SecProbe.io

CORRESP
 1
 filename1.htm

 CORRESP

 EQUITY BANCSHARES, INC.
 7701 East Kellogg Drive, Suite 300
 Wichita, Kansas 67207
 August 19, 2025 VIA EDGAR
 U.S. Securities and Exchange Commission Division
of Corporation Finance 100 F Street, N.E. Washington, D.C.
20549 Attn: Aisha Adegbuyi

    

 Re:

 Equity Bancshares, Inc.

 Registration Statement on Form S-4

 Filed August 11, 2025

 File No. 333-289492
 Ladies and Gentlemen: Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Equity Bancshares, Inc. hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be
accelerated to 12:00 p.m., Eastern Time, on August 21, 2025, or as soon as practicable thereafter. Please contact Michael G. Keeley of Norton Rose
Fulbright US LLP at (214) 855-3906 with any questions you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for acceleration has been granted.

 Respectfully,

 EQUITY BANCSHARES, INC.

 By:

 /s/ Chris M. Navratil

 Name:

 Chris M. Navratil

 Title:

 Executive Vice President and

 Chief Financial Officer

 cc:
 Michael G. Keeley, Norton Rose Fulbright US LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 18, 2025

Brad S. Elliott
Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 300
Wichita, KS 67207

 Re: Equity Bancshares, Inc.
 Registration Statement on Form S-4
 Filed August 11, 2025
 File No. 333-289492
Dear Brad S. Elliott:

 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 Aisha Adegbuyi at 202-551-8754 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Mike Keeley, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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 filename1.htm

 CORRESP

 EQUITY BANCSHARES, INC.
 7701 East Kellogg Drive, Suite 300
 Wichita, Kansas 67207
 August 11, 2025 U.S. Securities and
Exchange Commission Division of Corporation Finance 100 F
Street, N.E. Washington, D.C. 20549

 Re:

 Equity Bancshares, Inc. Registration
Statement on Form S-4 Filed August 11, 2025
 File No. 333-289492

 Ladies and Gentlemen: In
connection with the above referenced Registration Statement (the “ Registration Statement ”) relating to the registration by Equity Bancshares, Inc. (the “ Company ”) under the Securities Act of 1933, as
amended (the “ Securities Act ”), of $75,000,000 aggregate principal amount of the Company’s 7.125% Fixed-to-Floating Rate Subordinated Notes
due 2035 (the “ Exchange Notes ”) to be offered by the Company in exchange (the “ Exchange Offer ”) for a like principal amount of the Company’s issued and outstanding 7.125% Fixed-to-Floating Rate Subordinated Notes due 2035 (the “ Outstanding Notes ”), the Company hereby confirms and represents as follows:

 1.
 The Company is registering the Exchange Offer in reliance on the position of the staff (the
“ Staff ”) of the U.S. Securities and Exchange Commission enunciated in Exxon Capital Holdings Corporation, SEC No-Action Letter (April 13, 1988), Morgan
Stanley & Co., Inc. , SEC No-Action Letter (June 5, 1991), and Shearman & Sterling, SEC No-Action
Letter (July 2, 1993) (together, the “ No Action Letters ”).

 2.
 The Company has not entered into any arrangement or understanding with any person who will receive the Exchange
Notes in the Exchange Offer to distribute the Exchange Notes following the completion of the Exchange Offer. To the best of the Company’s knowledge and belief, each person participating in the Exchange Offer is acquiring the Exchange Notes in
its ordinary course of business and has no arrangement or understanding with any person to participate in the Exchange Offer with a view to distribute the Exchange Notes to be received in the Exchange Offer. In this regard, the Company will make
each person participating in the Exchange Offer aware (through the prospectus or the letter of transmittal) that, if such person is participating in the Exchange Offer with the intention of participating in any manner in a distribution of the
Exchange Notes, such person (i) cannot rely on the Staff position enunciated in the No Action Letters or interpretative letters to similar effect and (ii) must comply with the registration and prospectus delivery requirements of the
Securities Act in connection with a secondary resale transaction and be identified as an underwriter in the prospectus.

 3.
 The Company acknowledges that such a secondary resale transaction by such person participating in the Exchange
Offer for the purpose of distributing the Exchange Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 or Item 508, as applicable, of Regulation S-K under the Securities Act.

 4.
 The Company will make each person participating in the Exchange Offer aware (through the prospectus or the
letter of transmittal) that any broker-dealer that will receive Exchange Notes for its own account in exchange for Outstanding Notes that were acquired as a result of market-making activities or other trading activities may be a statutory
underwriter and must deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of such Exchange Notes.

 5.
 The Company will include in the letter of transmittal to be executed or deemed to be executed by each person
participating in the Exchange Offer (i) an acknowledgement that such participant does not intend to engage in a distribution of the Exchange Notes and (ii) an acknowledgement for each person that is a broker-dealer exchanging Outstanding
Notes acquired for its own account as a result of market-making activities or other trading activities, that such broker-dealer will satisfy any prospectus delivery requirements in connection with any resale of such Exchange Notes, and a statement
to the effect that by so acknowledging and by delivering a prospectus, such broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.
 If any additional supplemental information is required by the Staff, please contact Mike Keeley of Norton Rose Fulbright US LLP, our legal counsel, at (214) 855-3906.

 Respectfully,

 EQUITY BANCSHARES, INC.

 By:

 /s/ Chris M. Navratil

 Name:

 Chris M. Navratil

 Title:

 Executive Vice President and

 Chief Financial Officer

 cc:
 Norton Rose Fulbright US LLP

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CORRESP

 EQUITY BANCSHARES, INC.

7701 East Kellogg Drive, Suite 300

Wichita, Kansas 67207

August 25, 2022

 VIA EDGAR

 Tonya K. Aldave

 Office of Finance

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Equity Bancshares, Inc.

Registration Statement on Form S-3

File No. 333-267025

Request for Acceleration of Effectiveness

Dear Ms. Aldave:

 Reference is made to the
Registration Statement on Form S-3 (File No. 333-267025) (the “Registration Statement”) filed by Equity Bancshares, Inc. (the “Company”) with
the Securities and Exchange Commission on August 23, 2022.

 The Company hereby requests that the Registration Statement be made
effective at 12:00 p.m., Eastern Time, on August 29, 2022, or as soon as practicable thereafter, in accordance with Rule 461 promulgated under the Securities Act of 1933, as amended.

Please contact Michael G. Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 or mike.keeley@nortonrosefulbright.com with any
questions you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for acceleration has been granted.

 Respectfully,

EQUITY BANCSHARES, INC.

By:

/s/ Eric R. Newell

Name:

Eric R. Newell

Title:

Executive Vice President and Chief Financial Officer

cc:
 Michael G. Keeley, Norton Rose Fulbright US LLP

United States securities and exchange commission logo
August 24, 2022
Brad S. Elliott
Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 300
Wichita, KS 67207
Re:Equity Bancshares, Inc.
Registration Statement on Form S-3
Filed on August 23, 2022
File No. 333-267025
Dear Mr. Elliott:
            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 Tonya K. Aldave at (202) 551-3601 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Mike Keeley, Esq.

CORRESP
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CORRESP

 EQUITY BANCSHARES, INC.

7701 East Kellogg Drive, Suite 300

Wichita, Kansas 67207

July 19, 2021

 VIA EDGAR

U.S. Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
 Equity Bancshares, Inc.

Registration Statement on Form S-4

Filed June 11, 2021

File No. 333-257024

Ladies and Gentlemen:

 Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, Equity Bancshares, Inc. hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be
accelerated to 12:00 p.m., Eastern Time, on July 21, 2021, or as soon thereafter as is practicable.

 Please contact Michael G.
Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 with any questions you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for
acceleration has been granted.

Respectfully,

EQUITY BANCSHARES, INC.

By:

 /s/ Eric R. Newell

Name:

Eric R. Newell

Title:

Executive Vice President and Chief Financial Officer

cc:
 Michael G. Keeley, Norton Rose Fulbright US LLP

United States securities and exchange commission logo
June 16, 2021
Brad Elliott
Chairman and Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 300
Wichita, KS 67207
Re:Equity Bancshares, Inc.
Registration Statement on Form S-4
Filed June 11, 2021
File No. 333-257024
Dear Mr. Elliott:
            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 David Lin, Staff Attorney, at (202) 551-3552 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
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CORRESP

 EQUITY BANCSHARES, INC.

7701 East Kellogg Drive, Suite 300

Wichita, Kansas 67207

August 25, 2020

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

 Attn: Julia Griffith

Re:
 Equity Bancshares, Inc.

Registration Statement on Form S-4

Filed August 18, 2020

File No. 333-248102

Ladies and Gentlemen:

 Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, Equity Bancshares, Inc. hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be
accelerated to 12:00 p.m., Eastern Time, on August 27, 2020, or as soon as practicable thereafter.

 Please contact Michael G.
Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 with any questions you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for
acceleration has been granted.

Respectfully,

EQUITY BANCSHARES, INC.

By:

 /s/ Eric R. Newell

Name:

Eric R. Newell

Title:

Executive Vice President and

Chief Financial Officer

cc:
 Michael G. Keeley, Norton Rose Fulbright US LLP

United States securities and exchange commission logo
August 24, 2020
Brad S. Elliott
Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 300
Wichita, KS, 67207
Re:Equity Bancshares, Inc.
Registration Statement on Form S-4
Filed August 18, 2020
File No. 333-248102
Dear Mr. Elliott:
            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 Julia Griffith at 202-551-3267 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
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CORRESP

 EQUITY BANCSHARES, INC.

7701 East Kellogg Drive, Suite 300

Wichita, Kansas 67207

August 18, 2020

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

Re:
 Equity Bancshares, Inc.

Registration Statement on Form S-4

Filed August 18, 2020

File No. 333-248102

Ladies and Gentlemen:

 In connection with the above referenced
Registration Statement (the “Registration Statement”) relating to the registration by Equity Bancshares, Inc. (the “Company”) under the Securities Act of 1933, as amended (the “Securities
Act”), of $75,000,000 aggregate principal amount of the Company’s 7.00% Fixed-to-Floating Rate Subordinated Notes due 2030 (the “Exchange Notes”) to be offered by the Company in exchange (the
“Exchange Offer”) for a like principal amount of the Company’s issued and outstanding 7.00% Fixed-to-Floating Rate Subordinated Notes due 2030 (the “Outstanding Notes”), the Company hereby
confirms and represents as follows:

1.
 The Company is registering the Exchange Offer in reliance on the position of the staff (the
“Staff”) of the U.S. Securities and Exchange Commission enunciated in Exxon Capital Holdings Corporation, SEC No-Action Letter (April 13, 1988), Morgan
Stanley & Co., Inc., SEC No-Action Letter (June 5, 1991), and Shearman & Sterling, SEC No-Action
Letter (July 2, 1993) (together, the “No Action Letters”).

2.
 The Company has not entered into any arrangement or understanding with any person who will receive the Exchange
Notes in the Exchange Offer to distribute the Exchange Notes following the completion of the Exchange Offer. To the best of the Company’s knowledge and belief, each person participating in the Exchange Offer is acquiring the Exchange Notes in
its ordinary course of business and has no arrangement or understanding with any person to participate in the Exchange Offer with a view to distribute the Exchange Notes to be received in the Exchange Offer. In this regard, the Company will make
each person participating in the Exchange Offer aware (through the prospectus or the letter of transmittal) that, if such person is participating in the Exchange Offer with the intention of participating in any manner in a distribution of the
Exchange Notes, such person (i) cannot rely on the Staff position enunciated in the No Action Letters or interpretative letters to similar effect and (ii) must comply with the registration and prospectus delivery requirements of the
Securities Act in connection with a secondary resale transaction and be identified as an underwriter in the prospectus.

3.
 The Company acknowledges that such a secondary resale transaction by such person participating in the Exchange
Offer for the purpose of distributing the Exchange Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 or Item 508, as applicable, of Regulation S-K under the Securities Act.

4.
 The Company will make each person participating in the Exchange Offer aware (through the prospectus or the
letter of transmittal) that any broker-dealer that will receive Exchange Notes for its own account in exchange for Outstanding Notes that were acquired as a result of market-making activities or other trading activities may be a statutory
underwriter and must deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of such Exchange Notes.

5.
 The Company will include in the letter of transmittal to be executed or deemed to be executed by each person
participating in the Exchange Offer (i) an acknowledgement that such participant does not intend to engage in a distribution of the Exchange Notes and (ii) an acknowledgement for each person that is a broker-dealer exchanging Outstanding
Notes acquired for its own account as a result of market-making activities or other trading activities, that such broker-dealer will satisfy any prospectus delivery requirements in connection with any resale of such Exchange Notes, and a statement
to the effect that by so acknowledging and by delivering a prospectus, such broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.

If any additional supplemental information is required by the Staff, please contact Mike Keeley of Norton Rose Fulbright US LLP, our legal counsel, at (214) 855-3906.

Respectfully,

EQUITY BANCSHARES, INC.

By:

 /s/ Eric R. Newell

Name:

Eric R. Newell

Title:

Executive Vice President and

Chief Financial Officer

cc:
 Norton Rose Fulbright US LLP

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CORRESP

 VIA EDGAR

June 8, 2018

 Pamela Long

Assistant Director

 Office of Financial Services

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
Equity Bancshares, Inc.

Registration Statement on Form S-3

File No. 333-225419

Request for Acceleration of Effectiveness

 Dear Ms. Long:

Reference is made to the Registration Statement on Form S-3 (File
No. 333-225419) (the “Registration Statement”) filed by Equity Bancshares, Inc. (the “Company”) with the Securities and Exchange Commission (the
“Commission”) on June 4, 2018.

 The Company hereby requests the Registration Statement be made effective at 5:00
p.m. New York City time on June 11, 2018, or as soon as practicable thereafter, in accordance with Rule 461 promulgated under the Securities Act of 1933, as amended.

If the Staff has any questions or comments concerning this letter, or if you require any additional information, please feel free to contact
Michael G. Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 or mike.keeley@nortonrosefulbright.com.

Very truly yours,

EQUITY BANCSHARES, INC.

By:

/s/ Brad S. Elliott

 Name: Brad S. Elliott

 Title: Chairman and
Chief Executive Officer

cc:
Norton Rose Fulbright US LLP

Michael G. Keeley

Equity Bancshares, Inc.

Greg H. Kossover, Executive Vice President and

Chief Financial Officer

June 6, 2018

Brad S. Elliott
Chairman and Chief Executive Officer
Equity Bancshares,  Inc.
7701 East Kellogg Drive, Suite 300
Wichita, Kansas 67207

Re: Equity Bancshares, Inc.
  Registration Statement on Form S-3
Filed  June 4, 2018
  File No.  333-225419

Dear Mr. Elliott :

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,

 /s/ Pamela Long

 Pamela Long
Assistant Director
Office of Financial Services

CORRESP
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CORRESP

 Via EDGAR

February 15, 2018

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-4628

 Attn: Jessica Livingston

Re:
Equity Bancshares, Inc.

 Request for Acceleration of Effectiveness

Registration Statement on Form S-4

File No. 333-222931

Ladies and Gentlemen:

 Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, Equity Bancshares, Inc. hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be accelerated
to 12:00 p.m., Eastern Time, on February 20, 2018, or as soon as practicable thereafter.

 Please contact Michael G. Keeley of
Norton Rose Fulbright US LLP at (214) 855-3906 with any questions you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for acceleration has been
granted.

Respectfully,

Equity Bancshares, Inc.

By:

 /s/ Brad S. Elliott

Name:

Brad S. Elliott

Title:

Chairman and Chief Executive Officer

cc:
Michael G. Keeley, Norton Rose Fulbright US LLP

CORRESP
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CORRESP

 Via EDGAR

February 15, 2018

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-4628

 Attn: Jessica Livingston

Re:
Equity Bancshares, Inc.

Request for Acceleration of Effectiveness

Registration Statement on Form S-4

File No. 333-222934

 Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Equity Bancshares, Inc. hereby respectfully requests that the
effective date of the above referenced Registration Statement on Form S-4 be accelerated to 12:00 p.m., Eastern Time, on February 20, 2018, or as soon as practicable thereafter.

Please contact Michael G. Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 with any questions
you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for acceleration has been granted.

 Respectfully,

 Equity Bancshares,
Inc.

 By:

 /s/ Brad S. Elliott

 Name:

Brad S. Elliott

 Title:

Chairman and Chief Executive Officer

cc:
Michael G. Keeley, Norton Rose Fulbright US LLP

Mail Stop 4720
Febru ary 14, 2018

Brad S. Elliott
Chairman and Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 300
Wichita, KS  67207

Re:  Equity Bancshares, Inc.
Registration Statement on Form S -4
Filed  February 8, 2018
File No. 333-222931

Dear M r. Elliott :

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

Please refer to Rule s 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.

You may contact  Jessica Livingston , Staff Attorney,  at 202-551-3448  with any questions.

Sincerely,

 /s/ Era Anagnosti

Era Anagnosti
Acting Assistant Director
Office of Financial Servi ces

CORRESP
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CORRESP

 Via EDGAR

August 30, 2017

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-4628

 Attn: Christopher Dunham

Re:
Equity Bancshares, Inc.

Registration Statement on Form S-4 (as amended)

File No. 333-219974

 Ladies and Gentlemen:

Equity Bancshares, Inc. hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be accelerated to 12:00 p.m., Eastern Time, on September 1, 2017, or as soon practicable thereafter.

Please contact Michael G. Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 with any questions
you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for acceleration has been granted.

Respectfully,

Equity Bancshares, Inc.

By:

/s/ Brad S. Elliott

Name: Brad S. Elliott

Title: Chairman and Chief Executive Officer

cc:
Gregory H. Kossover, Equity Bancshares, Inc.

 Michael G. Keeley, Norton Rose Fulbright US LLP

CORRESP
1
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CORRESP

 Via EDGAR

August 30, 2017

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-4628

 Attn: Christopher Dunham

Re:
Equity Bancshares, Inc.

Registration Statement on Form S-4 (as amended)

File No. 333-219975

 Ladies and Gentlemen:

Equity Bancshares, Inc. hereby respectfully requests that the effective date of the above referenced Registration Statement on Form S-4 be accelerated to 12:00 p.m., Eastern Time, on September 1, 2017, or as soon practicable thereafter.

Please contact Michael G. Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 with any questions
you may have regarding this request. In addition, please notify Mr. Keeley by telephone when this request for acceleration has been granted.

Respectfully,

Equity Bancshares, Inc.

By:

/s/ Brad S. Elliott

Name:

Brad S. Elliott

Title:

Chairman and Chief Executive Officer

cc:
Gregory H. Kossover, Equity Bancshares, Inc.

Michael G. Keeley, Norton Rose Fulbright US LLP

Mail Stop 4720

August 18, 2017

Brad S. Elliott
Chairman and Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 300
Wichita, KS 67207

Re: Equity Bancshares, Inc.
  Registration Statement on Form S-4
Filed  August 15, 2017
  File No.  333-219975

Dear Mr. Elliott :

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 Christopher Dunham, Staff Attorney, at (202) 551 -3783  with any
questions .

Sincerely,

 /s/ Erin E. Martin

Erin E. Martin
Special Counsel
Office  of Financial Services

cc: Michael G. Keeley, Esq.

CORRESP
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Acceleration Request

 EQUITY BANCSHARES, INC.

February 1, 2017

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F. Street, N.E.

 Washington, D.C.
20549

 Attn: Christian Windsor, Special Counsel

Re:
Equity Bancshares, Inc.

Registration Statement on Form S-4

File No. 333-215330

 Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Equity Bancshares, Inc. hereby respectfully requests acceleration of the
effective date of the above-referenced Registration Statement on Form S-4 so that it will become effective at 4:00 p.m., Eastern Time, on February 3, 2017, or as soon thereafter as is practicable.

Please contact Michael G. Keeley, Esq. of Norton Rose Fulbright US LLP at (214) 855-3906 with any questions you may have regarding this request. In
addition, please notify Mr. Keeley by telephone when this request for acceleration has been granted.

Respectfully,

EQUITY BANCSHARES, INC.

By:

/s/ Gregory H. Kossover

Name: Gregory H. Kossover

Title: Chief Financial Officer

cc:
Michael G. Keeley, Esq., Norton Rose Fulbright US LLP

CORRESP
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Acceleration Request

 EQUITY BANCSHARES, INC.

January 25, 2017

 VIA EDGAR

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F. Street, N.E.

 Washington, D.C.
20549

 Attn: Katelyn Donovan

Re:
Equity Bancshares, Inc.

Registration Statement on Form S-3

File No. 333-215583

 Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Equity Bancshares, Inc. hereby respectfully requests acceleration of the
effective date of the above-referenced Registration Statement on Form S-3 so that it will become effective at 4:00 p.m., Eastern Time, on January 27, 2017, or as soon thereafter as is practicable.

Please contact Michael G. Keeley, Esq. of Norton Rose Fulbright US LLP at (214) 855-3906 with any questions you may have regarding this request. In
addition, please notify Mr. Keeley by telephone when this request for acceleration has been granted.

Respectfully,

EQUITY BANCSHARES, INC.

By:

/s/ Gregory H. Kossover

Name:

Gregory H. Kossover

Title:

Chief Financial Officer

cc:
Michael G. Keeley, Esq., Norton Rose Fulbright US LLP

Mail Stop 4720
January 24 , 2017

Brad S. Ellio tt
Chairman and Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive , Suite 300
Wichita, KS 67207

Re: Equity Bancshares, Inc.
  Registration Statement on Form S-3
Filed  January 17, 2017
  File No. 333-215583

Dear Mr. Ellio tt:

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 Kate Donovan, Staff Attorney, at (202) 551 -8636  with any questions.

Sincerely,

 /s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Services
cc: Mike Keeley
 Norton Rose Fulbright US LLP

CORRESP
1
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CORRESP

Norton Rose Fulbright US LLP

January 23, 2017

2200 Ross Avenue, Suite 3600

Dallas, Texas 75201-7932

VIA EDGAR AND E-MAIL

United States

Securities and Exchange Commission

Tel +1 214 855 8000

Division of Corporation Finance

Fax +1 214 855 8200

100 F Street, N.E.

nortonrosefulbright.com

Washington, D.C. 20549

Attn: Christian Windsor, Special Counsel

Re:

Equity Bancshares, Inc.

Registration Statement on Form S-4

 Filed December 27, 2016

 File No. 333-215330

 Ladies and Gentlemen:

On behalf of Equity Bancshares, Inc., a Kansas corporation (the “Company”), we are submitting this letter in response to the
comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated January 18, 2017 (the “Comment
Letter”) with respect to the Company’s Registration Statement on Form S-4, which was filed with the Commission on December 27, 2016 (the “Registration Statement”).

Concurrently with the submission of this letter, the Company is filing an Amendment No. 1 to the Registration Statement (the
“Amended Registration Statement”). Capitalized terms used but not otherwise defined in this letter shall have the meanings given to such terms in the Amended Registration Statement. References herein to page numbers are to page
numbers in the Amended Registration Statement being filed contemporaneously herewith. For your convenience, the numbered paragraphs of this letter correspond to the numbered paragraphs of the Comment Letter. In this letter, we have recited the
Staff’s comments in bold type and have followed each comment with the Company’s response.

 For your reference, this letter,
along with both a clean copy of the Amended Registration Statement and a copy marked to show all changes from the initial filing of the Registration Statement, are being furnished to you via e-mail.

The Merger, page 43

 Prairie’s Reasons
for the Merger; Recommendation of the Prairie Board, page 45

1.
Please supplementally provide us with any presentation materials that Capital presented to the board of directors relating to this transaction.

A copy of the materials reviewed and discussed by representatives of The Capital Corporation, LLC (“Capital”) with the board of
directors of Prairie will be supplementally provided to the Staff under separate cover by Capital.

 Norton Rose Fulbright US LLP is a limited liability
partnership registered under the laws of Texas.

 Norton Rose Fulbright US LLP, Norton Rose Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose
Fulbright Canada LLP and Norton Rose Fulbright South Africa Inc are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but
does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com.

 January 23, 2017

 Page
 2

 These materials will be submitted by Capital on a confidential and supplemental basis
pursuant to Rule 12b-4 under the Securities Exchange Act of 1934, as amended, and Rule 418 under the Securities Act of 1933, as amended. In accordance with such rules, Capital is requesting that the materials
be returned promptly following completion of the Staff’s review thereof. By separate letter, Capital also is requesting confidential treatment of these materials pursuant to the provisions of 17 C.F.R. Section 200.83.

2.
Please revise to disclose the extent to which Prairie’s board considered the fact that Capital had based its fairness determination upon the valuations in mergers involving Kansas based institutions, and that
some of the transactions involved institutions who had significantly different financial health and earnings performance. Also, we note that in the last bullet point on page 45, the board considered the “financial analyses presented by
Capital.” To the extent that Capital engaged in any analyses other than the market value analysis described beginning on page 49, please describe those analyses.

In response to the Staff’s comment, the Company has revised page 45 of the Amended Registration Statement to include additional discussion
of the Prairie Board’s consideration of the valuation of Prairie contained in Capital’s fairness opinion.

 The Company has also
revised page 50 of the Amended Registration Statement to include a discussion of the discounted cash flows analysis conducted by Capital.

 Opinion
of Prairie’s Financial Advisor, page 47

3.
We note that on page 47, Capital indicated that it received financial projections from Prairie and State Bank. To the extent that those projections impacted any of the financial analyses referenced in the final
bullet point on the top of page 48, disclose the projections necessary for an investor to evaluate the relevant analysis.

In response to the Staff’s comment, the Company has revised page 50 of the Amended Registration Statement to include the projections use
by Capital in its financial analyses.

 Interests of Prairie’s Directors and Executive Officers in the Merger, page 53

Employment Agreements, page 53

4.
Please revise to provide more details regarding these agreements. Specifically, if known, please indicate which Prairie officers will have their compensation changed when they join Equity and the amount of any
increase in their compensation.

 In response to the Staff’s comment, the Company has revised page 53 of the Amended
Registration Statement to provide more details regarding these agreements including the percentage amounts of changes in the compensation for each specified Prairie officer.

*****

 January 23, 2017

 Page
 3

 Please do not hesitate to contact me by telephone at (214)
855-3906 with any questions or comments regarding this correspondence.

Very truly yours,

/s/ Michael G. Keeley

 Michael G. Keeley

 of Norton Rose Fulbright US
LLP

cc:

William H. Dorton, Securities and Exchange Commission

Brad S. Elliott, Equity Bancshares, Inc.

Michael C. Mense, Prairie State Bancshares, Inc.

C. Robert Monroe, Esq., Stinson Leonard Street LLP

Mail Stop  4720
January  18, 2017

Brad S. Elliott
Chairman and Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 300
Wichita, KS 67207

Re: Equity Bancshares, Inc.
  Registration Statement on Form S-4
Filed  December  27, 2016
  File No.  333-215330

Dear Mr. Elliott :

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 com ments 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, w e may have  additional comments.

The Merger, page  43

Prairie’s Reasons for the Merger; Recommendation of the Prairie Board , page  45

1. Please supplementally provide us with any presentation materials that Capital presented
to the board of directors relati ng to this transaction.

2. Please revise to disclose the extent to which Prairie’s board considered the fact that
Capital had based its fairness determination upon the valuations in mergers involving
Kansas based institutions, and that some of  the transactio ns involved insti tutions who had
significantly different financial health and earnings performance.  Also, we note that in
the last bullet point on page 45, the board considered the “financial analyses presented by
Capital.”  To the extent that Capital eng aged in any analyses other than the market value
analysis described beginning on page  49, please describe those analyses.

Brad S. Elliott
Equity Bancshares, Inc.
January  18, 2017
Page 2

 Opinion of Prairie’s Financial Advisor, page  47

3. We note that on page 47, Capital indicated that it received financial projections fr om
Prairie and State Bank.  To the extent that those projections impacted any of the financial
analyses referenced in the final bullet point on the top of page 48, disclose the projections
necessary for an investor to evaluate the relevant analysis.

Interests of Prairie’s Directors and Executive Officers in the Merger, page  53

Employment Agreements, page  53

4. Please revise to provide more details regarding these agreements.  Specifically, if known,
please indicate which Prairie officers will have their compensation changed when they
join Equity  and the amount of any increase in their compensation.

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  accel eration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Please contact William H. Dorton, Staff Attorney , at (202) 551 -3107  or me at (202) 551 -
3419  with any other questi ons.

Sincerely,

/s/ Christian Windsor

Christian Windsor
Special Counsel
Office of Financial Services

CORRESP
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Acceleration Request

 EQUITY BANCSHARES, INC.

VIA EDGAR

 September 28, 2016

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F. Street, N.E.

 Washington, D.C.
20549

 Attn: Christian Windsor, Special Counsel

Re:
Equity Bancshares, Inc.

Registration Statement on Form S-4

File No. 333-213283

 Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, Equity Bancshares, Inc. (the “Company”),
respectfully requests that the effective date for its Registration Statement on Form S-4 (File No. 333-213283) be accelerated so that such Registration Statement will be declared effective at 4:00 p.m., Eastern time, on September 30, 2016, or as
soon thereafter as is practicable.

 In connection with the foregoing request for acceleration of effectiveness, the Company hereby
acknowledges the following:

•

should the Securities and Exchange Commission (the “Commission”) or the staff of the Division of Corporation Finance of the Commission (the “Staff”), acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 If you have any questions or desire additional information, please contact Michael G. Keeley of Norton Rose Fulbright US
LLP at (214) 855-3906. In addition, please notify Mr. Keeley when this request for acceleration has been granted.

Respectfully,

EQUITY BANCSHARES, INC.

By:

 /s/ Gregory H. Kossover

Name:

Gregory H. Kossover

Title:

Chief Financial Officer

cc:
Michael G. Keeley, Esq., Norton Rose Fulbright US LLP

CORRESP
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Response Letter

Norton Rose Fulbright US LLP

September 23, 2016

2200 Ross Avenue, Suite 3600

Dallas, Texas 75201-7932

VIA EDGAR AND COURIER

United States

Securities and Exchange Commission

Tel +1 214 855 8000

Division of Corporation Finance

Fax +1 214 855 8200

100 F Street, N.E.

nortonrosefulbright.com

Washington, D.C. 20549-4628

Attn: Christian Windsor, Special Counsel

Re:
Equity Bancshares, Inc.

 Registration Statement on Form S-4

Filed August 24, 2016

File No. 333-213283

 Ladies and
Gentlemen:

 On behalf of Equity Bancshares, Inc., a Kansas corporation (the “Company”), we are submitting this letter in
response to the comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated September 20, 2016 (the
“Comment Letter”) with respect to the Company’s Registration Statement on Form S-4, which was filed with the Commission on August 24, 2016 (the “Registration Statement”).

Concurrently with the submission of this letter, the Company is filing an Amendment No. 1 to the Registration Statement (the “Amended
Registration Statement”). Capitalized terms used but not otherwise defined in this letter shall have the meanings given to such terms in the Amended Registration Statement. References herein to page numbers are to page numbers in the
Amended Registration Statement being filed contemporaneously herewith. For your convenience, the numbered paragraphs of this letter correspond to the numbered paragraphs of the Comment Letter. In this letter, we have recited the Staff’s
comments in bold type and have followed each comment with the Company’s response.

 Prospectus Cover Page

1.
Please disclose the total merger consideration as of the date that the merger was announced, as well as for a recent date. Please make corresponding changes throughout your prospectus.

In response to the Staff’s comment, the Company has revised the cover page of the Amended Registration Statement and made corresponding
changes throughout the prospectus.

2.
 We note your disclosure that the cash component of the merger consideration may be reduced. Please disclose
“Community stockholders’ equity” (the “Adjusted Equity” in the merger agreement) as of a recent date, the calculation

 Norton Rose Fulbright US LLP is a limited
liability partnership registered under the laws of Texas.

 Norton Rose Fulbright US LLP, Norton Rose Fulbright LLP, Norton Rose Fulbright Australia, Norton
Rose Fulbright Canada LLP and Norton Rose Fulbright South Africa Inc are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members
but does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com.

 September 23, 2016

 Page
 2

date, the threshold below which the merger consideration, and the expected impact of merger related transactions. To the extent that the current equity value minus expected expenses would result
in a reduction in the per share cash consideration, revise the cover page to make this clear.

 In response to the
Staff’s comment, the Company has revised the cover page of the Amended Registration Statement to include the requested disclosures. The Company respectfully acknowledges the Staff’s comment concerning disclosure of the Community
stockholders’ equity as of the calculation date, but the Company will not know such amount until the close of business on the fifth business day immediately preceding the closing of the merger.

Questions and Answers about the Merger

 What
will Community stockholders be entitled to receive in the merger?, page 2

3.
Revise this section to disclose Community’s equity as of June 30, 2016 and to clarify the impact of the itemized merger costs on the equity value. Since it appears that the currently expected merger costs will
reduce Community’s equity value below the $44.8 million limit, please provide investors with tabular presentation of the impact of currently expected merger costs on the per-share cash merger consideration. The tabular presentation should also
provide investors with an idea as to the impact of further merger related costs, for instance by presenting the impact of up to $2 million in additional costs at $500 thousand intervals upon the per share cash merger consideration.

 In response to the Staff’s comment, the Company has revised the disclosures under the heading “Questions and
Answers—Will the value of the merger consideration change between the date of this joint proxy statement/prospectus and the time the merger is completed?” on page 3 and “The Merger Agreement—Merger Consideration” beginning
on page 284 to include the requested tabular presentation. The Company has also inserted a cross reference to the disclosure under the heading “Question and Answer—What will Community stockholders be entitled to receive in the
merger?” to the revised disclosure contained under the headings “Questions and Answers—Will the value of the merger consideration change between the date of this joint proxy statement/prospectus and the time the merger is
completed?” and “The Merger Agreement—Merger Consideration.”

 Summary

Interests of Community’s Directors and Executive Officers in the Merger, page 15

4.
Please disclose the salaries for Ms. Main and Mr. Criner and attach their employment agreements pursuant to Item 601(b)(10)(iii)(A) of Regulation S-K. Please also revise to quantify the aggregate severance payments
that Community’s Executive Officers will be entitled to receive. Please make conforming revisions on page 279.

 The
Company respectfully acknowledges the Staff’s comments. Following the effective time of the merger, Ms. Main will continue to receive the same salary that she currently receives as an employee of Community and Mr. Criner will receive a lower
salary than he currently receives as an employee of Community. In response to the Staff’s comments, the disclosure in the Amended Registration Statement under “The Merger—Interests of Community’s Directors and Executive Officers
in the Merger—Employment Agreements” on page 279 has been revised to clarify that Ms. Main’s compensation will remain the same and Mr. Criner’s compensation will be reduced.

 September 23, 2016

 Page
 3

 The employment agreements of Ms. Main and Mr. Criner were not filed as exhibits under Item
601(b)(10)(iii)(A) of Regulation S-K since such employment agreements are immaterial in amount and significance and neither Ms. Main nor Mr. Criner will be executive officers or directors of the Company or be involved in any policy making function
following the effective time of the merger. Therefore, the Company does not believe that it is required to file such employment agreements as exhibits pursuant to Item 601(b)(10)(iii)(A).

The Company has revised the disclosure on pages 15 and 280 of the Amended Registration Statement to include the aggregate severance that
Community’s executive officers, as a group, may be entitled to if they are terminated after the effective time of the merger and to clarify the severance to which Ms. Main and Mr. Criner may be entitled.

The Merger

 Opinion of Community’s
Financial Advisor, page 258

5.
We note that Community’s management provided Stephens with financial projections for the years between 2017 and 2021. To the extent that these projections materially impacted Stephen’s discounted cash flow
projections, as disclosed on page 263, please revise the S-4 to include those projections so that investors are able to evaluate the analysis conducted by the financial advisor.

In response to the Staff’s comment, the Company has revised page 278 of the Amended Registration Statement to include the projections
provided by Community’s management.

 Opinion of Equity’s Financial Advisor

Discounted Cash Flow Analysis—Community, page 276

6.
Please disclose the projections for Community’s assets that KBW used in its discounted cash flow analysis, as well as any projections for Community’s net income not already disclosed on page 279.

 In response to the Staff’s comment, the Company has revised page 278 of the Amended Registration Statement to
include the projections provided by Community’s management.

 Representations and Warranties, page 288

7.
 We note your statements that shareholders “should not rely on the representations, warranties, covenants
or any description thereof as characterizations of the actual state of facts or condition of Equity, Community or

 September 23, 2016

 Page
 4

any of their respective subsidiaries or affiliates” and that these representations and warranties “are solely for the benefit of Equity and Community.” Please revise to remove any
potential implication that the referenced merger agreement does not constitute public disclosure under the federal securities laws. We further note your disclosure that this information “may change after the date of the merger agreement, which
subsequent information may or may not be fully reflected in public disclosures by Equity or Community.” Please be advised that, notwithstanding the inclusion of a general disclaimer, you are responsible for considering whether additional
specific disclosures of material information regarding material contractual provisions are required to make the statements included in your joint proxy statement/prospectus not misleading.

In response to the Staff’s comment, the Company has revised page 288 of the Amended Registration Statement to remove any potential
implication that the referenced merger agreement does not constitute public disclosure under the federal securities laws. The Company confirms its understanding that it is responsible for considering whether additional specific disclosures of
material information regarding material contractual provisions are required to make the statements included in the joint proxy statement/prospectus not misleading.

Exhibit Index

8.
We note Exhibits 8.1 and 8.2. If the tax consequences of the transaction are material, then Item 601(b)(8) requires an opinion regarding the tax consequences. Exhibit 8.1 and 8.2 do not opine as to the tax
consequences, but instead opine only as to the accuracy of the disclosure. Revise the tax opinions so that they opine as to the material tax consequences of the transaction, including the tax consequences to the shareholders of Community. Please
refer to Sections III.B and III.C of Staff Legal Bulletin No. 19 for further guidance.

 In response to the Staff’s
comment, the Company has filed revised Exhibits 8.1 and 8.2 to the Amended Registration Statement.

9.
Please attach the consents of Messrs. Maland and Bowers as required by Securities Act Rule 438.

In response to the Staff’s comment, the Company has filed as Exhibits 99.5 and 99.6 to the Amended Registration Statement the written
consent of each person named in the Amendment Registration Statement as an anticipated director of the Company following the effective time of the merger.

*****

 In the event the Company
requests acceleration of the effective date of the Registration Statement, the Company acknowledges that:

•

should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 September 23, 2016

 Page
 5

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Please do not hesitate to contact me by telephone at (214) 855-3906 with any questions or comments regarding this
correspondence.

 Very truly yours,

 /s/ Michael G. Keeley

 Michael G. Keeley

 of Norton Rose Fulbright US LLP

cc:
Christopher Dunham, Securities and Exchange Commission

 Brad S. Elliott, Equity Bancshares,
Inc.

 Jerry P. Maland, Community First Bancshares, Inc.

Dan R. Bowers, Esq., Bowers Law Firm

Jonathan S. Hightower, Esq., Bryan Cave LLP

Mail Stop 4720

September 20, 2016

Via E -mail
Brad S. Elliott
Chairman and Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 200
Wichita, KS 67207

Re: Equity Bancshares, Inc.
  Registration Statement on Form S-4
Filed  August 24, 2016
  File No.  333-213283

Dear Mr. Elliott :

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 com ments 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, w e may have  additional comments.

Prospectus Cover Page

1. Please disclose the total merger consideration as of the date that the merger was
announced, as well as for a recent date.  Please make corresponding changes throughout
your prospectus.

2. We note you r disclosure that the cash component of the merger consideration may be
reduced.  Please disclose “Community stockholders’ equity” (the “Adjusted Equity” in
the merger agreement) as of a recent date, the calculation date, the threshold below which
the merg er consideration, and the expected impact of merger related transactions.  To the
extent that the current equity value minus expected expenses would result in a reduction
in the per share cash consideration, revise the cover page to make this clear.

Brad S. Elliott
Equity Bancshares, Inc.
September 20, 2016
Page 2

 Quest ions and Answers about the Merger

What will Community stockholders be entitle to receive in the merger? , page 2

3. Revise this section to disclose Community’s equity as of June 30, 2016 and to clarify the
impact of the itemized merger costs on the equity va lue.  Since it appears that the
currently expected merger costs will reduce Community’s equity value below the $44.8
million limit, please provide investors with tabular presentation of the impact of currently
expected merger costs on the per -share cash me rger consideration.  The tabular
presentation should also provide investors with an idea as to the impact of further merger
related costs, for instance by presenting the impact of up to $2 million in additional costs
at $500 thousand intervals upon the per  share cash merger consideration.

Summary

Interests of Community’s Directors and Executive Officers in the Merger, page 15

4. Please disclose the salaries for Ms. Main and Mr. Criner and attach their employment
agreements pursuant to Item 601(b)( 10)(iii)(A) of Regulation S -K.  Please also revise to
quantify the aggregate severance payments that Community’s Executive Officers will be
entitled to receive.  Please make conforming revisions on page 279.

The Merger

Opinion of Community’s Financial Ad visor , page 258

5. We note that Community’s management provided Stephens with financial projections for
the years between 2017 and 2021.  To the extent that these projections materially
impacted Stephen’s discounted cash flow projections, as disclosed on pag e 263, please
revise the S -4 to include those projections so that investors are able to evaluate the
analysis conducted by the financial advisor.

Opinion of Equity’s Financial Advisor

Discounted Cash Flow Analysis —Community, page 276

6. Please disclose the  projections for Community’s assets that KBW used in its discounted
cash flow analysis, as well as any projections for Community’s net income not already
disclosed on page 279.

Representations and Warranties, page 288

7. We note your statements that shareho lders “ should not rely on the representations,
warranties, covenants or any description thereof as characterizations of the actual state of

Brad S. Elliott
Equity Bancshares, Inc.
September 20, 2016
Page 3

 facts or condition of Equity, Community or any of their respective subsidiaries or
affiliates ” and that these repres entations and warranties “are solely for the benefit of
Equity and Community.”  Please revise to remove any potential implication that the
referenced merger agreement does not constitute public disclosure under the federal
securities laws.  We further note  your disclosure that this  information “may change after
the date of the merger agreement, which subsequent information may or may not be fully
reflected in public disclosures by Equity or Community .”  Please be advised that,
notwithstanding the inclusion of a general disclaimer, you are responsible for considering
whether additional specific disclosures of material information regarding material
contractual provisions are required to make the statements included in your joint proxy
statement/prospectus not  misleading.

Exhibit Index

8. We note Exhibits 8.1 and 8.2.  If the tax consequences of the transaction are material,
then Item 601(b)(8) requires an opinion regarding the tax consequences.  Exhibit 8.1 and
8.2 do not opine as to the tax consequences, but i nstead opine only as to the accuracy of
the disclosure.  Revise the tax opinions so that they opine as to the material tax
consequences of the transaction, including the tax consequences to the shareholders of
Community.  Please refer to Sections III.B and  III.C of Staff Legal Bulletin No. 19 for
further guidance.

9. Please attach the consents of Messrs. Maland and Bowers as required by Securities Act
Rule 438.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement , please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commiss ion from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and ac curacy of the disclosure in the filing; and

Brad S. Elliott
Equity Bancshares, Inc.
September 20, 2016
Page 4

  the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to rev iew any amendment prior to the requested effective date of the
registration statement.

Please contact Christopher Dunham, Staff Attorney,  at (202) 551 -3783  or, in his absence,
me at (202) 551 -3419 with any other questions.

Sincerely,

 /s/ Christian Windsor

Christian Windsor
Special Counsel
Office of Financial Services

cc: Michael G. Keeley, Esq.

CORRESP
1
filename1.htm

CORRESP

 November 6,
2015

VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

 Attention: Mr. Dietrich A. King

Re:
Equity Bancshares, Inc.

Registration Statement on Form S-1 (File No. 333-207351)

Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

In accordance with Rule 461 of the Securities Act of 1933, as amended (the “Securities Act”), we hereby join Equity Bancshares, Inc.
(the “Company”) in requesting that the effectiveness of the Company’s above-referenced Registration Statement on Form S-1, as amended, be accelerated so that it will become effective on Tuesday, November 10, 2015, at 2:00 p.m.,
Washington D.C. time, or as soon thereafter as practicable.

 Additionally, pursuant to Rule 460 of the Securities Act, we hereby advise
you that 1,800 copies of the Preliminary Prospectus dated November 2, 2015, were furnished to 3 prospective underwriters and distributed by the underwriters approximately as follows from November 2, 2015 through the date hereof: 1,450
copies to institutional investors and 350 copies to others.

 We, the undersigned, as representatives of the several underwriters, have and
will, and each underwriter has advised the undersigned that it has and will, comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[SIGNATURE PAGE FOLLOWS]

Very Truly Yours,

 KEEFE, BRUYETTE & WOODS, INC.

STEPHENS INC.

 as Representatives of the several
Underwriters

KEEFE, BRUYETTE & WOODS, INC.

By:

/s/ Lisa Schultz

Name:

Lisa Schultz

Title:

 Managing Director

 Co-Head Equity Capital
Markets

STEPHENS INC.

By:

/s/ Scott Studwell

Name:

Scott Studwell

Title:

 Managing Director

 Head of FIG
ECM

CORRESP
1
filename1.htm

CORRESP

 Via EDGAR

November 6, 2015

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-4628

 Attn: Dietrich A. King, Assistant
Director

Re:
Equity Bancshares, Inc.

        Registration
Statement on Form S-1 (as amended)

        File
No. 333-207351

 Ladies and Gentlemen:

Equity Bancshares, Inc. (the “Company”) hereby respectfully requests that the effective date of the above referenced
Registration Statement on Form S-1 be accelerated to 2:00 p.m. (Washington, D.C. time) on November 10, 2015, or as soon practicable thereafter.

The Company hereby acknowledges that:

•

should the Securities and Exchange Commission (the “Commission”) or the staff of the Division of Corporation Finance of the Commission (the “Staff”), acting pursuant to
delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the accuracy and adequacy of the
disclosure in the filing; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Please notify Michael G. Keeley of Norton Rose Fulbright US LLP at (214) 855-3906 upon the effectiveness of the
Registration Statement or if you have any questions regarding this request.

 Thank you for your assistance in this matter.

 Securities and Exchange Commission

November 6, 2015

  Page
 2

Sincerely,

Equity Bancshares, Inc.

By:

 /s/ Brad S. Elliott

Name:

Brad S. Elliott

Title:

Chairman and Chief Executive Officer

cc:
Gregory H. Kossover, Equity Bancshares, Inc.

Michael G. Keeley, Norton Rose Fulbright US LLP

Brennan Ryan, Nelson Mullins Riley & Scarborough, LLP

John Jennings, Nelson Mullins Riley & Scarborough, LLP

July 28 , 2015

Brad S. Elliott
Chairman and Chief Executive Officer
Equity Bancshares, Inc.
7701 East Kellogg Drive, Suite 200
Wichita, Kansas 67207

Re: Equity Bancshares, Inc.
Draft Registration Statement on Form S -1
Submitted June 30 , 2015
  CIK No. 0001227500

Dear Mr. Elliott :

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 circumst ances 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.

General

1. We note that you are an emerging growth company.  Please supplementally provide us with
copies of all written communications, as defined in Rule 405 under the Securities Act, that
you, or anyone authorized to do so on your behalf, present to potential investors in reliance
on Section 5(d) of the Securities Act, whether or not they retain copies of the
communications.

2. Please note the financial statement updating requirements pursuant to  Rule 3 -12 of
Regulation S -X.

Brad S. Elliott
Equity Bancshares, Inc.
July 28 , 2015
Page 2

 Risk Factors, page 12

3. Please balance the disclosure in the summary by including a list of the most significant risks
and other consideration that could negatively affect you.

Selected Historical Consolidated Financial an d Other Data, page 17

4. Please revise your asset quality ratio of net charge -offs (recoveries) to average loans on page
18 for the three -months ended March 31, 2015 and March 31, 2014 to provide this ratio as an
annualized percentage for consistency and com parability to your annual ratios.

The dividend rate on our Series C preferred stock fluctuates . . ., page 37

5. Please disclose your present intentions with respect to redeeming the Series C preferred stock
prior to December 2015.

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

Liquidity and Capital Resources, page 89

6. Please revise your filing to provide a comparative discussion of each section of your cash
flows (i.e., operating, investing and financing) between all  comparable periods presented in
the statements of cash flows.  Refer to Section IV.B of Release No. 33 -8350 "Interpretation:
Commission Guidance Regarding Management's Discussion and Analysis of Financial
Condition and Results of Operations" for further i nformation.

7. Please disclose your present intentions with respect to redeeming the Series C preferred stock
prior to December 2015.

Legal Proceedings, page 117

8. Please tell us how you analyzed the CitiMortgage lawsuit for purposes of the disclosure
requirements in Item 103 of Regulation S -K.

Executive Compensation and Other Matters

Summary Compensation Table, page 136

9. Please tell us how you concluded that you should include Mr. Pepper’s entire  award under
the Market President Incentive Plan in the “Non -Equity Incentive Plan Compensation.”  In
this regard, we note that awards under the Market President Incentive Plan are paid 50% in
cash and 50% in equity.  In your response, y ou may wish to refer to Question 119.22 of our
Regulation S -K Compliance and Disclosure Interpretations.

Brad S. Elliott
Equity Bancshares, Inc.
July 28 , 2015
Page 3

 Director Compensation Table, page 141

10. Please revise the table to include separate columns for fees paid in cash, stock awards and
stock options, as required by Item 402(r) of Regulation S -K or tell us why you believe the
current presentation is appropriate.

Principal Stockholders, page 151

11. Please update your disclosure to reflect the number of shares that each individual or entity
plans to purchase  in the offering.

Condensed Notes to Interim Consolidated Financial Statements

Note 2 – Securities, page F -9

12. We note that the amount of gross unrealized losses for your held to maturity securities
presented in the table on page F -10 is significantly le ss than that disclosed in the table on
page F -12.  We also note similar differences in your audited financial statement footnotes on
pages F -51 and F -53.  Please tell us the reason(s) for these differences and revise your filing
accordingly.

Note 9 – Fair Value, page F -26

13. Please revise the table of unobservable inputs used in the fair value measurement of financial
assets measured on a nonrecurring basis on pages F -30 and F -79 to disclose the weighted
average of the unobservable inputs. Refer to ASC 820-10-55-103 for example disclosure.

You may contact Stephen Kim  at (202) 551 -3291  or John Spitz  at (202) 551 -3484  if you
have questions regarding comments on the financial statements and related matters.  Please
contact Josh Samples  at (202) 551 -3199  or me at  (202) 551 -3338  with any other questions.

Sincerely,

 /s/ Dietrich A. King

Dietrich A. King
Assistant Director

cc. Michael Keeley
Norton Rose Fulbright US  LLP