CORRESP Filing
Lake Shore Bancorp, Inc. /MD/
Date: April 29, 2025 · CIK: 0002059653 · Accession: 0001193125-25-104006
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-285836
Referenced dates: April 2, 2025
Letter
Re: Lake Shore Bancorp, Inc. Registration Statement on Form S-1 Filed March 14, 2025 File No. 333-285836 To Whom It May Concern: On behalf of Lake Shore 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 comment, transmitted by letter dated April 2, 2025, is reproduced below, followed by the Company’s response. The Amended Registration Statement includes a “Recent Developments” section containing unaudited financial information as of and for the three-month periods ended March 31, 2025 and 2024. Form S-1 filed March 14, 2025 How We Intend To Use The Proceeds From The Stock Offering, page 36 1. We note that you may, “potentially restructure Lake Shore Bank’s investment securities portfolio.” Either here or elsewhere, as appropriate, provide additional details about this potential restructuring. Response: Page 43 has been revised to provide additional information regarding the potential securities restructuring.
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) 274-2010
bazoff@luselaw.com April 29, 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 April 29, 2025 Page 2 We trust the foregoing is responsive to the Staff’s comments. We request that the Staff advise the undersigned at (202) 274-2010 as soon as possible if it has any further comments.
Respectfully,
/s/ Benjamin Azoff
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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) 274-2010 bazoff@luselaw.com April 29, 2025 Via EDGAR United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, DC 20549 Re: Lake Shore Bancorp, Inc. Registration Statement on Form S-1 Filed March 14, 2025 File No. 333-285836 To Whom It May Concern: On behalf of Lake Shore 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 comment, transmitted by letter dated April 2, 2025, is reproduced below, followed by the Company’s response. The Amended Registration Statement includes a “Recent Developments” section containing unaudited financial information as of and for the three-month periods ended March 31, 2025 and 2024. Form S-1 filed March 14, 2025 How We Intend To Use The Proceeds From The Stock Offering, page 36 1. We note that you may, “potentially restructure Lake Shore Bank’s investment securities portfolio.” Either here or elsewhere, as appropriate, provide additional details about this potential restructuring. Response: Page 43 has been revised to provide additional information regarding the potential securities restructuring. L USE G ORMAN , PC United States Securities and Exchange Commission Division of Corporation Finance April 29, 2025 Page 2 We trust the foregoing is responsive to the Staff’s comments. We request that the Staff advise the undersigned at (202) 274-2010 as soon as possible if it has any further comments. Respectfully, /s/ Benjamin Azoff Benjamin Azoff Enclosure cc: Todd Schiffman, Esq., SEC Christian Windsor, Esq., SEC Kim C. Liddell, President and CEO, Lake Shore Bancorp, Inc.