SecProbe.io

CORRESP
 1
 filename1.htm

 CORRESP

 May 9, 2025
 Via Edgar U.S. Securities and Exchange Commission
 100 F Street, N.E. Washington, D.C. 20549

 Re:
 Avidia Bancorp, Inc.
   Registration Statement on Form S-1 (Commission File No. 333-285815)   Request for Acceleration of Effective Date
 To Whom It May Concern: Avidia
Bancorp, Inc. hereby requests that the effective date of the above referenced Registration Statement on Form S-1, as amended, be accelerated to May 13, 2025, at 11:00 a.m., Eastern time, or as soon
thereafter as is practicable. Please contact Victor L. Cangelosi, of Luse Gorman, PC ((202)
 274-2028), if you have any questions concerning this matter.

 Very truly yours,

 Robert D. Cozzone

 President and Chief Executive Officer

CORRESP
 1
 filename1.htm

 CORRESP

 May 9, 2025 Via
Edgar U.S. Securities and Exchange Commission 100 F
Street, N.E. Washington, D.C. 20549

 Re:
 Avidia Bancorp, Inc.
 Registration Statement on Form S-1 (Registration Number
 333-285815) Request for Acceleration of Effectiveness
 To Whom It May Concern: In accordance with Rule
461 of Regulation C promulgated under the Securities Act of 1933, we hereby join Avidia Bancorp, Inc. in requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 11:00 a.m.,
Eastern time, on May 13, 2025, or as soon thereafter as may be practicable.

 KEEFE, BRUYETTE & WOODS, INC.

 By:

 /s/ Patricia A. McJoynt

 Patricia A. McJoynt

 Managing Director

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.

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

Robert D. Cozzone
President and CEO
Avidia Bancorp, Inc.
42 Main Street
Hudson, MA 01749

 Re: Avidia Bancorp, Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed April 25, 2025
 File No. 333-285815
Dear Robert D. Cozzone:

 We have reviewed your amended registration statement and have the
following
comment.

 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. Unless
we note
otherwise, any references to prior comments are to comments in our April 8,
2025 letter.

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.
 May 2, 2025
Page 2

 Please contact Victor Cecco at 202-551-2064 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Christian Windsor at
202-551-3419 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Victor L. Cangelosi, Esq.
</TEXT>
</DOCUMENT>

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
 April 25, 2025
 Via EDGAR United States Securities and Exchange
Commission Division of Corporation Finance 100 F Street, NE
 Washington, DC 20549

 Re:

 Avidia Bancorp, Inc.

 Registration Statement on Form S-1

 Filed March 14, 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. 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 comments, transmitted
by letter dated April 8, 2025, are reproduced below, followed by the Company’s responses. The Amended Registration Statement includes a “Recent Developments” section containing unaudited consolidated financial information as of
and for period ended March 31, 2025, beginning on page 35 of the Prospectus. Registration Statement on Form
 S-1 Business Strategy, page 2
 1. We note your disclosure that you are in the process of developing and implementing a digital deposit account opening system and are currently
developing a comprehensive cloud-based resource known as a “data lake.” Please further describe the “data lake” and its role in your business. Please also describe the status of these development efforts.
 The disclosure on pages 2 and 68 of the Prospectus has been revised.

 L USE G ORMAN , PC
 United States Securities and Exchange Commission Division of
Corporation Finance April 25, 2025 Page
 2
 The geographic concentration of
our loan portfolio and lending activities makes us vulnerable to a downturn in the local economy, page 18 2. Please revise this risk
factor to discuss, as appropriate, the factors that may impact your primary market area. For instance, discuss factors that impact your primary market area’s commercial real estate market.
 The disclosure on page 18 of the Prospectus has been revised.
 Risks Related to Payments Processing Activities, page 19
 3. We note your disclosure on page 81 that there are concentrations in deposits related to your card acquiring business. Revise the appropriate risk
factor to discuss the potential risks related to concentration of deposits by your merchant and ISO clients. The disclosure on pages
19 and 20 of the Prospectus has been revised. The contribution to the charitable foundation will dilute your ownership, page 32
 4. Please revise the narrative disclosure in this risk factor to quantify the potential dilution of an investor’s ownership interest in Avidia at
the midpoint of the offering as a result of the contribution to the charitable foundation. Additional disclosure has been added to
page 32 of the Prospectus. Commercial and Industrial Loans, page 70
 5. We note that loans to condominium associations are among your largest grouping of loans. We also note that your largest concentration of these
loans that are outside of your home market area are in Florida, including your largest single loan. Please discuss the extent to which you conduct ongoing monitoring of your condominium loans. For example, do you monitor the need for assessments by
Florida based condominiums for salt water corrosion and concrete damage and the ability of those associations to successfully collect the assessments owed by their members? Consider also revising your risk factors discussion of the risks posed by
your lending business in the Risk Factors section based on your response. The disclosure on page 76 of the Prospectus has been
revised. Additionally, a new risk factor devoted to condominium association lending has been added to page 17 of the Prospectus.

 L USE G ORMAN , PC
 United States Securities and Exchange Commission Division of
Corporation Finance April 25, 2025 Page
 3
 Subsidiary Activities, page 84
 6. We note the discussion of your subsidiary activities. Please expand upon the description of your subsidiaries’ businesses. If
material to your business, please describe how such subsidiaries generate revenue or advise. In this regard, we note your disclosure on page F-5 that non-interest income
includes investment commissions. The disclosure on page 90 of the Prospectus has been revised.
 The investment commissions disclosed in the income statement on page F-5 of the Prospectus are
unrelated to the two subsidiaries that hold investment securities. Rather, these commissions relate to investment management services offered by Avidia Bank. Additional disclosure has been added, also on page 90 of the Prospectus, to describe the
investment management services. Business Background of Our Directors, page 98
 7. We note that for a number of your Directors, the business positions held during the last five years is unclear from the disclosure. For instance,
it is unclear when Mr. Saul began work for NVIDIA. Refer to Item 401(e)(1) of Regulation S-K.
 Additional disclosure has been added to pages 105 and 106 of the Prospectus.
 *  *  *
 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.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 8, 2025

Robert D. Cozzone
President and CEO
Avidia Bancorp, Inc.
42 Main Street
Hudson, MA 01749

 Re: Avidia Bancorp, Inc.
 Registration Statement on Form S-1
 Filed March 14, 2025
 File No. 333-285815
Dear Robert D. Cozzone:

 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
Business Strategy, page 2

1. We note your disclosure that you are in the process of developing and
implementing a
 digital deposit account opening system and are currently developing a
comprehensive
 cloud-based resource known as a "data lake." Please further describe the
"data lake"
 and its role in your business. Please also describe the status of these
development
 efforts.
The geographic concentration of our loan portfolio and lending activities makes
us vulnerable
to a downturn in the local economy, page 18

2. Please revise this risk factor to discuss, as appropriate, the factors
that may impact
 your primary market area. For instance, discuss factors that impact your
primary
 market area's commercial real estate market.
 April 8, 2025
Page 2
Risks Related to Payments Processing Activities, page 19

3. We note your disclosure on page 81 that there are concentrations in
deposits related to
 your card acquiring business. Revise the appropriate risk factor to
discuss the
 potential risks related to concentration of deposits by your merchant
and ISO clients.
The contribution to the charitable foundation will dilute your ownership, page
32

4. Please revise the narrative disclosure in this risk factor to quantify
the
 potential dilution of an investor's ownership interest in Avidia at the
midpoint of the
 offering as a result of the contribution to the charitable foundation.
Commercial and Industrial Loans, page 70

5. We note that loans to condominium associations are among your largest
grouping of
 loans. We also note that your largest concentration of these loans that
are outside of
 your home market area are in Florida, including your largest single
loan. Please
 discuss the extent to which you conduct ongoing monitoring of your
condominium
 loans. For example, do you monitor the need for assessments by Florida
based
 condominiums for salt water corrosion and concrete damage and the
ability of those
 associations to successfully collect the assessments owed by their
members? Consider
 also revising your risk factors discussion of the risks posed by your
lending business
 in the Risk Factors section based on your response.
Subsidiary Activities, page 84

6. We note the discussion of your subsidiary activities. Please expand upon
the
 description of your subsidiaries' businesses. If material to your
business, please
 describe how such subsidiaries generate revenue or advise. In this
regard, we note
 your disclosure on page F-5 that non-interest income includes investment
 commissions.
Business Background of Our Directors, page 98

7. We note that for a number of your Directors, the business positions held
during the
 last five years is unclear from the disclosure. For instance, it is
unclear when Mr. Saul
 began work for NVIDIA. Refer to Item 401(e)(1) of Regulation S-K.
 April 8, 2025
Page 3

 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 Victor Cecco at 202-551-2064 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Christian Windsor at
202-551-3419 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Victor L. Cangelosi, Esq.
</TEXT>
</DOCUMENT>