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Esquire Financial Holdings, Inc.
CIK: 0001531031  ·  File(s): 333-295076  ·  Started: 2026-04-20  ·  Last active: 2026-05-04
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2026-04-20
Esquire Financial Holdings, Inc.
Offering / Registration Process Regulatory Compliance Financial Reporting
File Nos in letter: 333-295076
↓
CR Company responded 2026-05-04
Esquire Financial Holdings, Inc.
Offering / Registration Process
File Nos in letter: 333-295076
Esquire Financial Holdings, Inc.
CIK: 0001531031  ·  File(s): 333-278832  ·  Started: 2024-04-23  ·  Last active: 2024-04-30
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2024-04-23
Esquire Financial Holdings, Inc.
Regulatory Compliance Offering / Registration Process Financial Reporting
File Nos in letter: 333-278832
↓
CR Company responded 2024-04-30
Esquire Financial Holdings, Inc.
Offering / Registration Process
File Nos in letter: 333-278832
Esquire Financial Holdings, Inc.
CIK: 0001531031  ·  File(s): 333-256678  ·  Started: 2021-06-03  ·  Last active: 2021-06-07
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2021-06-03
Esquire Financial Holdings, Inc.
Regulatory Compliance Financial Reporting Offering / Registration Process
File Nos in letter: 333-256678
↓
CR Company responded 2021-06-07
Esquire Financial Holdings, Inc.
Offering / Registration Process
File Nos in letter: 333-256678
Esquire Financial Holdings, Inc.
CIK: 0001531031  ·  File(s): 333-227725  ·  Started: 2018-10-11  ·  Last active: 2018-10-11
Response Received 1 company response(s) High - file number match
UL SEC wrote to company 2018-10-11
Esquire Financial Holdings, Inc.
File Nos in letter: 333-227725
Filing - SEC Comment Letter to Esquire Financial Holdings, Inc.
UPLOAD · 2018-10-11
Generating summary...
↓
CR Company responded 2018-10-11
Esquire Financial Holdings, Inc.
File Nos in letter: 333-227725
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2018-10-11
Generating summary...
Esquire Financial Holdings, Inc.
CIK: 0001531031  ·  File(s): N/A  ·  Started: 2017-05-04  ·  Last active: 2017-06-22
Response Received 3 company response(s) Medium - date proximity
UL SEC wrote to company 2017-05-04
Esquire Financial Holdings, Inc.
Filing - SEC Comment Letter to Esquire Financial Holdings, Inc.
UPLOAD · 2017-05-04
Generating summary...
↓
CR Company responded 2017-05-31
Esquire Financial Holdings, Inc.
References: May 4, 2017
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2017-05-31
Generating summary...
↓
CR Company responded 2017-06-22
Esquire Financial Holdings, Inc.
File Nos in letter: 333-218372
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2017-06-22
Generating summary...
↓
CR Company responded 2017-06-22
Esquire Financial Holdings, Inc.
File Nos in letter: 333-218372
Filing - Correspondence from Esquire Financial Holdings, Inc.
CORRESP · 2017-06-22
Generating summary...
Esquire Financial Holdings, Inc.
CIK: 0001531031  ·  File(s): N/A  ·  Started: 2016-11-10  ·  Last active: 2016-11-10
Awaiting Response 0 company response(s) Medium
UL SEC wrote to company 2016-11-10
Esquire Financial Holdings, Inc.
Filing - SEC Comment Letter to Esquire Financial Holdings, Inc.
UPLOAD · 2016-11-10
Generating summary...
DateTypeCompanyLocationFile NoLink
2026-05-04 Company Response Esquire Financial Holdings, Inc. MD N/A
Offering / Registration Process
Read Filing View
2026-04-20 SEC Comment Letter Esquire Financial Holdings, Inc. MD 333-295076
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2024-04-30 Company Response Esquire Financial Holdings, Inc. MD N/A
Offering / Registration Process
Read Filing View
2024-04-23 SEC Comment Letter Esquire Financial Holdings, Inc. MD 333-278832
Regulatory Compliance Offering / Registration Process Financial Reporting
Read Filing View
2021-06-07 Company Response Esquire Financial Holdings, Inc. MD N/A
Offering / Registration Process
Read Filing View
2021-06-03 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A
Regulatory Compliance Financial Reporting Offering / Registration Process
Read Filing View
2018-10-11 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A Read Filing View
2018-10-11 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-06-22 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-06-22 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-05-31 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-05-04 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A Read Filing View
2016-11-10 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2026-04-20 SEC Comment Letter Esquire Financial Holdings, Inc. MD 333-295076
Offering / Registration Process Regulatory Compliance Financial Reporting
Read Filing View
2024-04-23 SEC Comment Letter Esquire Financial Holdings, Inc. MD 333-278832
Regulatory Compliance Offering / Registration Process Financial Reporting
Read Filing View
2021-06-03 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A
Regulatory Compliance Financial Reporting Offering / Registration Process
Read Filing View
2018-10-11 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-05-04 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A Read Filing View
2016-11-10 SEC Comment Letter Esquire Financial Holdings, Inc. MD N/A Read Filing View
DateTypeCompanyLocationFile NoLink
2026-05-04 Company Response Esquire Financial Holdings, Inc. MD N/A
Offering / Registration Process
Read Filing View
2024-04-30 Company Response Esquire Financial Holdings, Inc. MD N/A
Offering / Registration Process
Read Filing View
2021-06-07 Company Response Esquire Financial Holdings, Inc. MD N/A
Offering / Registration Process
Read Filing View
2018-10-11 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-06-22 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-06-22 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2017-05-31 Company Response Esquire Financial Holdings, Inc. MD N/A Read Filing View
2026-05-04 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
 1
 filename1.htm

 Esquire
Financial Holdings, Inc.

 100 Jericho Quadrangle

 Suite 100

 Jericho, New York 11753

 May 4, 2026

 Via Edgar

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Esquire Financial Holdings, Inc.

 Registration Statement on Form S-4 (Registration
 No. 333-295076)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 Esquire Financial Holdings, Inc., a Maryland corporation (the
 "Company"), hereby requests that the above-referenced Registration Statement on Form S-4 be declared effective at 10:00
a.m., Eastern time, on May 6, 2026, or as soon thereafter as is practicable.

 Very truly yours,

 /s/ Andrew C. Sagliocca

 Andrew C. Sagliocca

 Vice Chairman, Chief Executive Officer
 and President

 (Duly Authorized Representative)
2026-04-20 - UPLOAD - Esquire Financial Holdings, Inc. File: 333-295076
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 20, 2026

Andrew C. Sagliocca
Chief Executive Officer
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle
Suite 100
Jericho, NY 11753

 Re: Esquire Financial Holdings, Inc.
 Registration Statement on Form S-4
 Filed April 15, 2026
 File No. 333-295076
Dear Andrew C. Sagliocca:

 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: Marc Levy
</TEXT>
</DOCUMENT>
2024-04-30 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm

      ESQUIRE FINANCIAL HOLDINGS, INC.

      100 Jericho Quadrangle, Suite 100

      Jericho, New York 11753

    April 30, 2024

    Via Edgar

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Re:       Esquire Financial Holdings, Inc.

    Registration Statement on Form S-3 (Registration No. 333-278832)

    Request for Acceleration of Effectiveness

    Ladies and Gentlemen:

    Esquire Financial Holdings, Inc., a Maryland corporation (the “Company”), hereby requests that the Company's above-referenced Registration
      Statement on Form S-3 be declared effective at 2:00 p.m., Eastern Time, on May 2, 2024, or as soon thereafter as is practicable.

            Very truly yours,

            /s/ Andrew C. Sagliocca

              Andrew C. Sagliocca

              Vice Chairman, President and Chief Executive Officer

            (Duly Authorized Representative)
2024-04-23 - UPLOAD - Esquire Financial Holdings, Inc. File: 333-278832
United States securities and exchange commission logo
April 23, 2024
Andrew C. Sagliocca
Vice Chairman, CEO and President
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle, Suite 100
Jericho, NY 11753
Re:Esquire Financial Holdings, Inc.
Registration Statement on Form S-3
Filed April 19, 2024
File No. 333-278832
Dear Andrew C. Sagliocca:
            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 Madeleine Joy Mateo at 202-551-3465 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Gregory M. Sobczak, Esq.
2021-06-07 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm

ESQUIRE
FINANCIAL HOLDINGS, INC.

100 Jericho Quadrangle,
Suite 100

Jericho, New York
11753

June 7, 2021

Via Edgar

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Esquire Financial Holdings, Inc.

    Registration Statement on Form S-3 (Registration No. 333-256678)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Esquire
Financial Holdings, Inc., a Maryland corporation (the “Company”), hereby requests that the Company's above-referenced Registration
Statement on Form S-3 be declared effective at 2:00 p.m., Eastern Time, on June 9, 2021, or as soon thereafter as is practicable.

    Very truly yours,

    /s/ Andrew C. Sagliocca

    Andrew C. Sagliocca

    President and Chief Executive Officer

    (Duly Authorized Representative)
2021-06-03 - UPLOAD - Esquire Financial Holdings, Inc.
United States securities and exchange commission logo
June 3, 2021
Andrew Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle, Suite 100
Jericho, NY 11753
Re:Esquire Financial Holdings, Inc.
Registration Statement on Form S-3
Filed June 1, 2021
File No. 333-256678
Dear Mr. Sagliocca:
            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
2018-10-11 - UPLOAD - Esquire Financial Holdings, Inc.
October 10, 2018
Andrew Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc.
100 Jericho Quadrangle, Suite 100
Jericho, NY 11753
Re:Esquire Financial Holdings, Inc.
Registration Statement on Form S-3
Filed October 5, 2018
File No. 333-227725
Dear Mr. Sagliocca:
            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
2018-10-11 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm

ESQUIRE FINANCIAL
HOLDINGS, INC.

100 Jericho Quadrangle,
Suite 100

Jericho, New York 11753

October 11, 2018

Via Edgar

Securities and Exchange
Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Esquire
                                         Financial Holdings, Inc.

    Registration
                                         Statement on Form S-3 (Registration No. 333-227725)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Esquire
Financial Holdings, Inc., a Maryland corporation (the “Company”), hereby requests that the Company's above-referenced
Registration Statement on Form S-3 be declared effective at 4:00 p.m., Eastern Time, on October 17, 2018, or as soon thereafter
as is practicable.

    Very truly yours,

    /s/ Andrew C. Sagliocca

    Andrew C. Sagliocca

    President and Chief Executive Officer

    (Duly Authorized Representative)
2017-06-22 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm

VIA EDGAR

June 22, 2017

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington, DC 20549

 Re: Esquire Financial Holdings, Inc.

Registration Statement on Form
S-1

Registration No. 333-218372

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended (the “Securities Act”), the undersigned, as underwriter for Esquire Financial Holdings, Inc.
proposed initial public offering of its common stock, hereby joins Esquire Financial Holdings, Inc.’s request for acceleration
of the above-referenced Registration Statement, requesting acceleration of the effective date to 4:00 p.m. (Eastern time)
on Monday, June 26, 2017, or as soon thereafter as is practicable.

In accordance with Rule 460 under the
Securities Act, and in connection with the foregoing, please be advised that we have distributed approximately 600 copies of the
Preliminary Prospectus, dated June 19, 2017.

The undersigned confirms that they have complied with and will
continue to comply with, and that they have been informed by the participating underwriters and dealers that they have complied
with and will continue to comply with, Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the
above-referenced issue.

Very truly yours,

SANDLER O’NEILL & PARTNERS, L.P.

    By:
    Sandler O’Neill & Partners Corp.,

        the sole general partner

    By:
    /s/ Britten L.
    Cosgrove

      Britten L. Cosgrove

          Authorized Signatory
2017-06-22 - CORRESP - Esquire Financial Holdings, Inc.
CORRESP
1
filename1.htm

Esquire Financial Holdings, Inc.

100 Jericho Quadrangle, Suite 100

Jericho, New York 11753

June 22, 2017

Via Edgar

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Esquire Financial Holdings, Inc.

    Registration Statement on Form S-1 (Registration Number 333-218372)

    Request for Acceleration of Effectiveness

Ladies and Gentlemen:

Esquire Financial Holdings, Inc., a Maryland
corporation (the “Company”), hereby requests that the Company’s Registration Statement on Form S-1 be declared
effective on June 26, 2017 at 4:00 pm, or as soon thereafter as is practicable.

    Very truly yours,

    /s/ Andrew C. Sagliocca

    Andrew C. Sagliocca

    President and Chief Executive Officer
2017-05-31 - CORRESP - Esquire Financial Holdings, Inc.
Read Filing Source Filing Referenced dates: May 4, 2017
CORRESP
1
filename1.htm

LUSE GORMAN,
PC

ATTORNEYS AT LAW

5335 WISCONSIN AVENUE, N.W., SUITE 780

WASHINGTON, D.C. 20015

TELEPHONE (202) 274-2000

FACSIMILE (202) 362-2902

www.luselaw.com

    WRITER'S DIRECT DIAL NUMBER
    WRITER’S E-MAIL

    (202) 274-2001
    jgorman@luselaw.com

May 31, 2017

Erin E. Martin

Special Counsel

Office of Financial Services

United States Securities and Exchange Commission

Washington, D.C. 20549

    Re:
    Esquire Financial Holdings, Inc.

    Draft Registration Statement on Form S-1

    Submitted April 12, 2017

    CIK No. 0001531031

Dear Ms. Martin:

On behalf of Esquire Financial Holdings,
Inc., a Maryland corporation (the “Company”), we are publicly filing herewith a Registration Statement on Form S-1
(the “Public Filing”) via the Securities and Exchange Commission’s (the “Commission”) EDGAR system.
In this letter, we respond to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the
Commission contained in the Staff’s letter dated May 4, 2017 (the “Comment Letter”) regarding the above-referenced
Draft Registration Statement submitted to the Commission on April 12, 2017.

The Public Filing also includes other changes
that are intended to update, clarify and render more complete the information contained therein, including updates to the financial
statements and disclosures to reflect the Company’s financial results as of and for the three months ended March 31, 2017.

Set forth below are the Company’s
responses to the comments in the Comment Letter. For the convenience of the Staff, the Company has restated in this letter each
of the comments in the Comment Letter and numbered each of the responses to correspond to the numbers of the comments. Capitalized
terms used but not defined herein have the meanings given to them in the Public Filing. All references to page numbers and
captions (other than those in the Staff’s comments) correspond to the page numbers and captions in the Public Filing.

Prospectus Summary

Our Competitive Strengths, page 3

 1. We note your response to comment 4. Please further balance your disclosure regarding your
business and growth strategies as well as competitive strengths by providing a brief summary of the most significant risks that
your business faces in the Summary section.

Response: In response
to the Staff’s comment, the Company has included a brief summary of the most significant risks on page 7 of the Public
Filing.

Business

Lending Activities, page 69

 2. Clarify the percentage of total loans represented by each of attorney consumer loans and real
estate loans.

Response: In response
to the Staff’s comment, the Company has clarified the percentage of total loans represented by each of attorney consumer
loans and real estate loans beginning on page 71 of the Public Filing.

* * *

The Company believes the foregoing provides
a complete response to the Comment Letter. If you have questions regarding the foregoing or require any additional information,
please do not hesitate to contact the undersigned at (202) 274-2001 or Gary Lax at (202) 274-2031.

    Very truly yours,

    /s/ John J. Gorman

    cc:
    Jessica Livingston, Esq.

    William Schroeder, CPA

    Amit Pande, CPA

    Andrew C. Sagliocca, President and Chief Executive Officer

    Gary Lax, Esq.
2017-05-04 - UPLOAD - Esquire Financial Holdings, Inc.
Mail Stop 4720
May 4, 2017

Andrew C. Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc.
320 Old Country Road, Suite 101
 Garden City, NY 11530

Re: Esquire  Financial  Holdings,  Inc.
Amendment No. 1  to Draft Registration Statement on Form S -1
Submitted  April 12, 2017
  CIK No . 0001531031

Dear  Ms. Sagliocca :

We have reviewed your amended 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 publicl y 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 r esponse to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

Prospectus Summary

Our Competitive Strengths, page 3

1. We note your response to comment 4.  Please further balance your disclosure regarding
your business and growth strategies as well as competitive strengths by providing a brief
summary of the most significant risks that your business faces in the Summary se ction.

Business

Lending Activities, page 69

2. Clarify the percentage of total loans represented by each of attorney consumer loans and
real estate loans.

Andrew  C. Sagliocca
Esquire  Financial  Holdings,  Inc.
May 4, 2017
 Page 2

 You may  contact  William  Schroeder  at 202-551-3294 or  Amit Pande at  202-551-3423
if you have  questions  regarding  comments  on the financial  statements  and related  matters.
Please  contact  Jessica  Livingston  at 202-551-3448  or me at 202-551-3391 with any  other
questions.

Sincerely,

          /s/ Erin E. Martin

Erin E. Martin
Special  Counsel
Office of Financial  Services

cc:  John  J. Gorman,  Esq.
2016-11-10 - UPLOAD - Esquire Financial Holdings, Inc.
Mail Stop 4720
November 9, 2016

Via E -mail
Andrew C. Sagliocca
President and Chief Executive Officer
Esquire Financial Holdings, Inc .
320 Old Country Road, Suite 101
Garden City, NY  11530

Re: Esquire Financial Holdings, Inc.
Draft Registration Statement on Form S -1
Submitted October 13, 2016
  CIK No. 0001531031

Dear Mr. Sagliocca :

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 disclos ure.

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.

General

1. 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

Andrew C. Sagliocca
Esquire Financial Holdings, Inc .
 November 9, 2016
 Page 2

 Summary

Our Company , page 1

2. In order to provide investors with a more balanced picture of your growth history and
challenges, expand your discussion of your results over the last 6 month period to also
capture th e results over the full fiscal years included in the financial statements.
Similarly, please discuss the challenges, including  credit exposure, from a growing and
unseasoned loan portfolio.

Our Business Strategy, page 2

3. Please tell us wh ether Esquire commissioned the Towers Watson report cited in this
section.  Also, balance your discussion  of the growth in tort costs compared to GDP
growth by also disclosing that over the last 5 years covered by the report, tort costs had
lagged GDP growt h.  Finally, please revise this section to clarify whether management
has conducted any research to determine if the value of tort actions in 2010 remains
indicati ve of the size of the tort actions in 2016.

Our Competitive Strengths, page 3

4. The disclosure in the summary should be a balanced presentation of your business. Please
balance the description of your competitive strengths with equally prominent disclosure
of the challenges you face and the risks and limitations that could harm your business or
inhibit your strategic plans. For example, and without limitation, please balance your
discussion of your asset quality with a discussion of the added risks of targeting small
and medium sized business es as loan clients. In this regard, we note your disclosure in
the first three risk factors on page 11, which disclose  that increasing commercial loans
may increase credit risk and the commercial, multifamily real estate and attorney loans
that comprise a substantial percentage of your loan portfolio have a higher degree of risk
than other loan types . As another example, please balance your discussion with a
discussion of the risks your business faces from business concentration in New York , as
you discuss in the s econd risk factor on page 15 .

Risk Fact ors

Because we intend …increase our commercial loans, our credit risk will increase , page 11

5. Revise this risk factor to discuss, in detail, the specific credit risk challenges associated
with your loans to attorneys as well as to law firm clients.

Andrew C. Sagliocca
Esquire Financial Holdings, Inc .
 November 9, 2016
 Page 3

 Our loan portfolio is unseasoned, page 14

6. Revise this risk factor to disclose the average age of the loans in each major lending
category.

As a community banking institutio n, we have lower lending limits …, page 17

7. Revise this risk factor to disclose your current lending limit, and indicate the aggregate
number of loans that are at or within 10% of your current limit.

Our management will have broad discretion as to the use of proceeds …, page 2 4

8. Revise this risk factor to disclose your current return on equity, your current equity
position as well as your expected equity position after the offering.

Use of Proceeds, page 29

9. We note your disclosure on page 23 that your return on equity may decline as a res ult of
the proceeds from the offering.  We also note that you already have a significant amount
of capital.  Please revise this section to explain all the specific  reasons that you chose to
make an offering at this time.  For instance, how much will your l ending limit increase as
a result of your increased capital?  Please refer to Item 504 of Regulation S -K.

10. We note that you anticipate using net proceeds to explore acquisition opportunities.
Please also give a brief description of  any acquisition strategy, including  the types of
opportunities you intend to explore , or clarify that management has not yet determined
the types of businesses that you might target .  Consider revisions to your management ’s
discussion and analysis based o n your response.

Business

Merchant Services Activities, page 66

11. Revise this section to explain, in more detail, your merchant servicing operations.  For
instance, how much in revenue do you generate from your $300 million in payment
volume.  Also, since you note that the independent servicin g organization model
represents a lower risk profile due to merchant reserves, please discuss how you
determine the size of the merchant reserves, as well as the risks associated with the direct
merchant model.  Also, please disclose the payment processing  system that you access
for your clients, and your contractual arrangements with that network.

Credit Risk Management, page 70

Andrew C. Sagliocca
Esquire Financial Holdings, Inc .
 November 9, 2016
 Page 4

 12. Revise your discussion  regarding  settlement loans to discuss your underwriting procedure
to determine the value of a settlement  and the potential time until the settlement is paid.
Also, please discuss your monitoring process to determine when a settlement  has been
paid and any protections you have to ensure that a settlement is not renegotiated after you
have made the loan.

Competitors, page 73

13. Revise this section , as well as your discussion regarding competition in the risk factors, to
discuss whether you face competition with other banks or other lenders t o fund lawyers
or to provide  financing for legal clients awaiting settlement payments.

Management

The Business Background of Our Directors and Executive Officers, page 84

14. In order for investors to evaluate the management of a public company, Item 401(e) o f
Regulation S -K requires that you disclose the business experience of your officers and
directors .  Please revise your disclosure to state the date each director and executive
officer began their current occupation or otherwise expand to include specific business
experience for the past five years.   For instance, how long has Mr. Kornhaber been
director of sa les for Esquire?  Si milarly, please clarify whether  Mr. Deutsch has managed
his family office , or if  Mr. Herman managed his law firm  for the five y ear period .

Description of Capital Stock, page 99

15. We note your disclosure in the introductory paragraph that the description appearing in
this section “does not purport to be a complete description of these rights and may not
contain all of the information regarding our capital stock that is important to you. These
rights can be determined in full only by reference to federal and state banking laws and
regulations, the Maryland General Corporation Code….”   Remove this language and
revise your  disclosure to provide a complete description of the material rights  of your
capital stock.

Andrew C. Sagliocca
Esquire Financial Holdings, Inc .
 November 9, 2016
 Page 5

 You may contact William Schroeder at 202-551-3294  or Amit Pande  at 202-551-3423 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jessica Livingston at 202-551-3448 or me at  202-551-3419  with any other questions.

Sincerely,

 /s/ Christian Windsor

 Christian Windsor
Special Counsel
Office of Financial Services

cc:  John J. Gorman , Esq.  (Via E -mail)

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