dilution, reduced EPS, and reduced ROE. However, we believe we properly show the dilution of the issuance of these shares in our Offering
Circular.

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Interestingly,
in the short-term, a higher Tier 1 Leverage Ratio could actually increase the profitability of Old Glory Bank because it raises our “legal
lending limit,” and provides additional “cash” on our balance sheet earning interest at the Federal Funds rate. With
regard to lending, a bank’s “legal lending limit” is tied to tier 1 capital (not deposits, like many people believe).
Thus, the higher the tier 1 capital, the higher a bank’s legal lending limit. So, Old Glory Bank, with a disproportionately higher
tier 1 leverage ratio, can actually originate fewer, larger loans, as compared to a typical bank of its size, which likely has less tier
1 capital and a lower legal lending limit. With the typical number of FTEs for a bank of our size, it may be more profitable to do fewer,
larger loans, than other banks of our size can legally do. However, please note that this discussion about the legal lending limit is
only for purposes of this Comment and not to suggest any change in the lending strategy of Old Glory Bank that is adopted by our Board
of Directors from time to time.

6-11 We
                                            made the decision to delete our 5-Year Projections (and applicable commentary) from our Offering
                                            Circular and, thus, we believe these comments are no longer applicable. Many pages of the
                                            Offering Circular were impacted by this change, and the bulk of such changes are on pages
                                            14 (previously 15), 58 (previously 59), and 85-88 (previously 86-91).

12. We
                                            added new risk language on Page 42 (previously 43), Business Banking Product, and Page 101
                                            (previously 104), Capital Requirements.

13. We
                                            made these requested changes on Pages 102 (previously 105).

14. We
                                            made these changes on Pages 14 (previously 15) and 102 (previously 105).

Again,
we thank you and your colleagues for the review of our materials, which we believe we have now addressed.

Please
let me know if you have any questions.

    Sincerely,

    Old
    Glory Holding Company

    By:
    /s/
    Michael P. Ring

    Michael
    P. Ring

    President
    and CEO

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