CORRESP Filing
Avidia Bancorp, Inc.
Date: May 6, 2025 · CIK: 0002058758 · Accession: 0001193125-25-113789
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-285815
Referenced dates: May 2, 2025
Letter
Re: Avidia Bancorp, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed April 25, 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. 2 to Registration Statement on Form S-1, including exhibits (the “Amended Registration Statement”), which is marked pursuant to SEC Rule 472. The Staff’s comment, transmitted by letter dated May 2, 2025, is reproduced below, followed by the Company’s response. Amendment No. 1 to Registration Statement on Form S-1 Loan Approval Procedures, Loans to One Borrower Limit and Lending Authority, page 79 1. We note your disclosure on page 37 that your current underwriting standards have evolved since the $25 million land loan discussed in Loan Matter was originated. Please revise your disclosure here to discuss how your underwriting standards have evolved, including any change to the governance provided by the Executive Committee for outstanding loans to identify any other loans that may not meet your revised underwriting standards. The requested disclosure has been added to page 71 of the Prospectus.
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 May 6, 2025 Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549
L USE G ORMAN , PC United States Securities and Exchange Commission Division of Corporation Finance May 6, 2025 Page
If you have any questions, please contact the undersigned.
Very truly yours,
/s/ Victor L. Cangelosi
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CORRESP 1 filename1.htm 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 May 6, 2025 Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549 Re: Avidia Bancorp, Inc. Amendment No. 1 to Registration Statement on Form S-1 Filed April 25, 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. 2 to Registration Statement on Form S-1, including exhibits (the “Amended Registration Statement”), which is marked pursuant to SEC Rule 472. The Staff’s comment, transmitted by letter dated May 2, 2025, is reproduced below, followed by the Company’s response. Amendment No. 1 to Registration Statement on Form S-1 Loan Approval Procedures, Loans to One Borrower Limit and Lending Authority, page 79 1. We note your disclosure on page 37 that your current underwriting standards have evolved since the $25 million land loan discussed in Loan Matter was originated. Please revise your disclosure here to discuss how your underwriting standards have evolved, including any change to the governance provided by the Executive Committee for outstanding loans to identify any other loans that may not meet your revised underwriting standards. The requested disclosure has been added to page 71 of the Prospectus. L USE G ORMAN , PC United States Securities and Exchange Commission Division of Corporation Finance May 6, 2025 Page 2 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.