SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 9, 2025

Jospeh Vitale
President and Chief Executive Officer
Seneca Bancorp, Inc.
35 Oswego Street
Baldwinsville, NY 13027

 Re: Seneca Bancorp, Inc.
 Registration Statement on Form S-1
 Filed June 13, 2025
 File No. 333-288044
Dear Jospeh Vitale:

 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 filed June 13, 2025
Cover Page

1. We note that the Seneca Savings 401(k) Plan is offering participation
interests of up to
 135,438 shares of your common stock. As such, please include Seneca
Savings 401(k)
 Plan as a co-registrant on the cover page.
2. Please revise your disclosure on the cover page of the prospectus and
prospectus
 supplement to clarify if the offering is contingent on receipt of
approval to be quoted
 on the OTCQX Market.
 July 9, 2025
Page 2
Our Business, page 2

3. We note your disclosure here and throughout that you purchased land in
Clay, New
 York and intend to establish a future branch office on this property.
Please revise your
 discussion regarding this site to provide more details of the status of
development of
 the future branch office, including what actions, if any that you have
taken beyond the
 land purchase, and any anticipated opening date.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Comparison of Results of Operations, page 58

4. We note your disclosure on page F-64 that you have two reportable
segments, Seneca
 Savings and Financial Quest. Please revise your Management's Discussion
and
 Analysis section to expand the discussion of your operating results for
each period
 presented at the segment level, including significant factors materially
affecting your
 segment results. Refer to Item 303(b) of Regulation S-K.
5. We note your disclosure on page 21 that you had approximately $223
million in assets
 under management ( AUM ) at March 31, 2025, and generated
approximately 46% of
 your non-interest income from your wealth management activities for the
three
 months ended March 31, 2025. Please revise to quantify your AUM as of
each period
 end presented and discuss any significant trends or concentrations
within your AUM,
 as well as related drivers impacting your revenues and operating results
from wealth
 management activities.
Transactions with Certain Related Persons, page 100

6. We note your disclosure that Seneca Savings makes certain loans through
an
 employee loan program pursuant to which loans are made at reduced rates.
For loans
 made under the employee loan program to officers, directors and other
related parties
 exceeding the threshold amount, please provide the information required
by Item
 404(a) of Regulation S-K.
Director Compensation, page 106

7. Please confirm that the Director Compensation Table figures include the
fees earned
 for serving on the boards of Seneca Financial MHC and Seneca Savings
Insurance
 Agency, Inc. in 2024 or revise the table to include those fees.
Table of Contents, page F-1

8. Please revise your filing to provide relevant subsequent event
disclosures required by
 ASC 855-10-50.
9. We note that the registrant for this offering is Seneca Bancorp, Inc.
which was
 recently formed; however, the financial statements included in the
offering are for
 Seneca Financial Corp. and subsidiaries. Please revise to include
financial statements
 of the registrant or revise to disclose why they are not required to be
filed.
 July 9, 2025
Page 3
Note 2. Summary of Significant Accounting Policies
Allowance for Credit Losses Loans, page F-14

10. We note that loans are charged off when management believes the
uncollectibility of a
 loan balance is confirmed. Please revise to expand your charge-off
policy for
 recognizing write-offs within the allowance for credit losses and
clarify the criteria for
 when a loan is deemed uncollectible. Refer to ASC 326-20-50-17.
Note 17. Segment Information, page F-66

11. We note your disclosure on page F-64 that for each of the two reportable
segments,
 compensation and employee benefits are significant segment expenses. We
note from
 page F-66 that your line item of Other expense for Financial Quest
represented
 approximately 31% of total segment noninterest expense for the year
ended December
 31, 2024. Please revise your disclosure to provide a qualitative
description of the
 composition of Other segment item. Refer to ASC 280-10-50-26B.
Exhibits

12. Please include the participation interests in the Exhibit 5 legal
opinion.

 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 Jee Yeon Ahn at 202-551-3673 or Amit Pande at
202-551-3423 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Eric Envall at 202-551-3234 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Benjamin M. Azoff, Esq.
</TEXT>
</DOCUMENT>