SecProbe.io

CORRESP
 1
 filename1.htm

 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 EMAIL

 (202) 274-2010
 bazoff@luselaw.com

 July 25, 2025

 Via EDGAR

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

 Re: Seneca Bancorp, Inc.

 Registration
Statement on Form S-1

 Filed
June 13, 2025

 File
No. 333-288044

 On behalf of Seneca
Bancorp, Inc. (the "Company"), filed herewith is its Pre-Effective Amendment No. 1 to the 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 July 9, 2025, are reproduced below, followed by the Company's responses.
The Amended Registration Statement includes a "Recent Developments" section containing unaudited financial information as
of and for the three- and six-month periods ended June 30, 2025 and 2024.

 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.

 The cover page has been
revised as requested in response to this comment.

 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.

 The cover pages of
the prospectus and prospectus supplement have been revised as requested in response to this comment. Additional disclosure has also been
added to pages 11 and 49 of the prospectus in response to this comment.

 Luse Gorman,
PC

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 July 25, 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.

 Additional disclosure
has been added to pages 2, 4, 22, 60, 77, 78 and 96 of the prospectus in response to this comment.

 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.

 Additional disclosure
has been added to pages 71-72 of the prospectus in response to this comment.

 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.

 Additional disclosure
has been added to pages 71-72 of the prospectus in response to this comment.

 Luse Gorman,
PC

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 July 25, 2025

 Page 3

 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.

 Additional disclosure
has been added to page 110 of the prospectus in response to this comment.

 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.

 Additional disclosure
has been added to page 116 of the prospectus in response to this comment.

 Table of Contents, page F-1

 8. Please revise your filing to provide
 relevant subsequent event disclosures required by ASC 855-10-50.

 Additional disclosure
has been added to page F-67 of the prospectus in response to this comment.

 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.

 Additional disclosure
has been added to page F-1 of the prospectus in response to this comment.

 Luse Gorman,
PC

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 July 25, 2025

 Page 4

 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.

 Additional disclosure
has been added to page F-14 of the prospectus in response to this comment.

 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.

 Additional disclosure
has been added to page F-64 of the prospectus in response to this comment.

 Exhibits

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

 Exhibit 5 has been revised
as requested in response to this comment.

 * * *

 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: Joseph Vitale, President and CEO,
Seneca Bancorp, Inc.

 Madeleine
Joy Mateo, SEC

 Eric
Envall, SEC

 Jee
Yeon Ahn, SEC

 Amit
Pande, SEC