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CORRESP
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 CORRESP

 LUSE GORMAN, PC
 Attorneys at Law 5335
WISCONSIN AVENUE, N.W., SUITE 780 Washington, D.C. 20015
 TELEPHONE (202) 274-2000
 Facsimile (202) 362-2902
 www.luselaw.com

 WRITER’S DIRECT DIAL NUMBER

 WRITER’S E-MAIL

 (202) 274-2028

 vcangelosi@luselaw.com
 April 25, 2025
 Via EDGAR United States Securities and Exchange
Commission Division of Corporation Finance 100 F Street, NE
 Washington, DC 20549

 Re:

 Avidia Bancorp, Inc.

 Registration Statement on Form S-1

 Filed March 14, 2025

 File No. 333-285815
 To Whom It May Concern:
 On behalf of Avidia Bancorp, Inc. (the “Company”), filed herewith is its Pre-Effective
Amendment No. 1 to Registration Statement on Form S-1, including exhibits (the “Amended Registration Statement”), which is marked pursuant to SEC Rule 472. The Staff’s comments, transmitted
by letter dated April 8, 2025, are reproduced below, followed by the Company’s responses. The Amended Registration Statement includes a “Recent Developments” section containing unaudited consolidated financial information as of
and for period ended March 31, 2025, beginning on page 35 of the Prospectus. 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 disclosure on pages 2 and 68 of the Prospectus has been revised.

 L USE G ORMAN , PC
 United States Securities and Exchange Commission Division of
Corporation Finance April 25, 2025 Page
 2
 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.
 The disclosure on page 18 of the Prospectus has been revised.
 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 disclosure on pages
19 and 20 of the Prospectus has been revised. 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. Additional disclosure has been added to
page 32 of the Prospectus. 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. The disclosure on page 76 of the Prospectus has been
revised. Additionally, a new risk factor devoted to condominium association lending has been added to page 17 of the Prospectus.

 L USE G ORMAN , PC
 United States Securities and Exchange Commission Division of
Corporation Finance April 25, 2025 Page
 3
 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. The disclosure on page 90 of the Prospectus has been revised.
 The investment commissions disclosed in the income statement on page F-5 of the Prospectus are
unrelated to the two subsidiaries that hold investment securities. Rather, these commissions relate to investment management services offered by Avidia Bank. Additional disclosure has been added, also on page 90 of the Prospectus, to describe the
investment management services. 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.
 Additional disclosure has been added to pages 105 and 106 of the Prospectus.
 *  *  *
 If you have any questions, please contact the undersigned.
 Very truly yours,
 /s/ Victor L. Cangelosi
 Victor L. Cangelosi Enclosure

 cc:

 Victor Cecco, SEC

 Robert Klein, SEC

 Madeleine Joy Mateo, SEC

 Christian Windsor, SEC

 Robert D. Cozzone, Avidia Bancorp, Inc.

 Barry H. Jensen, Avidia Bancorp, Inc.

 Lawrence M.F. Spaccasi, Esq.

 Kent M. Krudys, Esq.