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SEC Company Response from URSB Bancorp, (URSB) — Dec 16, 2025

URSB Bancorp, Inc.
Date: Dec. 16, 2025 · CIK: 0002084261 · Accession: 0001104659-25-121580

Financial Reporting Regulatory Compliance Risk Disclosure

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File numbers found in text: 333-290213

Referenced dates: November 25, 2025

Date
December 16, 2025
Author
/s/ Victor L. Cangelosi
Form
CORRESP
Company
URSB Bancorp, Inc.

Letter

LUSE GORMAN, PC

Attorneys at Law

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

December 16, 2025

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Re: URSB Bancorp, Inc.

Registration Statement on Form S-1

Filed September 12, 2025

File No. 333-290213

To Whom It May Concern:

On behalf of URSB 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 comment transmitted by the Staff's comment letter dated November 25, 2025, is reproduced below, followed by the Company's response. The Prospectus included in the Amended Registration Statement has been updated with financial statements and related financial data as of September 30, 2025.

Form S-1 filed September 12, 2025

Supervision and Regulation

Brokered Deposits, page 87

1. We note your disclosures regarding reciprocal deposits. We also note your risk factor disclosure on page 19 about brokered certificates of deposit representing 22.0% of your total deposits at June 30, 2025. Please revise your disclosures, here or elsewhere, to clarify and quantify the extent to which you use reciprocal deposits and whether you classify any as brokered deposits as of each of the period ends presented.

Additional disclosure has been added to pages 81 and 87 of the Prospectus in response to this comment.

Luse Gorman, PC

United States Securities and Exchange Commission

Division of Corporation Finance

December 16, 2025

Page 2

If you have any questions, please contact the undersigned.

Very truly yours,
/s/ Victor L. Cangelosi

Show Raw Text
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 e-mail

 (202) 274-2028
 vcangelosi@luselaw.com

 December 16, 2025

 Via EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

 Re:	URSB Bancorp,
Inc.

 Registration Statement
on Form S-1

 Filed September
12, 2025

 File No. 333-290213

 To Whom It May Concern:

 On behalf of URSB 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 comment transmitted by the Staff's comment letter dated November
25, 2025, is reproduced below, followed by the Company's response. The Prospectus included in the Amended Registration Statement
has been updated with financial statements and related financial data as of September 30, 2025.

 Form S-1 filed September 12, 2025

 Supervision and Regulation

 Brokered Deposits, page 87

 1. We note your disclosures
regarding reciprocal deposits. We also note your risk factor disclosure on page 19 about brokered certificates of deposit representing
22.0% of your total deposits at June 30, 2025. Please revise your disclosures, here or elsewhere, to clarify and quantify the extent to
which you use reciprocal deposits and whether you classify any as brokered deposits as of each of the period ends presented.

 Additional disclosure has been added to pages 81
and 87 of the Prospectus in response to this comment.

 Luse Gorman, PC

 United States Securities and Exchange Commission

 Division of Corporation Finance

 December 16, 2025

 Page 2

 If you have any questions, please contact the undersigned.

 Very truly yours,

 /s/ Victor L. Cangelosi

 Victor L. Cangelosi

 Enclosure

 cc:
 Cara Lubit, SEC

 Amit Pande, SEC

 Aisha Adegbuyi, SEC

 Eric Envall, SEC

 Kenneth R. Totten, URSB Bancorp, Inc.

 David Van Steyn, URSB Bancorp, Inc.

 Lawrence M.F. Spaccasi, Esq.

 Kent M. Krudys, Esq.

 Zachary A. Davis, Esq.