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 BANK
FIRST CORPORATION

 402 NORTH 8 TH STREET

 MANITOWOC, WISCONSIN 54220

 September 26, 2025

 Via EDGAR and e-mail

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

 Attention: Robert Arzonetti

 Re: Bank First Corporation (the " Company ")
 Registration Statement on Form S-4

 Filed September 12, 2025 (amended
on September 26, 2025)

 File No. 333-290230

 Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended (the " Securities Act "), the Company hereby requests that the Securities
and Exchange Commission (the " Commission ") accelerate the effective date of the Registration Statement and declare
the Registration Statement effective under the Securities Act at 5:00 p.m., Eastern Time, on Tuesday, September 30, 2025, or as soon
thereafter as practicable. Please contact Olivia Weber at (404) 881-7298 of Alston & Bird LLP with any questions you may have
concerning this request and to confirm when this request for acceleration has been granted.

 Sincerely,

 Bank First Corporation

 By:
 /s/ Kevin LeMahieu

 Kevin LeMahieu

 Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 23, 2025

Kelly Dvorak
Chief Legal Officer
Bank First Corporation
402 North 8th Street
Manitowoc, WI 54220

 Re: Bank First Corporation
 Registration Statement on Form S-4
 Filed September 12, 2025
 File No. 333-290230
Dear Kelly Dvorak:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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.

 Please contact Robert Arzonetti at 202-551-8819 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Mark Kanaly
</TEXT>
</DOCUMENT>

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BANK
FIRST CORPORATION

November 10, 2022

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

 Re: Bank First Corporation (the “Company”) Registration Statement on Form S-4 (File No.
333-267621), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests the Securities and Exchange
Commission (the “Commission”) to accelerate the effective date of the above-referenced Registration Statement and declare
the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on Monday, November 14, 2022, or
as soon thereafter as practicable. The Company also requests the Commission to specifically confirm such effective date and time to the
Company in writing.

    Sincerely,

    Bank First Corporation

    By:
    /s/ Kevin LeMahieu

    Kevin LeMahieu

    Chief Financial Officer

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One Atlantic Center

1201 West Peachtree Street

Atlanta, GA 30309-3424

404-881-7000 | Fax: 404-881-7777

    David S. Park
    Direct Dial:  404-881-7411
    Email:  david.park@alston.com

October 26, 2022

    Mr. David Gessert

    Staff Attorney

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549-7561

    Re:

    Bank First Corporation

    Registration Statement on Form S-4

    Filed September 26, 2022

    File no. 333-267621

Dear Mr. Gessert:

On behalf of Bank First Corporation (the “Company”),
this letter sets forth the Company’s responses to the comments of the staff (the “Staff”) of the Division of Corporation
Finance of the Securities and Exchange Commission set forth in its letter dated October 11, 2022 (the “Comment Letter”), regarding
the above-referenced registration statement on Form S-4 (the “Registration Statement”). The Company has also revised the Registration
Statement in response to the Staff’s comments and is submitting concurrently with this letter Amendment No. 1 to the Registration
Statement (“Amendment”), which reflects these revisions and updates and clarifies certain other information.

For the convenience of the Staff, each comment
from the Comment Letter is restated in italics prior to the response to such comment. Page references in the text of this letter correspond
to pages and captions in the Amendment. We are also sending, under separate cover, a marked copy of the Amendment showing the changes
from the Registration Statement filed on September 26, 2022.

General

 1. It appears that you have not included all of the disclosure concerning Hometown Bancorp, Ltd. called
for under Item 17 of Form S-4. Please provide us with an analysis as to why you believe this information is not required or amend your
registration statement to include this information.

Alston & Bird LLP
www.alston.com

Atlanta | Beijing | Brussels | Charlotte | Dallas | Los Angeles | New York | Research Triangle | San Francisco | Silicon Valley | Washington, D.C.

October 26, 2022

Page 2

Response: The Company respectfully
submits that the financial information of Hometown Bancorp, Ltd. (“Hometown”) (including pro forma and comparative per
share information) does not need to be included under Item 17 of Form S-4 because (1) Hometown is a non-reporting company, (2) the
Company’s shareholders are not voting on this transaction, and (3) Hometown is significant to the Company at or below the 20% level under
Section 2025.3 of the Financial Reporting Manual (“FRM”).

In determining the significance of an acquisition,
Instruction 4 under Item 17(b)(7) provides that the significance of an acquisition should be determined by applying the tests prescribed
in S-X 1-02(w), and Section 2025 in the FRM provide guidance with respect to S-X 1-02(w). Generally, a registrant measures significance
of an acquisition under S-X 1-02(w) by using its pre-acquisition consolidated financial statements as of the end of the most recently
completed audited fiscal year required to be filed with the SEC. However, Section 2025.3 of the FRM provides that if an acquisition is
made after reporting a previous significant acquisition on a Form 8-K, then the registrant may evaluate the significance of the new acquisition
using the registrant’s pro forma financial information for the latest audited annual period rather than historical pre-acquisition
financial statements.

Per the above, the Company reported its
significant acquisition of Denmark Bancshares, Inc. (“Denmark”) prior to filing the Registration Statement on its Form
8-K and Form 8-K/A on August 15, 2022 and September 9, 2022, respectively. Based on the pro forma financial information as reported
by the Company, the results of the three significance tests are as follows:

 · Hometown’s net income before taxes as of
December 31, 2021 is 17.96% of the Company’s pro forma net income before taxes as of December 31, 2021;

 · Hometown’s total assets as of December
31, 2021 is 17.92% of the Company’s pro forma total assets as of December 31, 2021; and

 · The aggregate purchase price for Hometown is
3.37% of the Company’s pro forma total assets as of December 31, 2021.

    Dollars in thousands
    Company
    Hometown
    Significance

    Income Test
    $65,563
    $11,774
    17.96%

    Asset Test
    $3,680,919
    $659,507
    17.92%

    Investment Test
    $3,680,919
    $124,000
    3.37%

Therefore, per the analysis above, Hometown’s
significance is below the 20% threshold in each of the significance tests and thus Hometown’s financial information is not required
to be included under Item 17 of Form S-4. In addition, the Company has omitted other related financial information under Item 17 of Form
S-4 by relying on the Division of Corporation Finance’s Manual of Publicly Available Telephone Interpretations, Third Supplement
July 2001, Section H. Financial Statements, Question 2, which provides that if the target is a non-reporting company, the acquiror’s
shareholders are not voting on the transaction, and the target’s significance to the acquiror is below the 20% threshold, the staff
will not object to the omission of pro forma and comparative per share information as well as financial and related information of the
target stipulated under Regulation S-K Items 301, 302, 303, 304(b) and 305.

Summary

Board Composition and Management of Bank First
after the Merger, page 13

 2. We note your disclosure that Bank First will appoint Timothy J. McFarlane, Chief Executive Officer
and Chairman of Hometown Bancorp, as director of both Bank First and Bank First, N.A. at the effective time of the merger. Please file
the consent of Mr. McFarlane required by Rule 438 of the
Securities Act, or tell us why you are not required to do so.

October 26, 2022

Page 3

Response: In response to the Staff’s
comments, the Company has filed the consent of Mr. McFarlane required by Rule 438 of the Securities Act in the Amendment.

The Merger

Background of the Merger, page 34

 3. Please expand your disclosure to describe how the merger consideration was determined and how the board
of Hometown took this factor into account in recommending the transaction.

Response: In response to the Staff’s
comments, the Company has expanded the disclosure in the Amendment to describe how the merger consideration was determined and how the
board of Hometown took this factor into account in recommending the transaction.

 4. We note your disclosure in the penultimate paragraph of this section that Piper Sandler & Co. provided
a fairness opinion to the Bank First board. Please file the opinion and Piper’s consent as exhibits to your registration or advise.
Refer to Rule 436 of the Securities Act.

Response: In response to the Staff’s
comments, the Company has removed the disclosure regarding the reference to Piper Sandler & Co.’s fairness opinion from the
Amendment. This language was inadvertently included from a previous registration statement on Form S-4 where Bank First shareholders were
asked to vote on the merger, whereas Bank First shareholders are not being asked to vote on the merger with Hometown.

October 26, 2022

Page 4

We thank the Staff for its courtesies and consideration of the Company’s
response. If the Staff needs any additional information or has any questions regarding the foregoing response, please do not hesitate
to contact the undersigned at (404) 881-7411 or david.park@alston.com.

    Sincerely,

    /s/ David Park

    David Park

cc: Michael Molepske, Chief Executive Officer and President, Bank First
Corporation

Kelly Dvorak, General Counsel, Bank First Corporation

United States securities and exchange commission logo
October 11, 2022
Kelly Dvorak
General Counsel
Bank First Corporation
402 North 8th Street
Manitowoc, WI 54220
Re:Bank First Corporation
Registration Statement on Form S-4
Filed September 26, 2022
File No. 333-267621
Dear Kelly Dvorak:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form S-4 filed September 26, 2022
General
1.It appears that you have not included all of the disclosure concerning Hometown Bancorp,
Ltd. called for under Item 17 of Form S-4.  Please provide us with an analysis as to why
you believe this information is not required or amend your registration statement to
include this information.
Summary
Board Composition and Management of Bank First after the Merger, page 13
2.We note your disclosure that Bank First will appoint Timothy J. McFarlane, Chief
Executive Officer and Chairman of Hometown Bancorp, as a director of both Bank First
and Bank First, N.A. at the effective time of the merger.  Please file the consent of Mr.

 FirstName LastNameKelly Dvorak
 Comapany NameBank First Corporation
 October 11, 2022 Page 2
 FirstName LastName
Kelly Dvorak
Bank First Corporation
October 11, 2022
Page 2
McFarlane required by Rule 438 of the Securities Act, or tell us why you are not required
to do so.
The Merger
Background of the Merger, page 34
3.Please expand your disclosure to describe how the merger consideration was determined
and how the board of Hometown took this factor into account in recommending the
transaction.
4.We note your disclosure in the penultimate paragraph of this section that Piper Sandler
& Co. provided a fairness opinion to the Bank First board.  Please file the opinion and
Piper's consent as exhibits to your registration statement, or advise.  Refer to Rule 436 of
the Securities Act.
            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.
            You may contact David Gessert at 202-551-2326 or Sandra Hunter Berkheimer at 202-
551-3758 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Mark C. Kanaly

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BANK
FIRST CORPORATION

April 22, 2022

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

 Re: Bank First Corporation (the “Company”) Registration Statement on Form S-4 (File No.
333-263865), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests the Securities and Exchange
Commission (the “Commission”) to accelerate the effective date of the above-referenced Registration Statement and declare
the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on Tuesday, April 26, 2022, or
as soon thereafter as practicable. The Company also requests the Commission to specifically confirm such effective date and time to the
Company in writing.

    Sincerely,

    Bank First Corporation

    By:
    /s/ Kevin LeMahieu

    Kevin LeMahieu

    Chief Financial Officer

United States securities and exchange commission logo
April 6, 2022
Kelly Dvorak
General Counsel
Bank First Corporation
402 North 8th Street
Manitowoc, Wisconsin 54220
Re:Bank First Corporation
Registration Statement on Form S-4
Filed March 25, 2022
File No. 333-263865
Dear Ms. Dvorak:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact John Stickel at 202-551-3324 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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BANK
FIRST CORPORATION

March 4, 2020

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Eric Envall

 Re: Bank First Corporation (the “Company”)

                                                                                Registration Statement on Form S-4 (File No. 333-236067), as amended (the “Registration Statement”) – Acceleration Request

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests
the Securities and Exchange Commission (the “Commission”) to accelerate the effective date of the above-referenced
Registration Statement and declare the Registration Statement effective under the Securities Act at 4:00 p.m., Eastern Time,
on Friday, March 6, 2020, or as soon thereafter as practicable.

Feel
free to telephone Joseph T. Ceithaml of Barack Ferrazzano Kirschbaum & Nagelberg LLP, the Company’s legal counsel, at
(312) 629-5143 with any questions or comments.

    Sincerely,

    Bank First Corporation

    By:
    /s/ Kevin M. LeMahieu

    Kevin M. LeMahieu

    Chief Financial Officer

January 30, 2020
Kelly M. Dvorak
General Counsel
Bank First Corporation
402 N. 8th Street
Manitowoc, Wisconsin 54220
Re:Bank First Corporation
Registration Statement on Form S-4
Filed January 24, 2020
File No. 333-236067
Dear Ms. Dvorak:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Eric Envall at (202) 551-3234 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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BANK
FIRST NATIONAL CORPORATION

May 2, 2019

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

 Re: Bank First National Corporation (the “Company”) Registration Statement on Form S-4

                                                                                (File No. 333-230784), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests the Securities
and Exchange Commission (the “Commission”) to accelerate the effective date of the above-referenced Registration
Statement and declare the Registration Statement, as amended, effective under the Securities Act at 3:00 p.m., Eastern Time, on
Monday, May 6, 2019, or as soon thereafter as practicable. The Company also requests the Commission to specifically confirm such
effective date and time to the Company in writing.

    Sincerely,

    Bank First National Corporation

    By:
    /s/ Kevin M. LeMahieu

    Kevin M. LeMahieu

    Chief Financial Officer

April 15, 2019
Kelly Dvorak
General Counsel
Bank First National Corporation
402 N. 8th Street
Manitowoc, WI 54220
Re:Bank First National Corporation
Registration Statement on Form S-4
Filed April 9, 2019
File No. 333-230784
Dear Ms. Dvorak:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Eric Envall at (202) 551-3234 with any questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services

October 24, 2018
Kelly Dvorak
General Counsel
Bank First National Corporation
402 North 8th Street
Manitowoc, WI 54220
Re:Bank First National Corporation
Form 10-12B
Filed September 24, 2018
File No. 001-38676
Dear Ms. Dvorak:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Financial Services

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Bank First National Corporation

402 North 8th Street

Manitowoc, Wisconsin 54220

October 19, 2018

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE

Washington, D.C. 20549

Attention: David Lin

    Re:

        Bank First National Corporation

        Registration Statement on Form10

        File No. 001-38676

Dear Mr. Lin:

Reference is made to
the Registration Statement on Form 10-12B (as amended to date, the “Registration Statement”) filed by Bank
First National Corporation (the “Company”) with the United States Securities and Exchange Commission. In accordance
with Rule 12d1-2 promulgated under the Securities Exchange Act of 1934, as amended, the Company hereby respectfully requests
that the effective date and time of the Registration Statement be accelerated to October 23, 2018 at 4:10 p.m., Eastern Time, or
as soon thereafter as practicable.

If you should have
any questions or further comments with respect to the Registration Statement, please direct them to David Park of Alston and Bird
LLP at (404) 881-7411. The Company requests that notification of the effectiveness of the Registration Statement be made by a telephone
call to Mr. Park and that such effectiveness also be confirmed in writing.

[Remainder of the page intentionally
left blank]

    Very truly yours,

    Bank First National Corporation

    By:
     /s/
    Kevin LeMahieu

    Name:
    Kevin LeMahieu

    Title:
    Chief Financial Officer

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One Atlantic Center

1201 West Peachtree Street

Atlanta, GA 30309-3424

404-881-7000 | Fax: 404-881-7777

    David Park
    Direct Dial:  404-881-7411
    Email:  david.park@alston.com

September 24, 2018

        Mr. Michael Clampitt

        Senior Staff Attorney Office of Financial Services

        Division of Corporation Finance

        U.S. Securities and Exchange Commission

        100 F Street, N.E.

        Washington, D.C. 20549-7561

    Re:

        Bank First National Corporation

        Draft Registration Statement on Form 10-12B

        Submitted August 15, 2018

        CIK No. 0001746109

Dear Mr. Clampitt,

On behalf of Bank First National Corporation
(the “Company”), and pursuant to the applicable provisions of the Securities and Exchange of 1934, as amended, and
the rules promulgated thereunder, the Company has publicly filed with the Securities and Exchange Commission (the “Commission”),
on the date hereof the above-captioned Registration Statement on Form 10 of the Company (the “Registration Statement”),
originally confidentially submitted on August 15, 2018 (the “Confidential Submission”).

The Company has made certain revisions to
the Confidential Submission in response to the comment letter, dated September 11, 2018, from the staff of the Commission (the
 “Staff”). In addition, the Company has made certain updates to the disclosures contained in the Confidential Submission.
The numbered paragraphs below set forth the Staff’s comments together with the Company’s responses. Page numbers in
the Company’s responses correspond to page numbers in the Registration Statement. Unless otherwise indicated, capitalized
terms used herein have the meanings assigned to them in the Registration Statement.

Draft Registration Statement on Form 10-12B

Cautionary Note Regarding Forward-Looking Statements, page
1

 1. Please remove the reference to the safe harbor under Section 21E of the Securities Exchange Act of 1934 and Section 27A
of the Securities Act of 1933. As you are not a reporting company as of the date of filing, you are not eligible to rely on the
safe harbor for your forward-looking statements.

    Alston & Bird LLP
    www.alston.com

    Atlanta     |
        Beijing     |     Brussels     |
        Charlotte     |    Dallas     |     Los
    Angeles     |     New York     |     Raleigh     |
        San Francisco     |     Silicon Valley     |
        Washington, D.C.

    September 24, 2018

Page 2

Response: The Company
acknowledges the Staff’s comment and have revised this language in the Registration Statement on page 1 to remove the references
to the Securities Act and Exchange Act safe harbors.

Item 1A. Risk Factors

The Company is exposed to risk of environmental liabilities
. . . , page 29

 2. If material, please revise to state, as of a recent date, the amount and type of real estate of which the company has taken
title and is therefore the potential source of environmental liabilities.

Response: The Company respectfully submits that at this
time, the Company does not have title to any real estate that may be the potential source of any material environmental liabilities.

Item 2. Financial Information

Management's Discussion and Analysis of Financial Condition
and Results of Operations

 Critical Accounting Policies - Recent Accounting Developments, page 45

 3. Please revise the disclosure of ASU 2014-09, Revenue from Contracts with Customers (Topic 606) and ASU 2016-09 - Compensation
 – Stock Compensation (Topic 718): Improvements to Employee Share-Based Payment Accounting to reflect the adoption guidance
for that of a non-EGC since you have chosen to opt out of the extended transition period for complying with new or revised accounting
standards.

Response: In light of the Staff’s comments, the
Company has revised its disclosure on page 45 of the Registration Statement to reflect the adoption guidance for that of a non-EGC.

Sources of Funds

Deposits, page 68

 4. Please revise the presentation of average balances of deposits to be consistent with the average amounts and weighted average
rates paid appearing in the Average Balance Sheets appearing on pages 55 and 56.

Response: In light of the Staff’s comments, the
Company has revised the presentation of average balances of deposits on page 69 of the Registration Statement to be consistent
with the average amounts and weighted average rates paid appearing in the Average Balance Sheets appearing on pages 55 and 56.

Return on Average Equity and Assets, page 74

    September 24, 2018

Page 3

 5. Please recompute the ratio of average shareholders’ equity to average assets based on the average shareholders’ equity
and average assets disclosed in the tables on pages 55 and 56.

Response: In light of the Staff’s comments, the
Company has recomputed the ratio of average shareholders’ equity to average assets on page 74 of the Registration Statement
based on the average shareholders’ equity and average assets disclosed in the tables on pages 55 and 56.

Item 9. Market Price of and Dividends on the Registrant’s
Common Equity and Related Stockholder Matters, page 98

 6. Please revise to disclose the information required by Item 201(d) of Regulation S-K or advise.

Response: The Company respectfully submits that at this time, the Company
does not have any equity compensation plan that requires disclosure pursuant to Item 201(d) of Regulation S-K. The Company’s
only equity compensation plan is the Company’s 2011 Equity Plan, which grants restricted stock awards to certain senior officers,
employees and directors of the Company. Pursuant to Question 106.02 of the SEC’s Compliance and Disclosure Interpretations,
the restricted stock granted pursuant to the Company’s 2011 Equity Plan are neither ‘”to be issued upon exercise
of outstanding options, warrants and rights” nor “available for future issuance.”

Dividends, page 98

 7. Please disclose the frequency and amount of dividends you have paid during your two most recent fiscal years and the subsequent
interim period covered by your financial statements. Refer to Item 201(c) of Regulation S-K.

Response: The Company respectfully submits that page
98 of the Registration Statement discloses the frequency and amount of dividends as required by Item 201(c) of Regulation S-K.

Item 13. Financial Statements and Supplementary
Data

Pro Forma Combined Statements of Income

 For the year ended December 31, 2017, page 106

 8. You disclose a pro forma adjustment of $4,682,000 to interest income on loans in 2017 related to a $14.6 million yield premium
recorded on the loans acquired from Waupaca. Please tell us the factors that contributed to your acquiring the loans at a premium.
Please also tell us why the amortization of the loan premium resulted in an increase in interest income in 2017.

Response: The terminology used in the footnote for the
Confidential Submission indicated that the pro forma adjustment referenced was related to a $14.6 million yield “premium”.
In actuality it was a $14.6 million credit and yield “discount” on loans acquired from Waupaca. This discount
accretes $4,682,000 to interest income through the first twelve months after acquisition, leading to the pro forma adjustment.

    September 24, 2018

Page 4

In light of the Staff’s comments, the Company has revised
the footnote on page 107 of the Registration Statement to correctly identify the pro forma adjustment as a discount as opposed
to a premium.

Bank First National Corporation

Notes to Consolidated Financial Statements

Note 1. Summary of Significant Accounting Policies

New Accounting Pronouncements, page 144

 9. Please revise your disclosures to ensure that you reflect the adoption guidance of a non-EGC.

Response: In light of the Staff’s comments, the
Company has revised its disclosure on pages 144 - 147 of the Registration Statement to reflect the adoption guidance for that of
a non-EGC.

Item 14. Changes in and Disagreements with Accountants on
Accounting and Financial Disclosures, page 227

 10. You disclose in the fifth paragraph that you did not consult with CliftonLarsonAllen LLP during the years ended December
31, 2017 and 2016. Please revise to disclose whether you consulted with CliftonLarsonAllen LLP in the subsequent interim period
ended February 27, 2018 pursuant to Item 304 (a) (2) of Regulation S-K.

Response: In light of the Staff’s comments, the
Company has revised the disclosure on page 227 of the Registration Statement to confirm that the Company has not consulted with
CliftonLarsonAllen LLP in the period from December 31, 2017 to February 27, 2018 pursuant to Item 304(a)(2) of Regulation S-K.

We
hope that the foregoing has been responsive to the Staff’s comments. If you have any questions related to this letter, please
contact me at (404) 881-7411.

    Sincerely,

    /s/ David S. Park

    David S. Park

cc: Kelly Dvorak, General Counsel, Bank First National Corporation

September 11, 2018
Kelly Dvorak
General Counsel
Bank First National Corporation
402 North 8th Street
Manitowoc, WI 54220
Re:Bank First National Corporation
Draft Registration Statement on Form 10-12B
Submitted August 15, 2018
CIK No. 0001746109
Dear Ms. Dvorak:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form 10-12B
Cautionary Note Regarding Forward-Looking Statements, page 1
1.Please remove the reference to the safe harbor under Section 21E of the Securities
Exchange Act of 1934 and Section 27A of the Securities Act of 1933. As you are not a
reporting company as of the date of filing, you are not eligible to rely on the safe harbor
for your forward-looking statements.

 FirstName LastNameKelly Dvorak
 Comapany NameBank First National Corporation
 September 11, 2018 Page 2
 FirstName LastNameKelly Dvorak
Bank First National Corporation
September 11, 2018
Page 2
Item 1A. Risk Factors
The Company is exposed to risk of environmental liabilities . . . , page 29
2.If material, please revise to state, as of a recent date, the amount and type of real estate of
which the company has taken title and is therefore the potential source of environmental
liabilities.
Item 2. Financial Information
Management's Discussion and Analysis of Financial Condition and Results of Operations
Critical Accounting Policies - Recent Accounting Developments, page 45
3.Please revise the disclosure of ASU 2014-09, Revenue from Contracts with Customers
(Topic 606) and ASU 2016-09 - Compensation – Stock Compensation (Topic 718):
Improvements to Employee Share-Based Payment Accounting to reflect the adoption
guidance for that of a non-EGC since you have chosen to opt out of the extended
transition period for complying with new or revised accounting standards.
Sources of Funds
Deposits, page 68
4.Please revise the presentation of average balances of deposits to be consistent with the
average amounts and weighted average rates paid appearing in the Average Balance
Sheets appearing on pages 55 and 56.
Return on Average Equity and Assets, page 74
5.Please recompute the ratio of average shareholders’ equity to average assets based on the
average shareholders' equity and average assets disclosed in the tables on pages 55 and 56.
Item 9. Market Price of and Dividends on the Registrant’s Common Equity and Related
Stockholder Matters, page 98
6.Please revise to disclose the information required by Item 201(d) of Regulation S-K or
advise.
Dividends, page 98
7.Please disclose the frequency and amount of dividends you have paid during your two
most recent fiscal years and the subsequent interim period covered by your financial
statements. Refer to Item 201(c) of Regulation S-K.
Item 13. Financial Statements and Supplementary Data
Pro Forma Combined Statements of Income
For the year ended December 31, 2017, page 106
8.You disclose a pro forma adjustment of $4,682,000 to interest income on loans in 2017

 FirstName LastNameKelly Dvorak
 Comapany NameBank First National Corporation
 September 11, 2018 Page 3
 FirstName LastName
Kelly Dvorak
Bank First National Corporation
September 11, 2018
Page 3
related to a $14.6 million yield premium recorded on the loans acquired from Waupaca.
Please tell us the factors that contributed to your acquiring the loans at a premium.  Please
also tell us why the amortization of the loan premium resulted in an increase in interest
income in 2017.
Bank First National Corporation
Notes to Consolidated Financial Statements
Note 1. Summary of Significant Accounting Policies
New Accounting Pronouncements, page 144
9.Please revise your disclosures to ensure that you reflect the adoption guidance of a non-
EGC.
Item 14. Changes in and Disagreements with Accountants on Accounting and Financial
Disclosures, page 227
10.You disclose in the fifth paragraph that you did not consult with CliftonLarsonAllen LLP
during the years ended December 31, 2017 and 2016. Please revise to disclose whether
you consulted with CliftonLarsonAllen LLP in the subsequent interim period ended
February 27, 2018 pursuant to Item 304 (a) (2) of Regulation S-K.
            You may contact Christina Harley, Staff Accountant, at (202) 551-3695 or Gus
Rodriguez, Accounting Branch Chief, at (202) 551-3752 if you have questions regarding
comments on the financial statements and related matters.  Please contact David Lin, Staff
Attorney, at (202) 551-3552 or Michael Clampitt, Senior Staff Attorney, at (202) 551-3434 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services