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 April 8, 2025

Robert D. Cozzone
President and CEO
Avidia Bancorp, Inc.
42 Main Street
Hudson, MA 01749

 Re: Avidia Bancorp, Inc.
 Registration Statement on Form S-1
 Filed March 14, 2025
 File No. 333-285815
Dear Robert D. Cozzone:

 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
Business Strategy, page 2

1. We note your disclosure that you are in the process of developing and
implementing a
 digital deposit account opening system and are currently developing a
comprehensive
 cloud-based resource known as a "data lake." Please further describe the
"data lake"
 and its role in your business. Please also describe the status of these
development
 efforts.
The geographic concentration of our loan portfolio and lending activities makes
us vulnerable
to a downturn in the local economy, page 18

2. Please revise this risk factor to discuss, as appropriate, the factors
that may impact
 your primary market area. For instance, discuss factors that impact your
primary
 market area's commercial real estate market.
 April 8, 2025
Page 2
Risks Related to Payments Processing Activities, page 19

3. We note your disclosure on page 81 that there are concentrations in
deposits related to
 your card acquiring business. Revise the appropriate risk factor to
discuss the
 potential risks related to concentration of deposits by your merchant
and ISO clients.
The contribution to the charitable foundation will dilute your ownership, page
32

4. Please revise the narrative disclosure in this risk factor to quantify
the
 potential dilution of an investor's ownership interest in Avidia at the
midpoint of the
 offering as a result of the contribution to the charitable foundation.
Commercial and Industrial Loans, page 70

5. We note that loans to condominium associations are among your largest
grouping of
 loans. We also note that your largest concentration of these loans that
are outside of
 your home market area are in Florida, including your largest single
loan. Please
 discuss the extent to which you conduct ongoing monitoring of your
condominium
 loans. For example, do you monitor the need for assessments by Florida
based
 condominiums for salt water corrosion and concrete damage and the
ability of those
 associations to successfully collect the assessments owed by their
members? Consider
 also revising your risk factors discussion of the risks posed by your
lending business
 in the Risk Factors section based on your response.
Subsidiary Activities, page 84

6. We note the discussion of your subsidiary activities. Please expand upon
the
 description of your subsidiaries' businesses. If material to your
business, please
 describe how such subsidiaries generate revenue or advise. In this
regard, we note
 your disclosure on page F-5 that non-interest income includes investment
 commissions.
Business Background of Our Directors, page 98

7. We note that for a number of your Directors, the business positions held
during the
 last five years is unclear from the disclosure. For instance, it is
unclear when Mr. Saul
 began work for NVIDIA. Refer to Item 401(e)(1) of Regulation S-K.
 April 8, 2025
Page 3

 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 Victor Cecco at 202-551-2064 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Christian Windsor at
202-551-3419 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Victor L. Cangelosi, Esq.
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