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 Document CORRESP HOME BANCORP, INC. 503 Kaliste Saloom Road Lafayette, Louisiana 70508 (337) 237-1960 December 1, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Robert Arzonetti, Esq. Re: Home Bancorp, Inc. Registration Statement on Form S-3 File No. 333-291693 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Home Bancorp, Inc. (the “Company”) hereby requests that the above captioned Registration Statement be declared effective on Wednesday, December 3, 2025, at 10:00 a.m., Eastern time, or as soon thereafter as is practicable. Should you have any questions with respect to this request, please contact our counsel Kenneth Tabach of Silver, Freedman, Taff & Tiernan LLP at 202-295-4531. Once the Registration Statement has been declared effective, please orally confirm that event by calling Mr. Tabach. Very truly yours, HOME BANCORP, INC. By: /s/ John W. Bordelon John W. Bordelon Chairman, President and Chief Executive Officer

December 19, 2024
David Kirkley
Chief Financial Officer
Home Bancorp, Inc.
503 Kaliste Saloom Road
Lafayette, LA 70508
Re:Home Bancorp, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-34190
Dear David Kirkley:
            We have completed our review of your filing. We remind you that the company and
its management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Finance

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CORRESP.

December 18, 2024

VIA EDGAR

Division of Corporation Finance

Office of Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attn:  Marc Thomas

        Re:    Home Bancorp, Inc. (the “Company”)

            Form 10-K for the Fiscal Year Ended December 31, 2023

            Form 8-K filed October 17, 2024

            File No. 001-34190

Dear Mr. Thomas,

This letter is in response to your comment letter, dated December 6, 2024 (“Comment Letter”), regarding the Form 8-K filed on October 17, 2024, of Home Bancorp, Inc. (the “Company”).  For ease of reference, the comment from the Comment Letter is reproduced below in bold-face type and our response thereto follows.

Form 8-K filed October 17, 2024

Exhibit 99.2, page 29

1.We note that your presentation of Non-GAAP tangible shareholders’ equity AOCI adjusted and Non-GAAP tangible book value per share AOCI adjusted represent individually tailored accounting measures given that the adjustment to exclude accumulated other comprehensive loss, net has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP.  Therefore, please remove the presentation of these non-GAAP measures from future filings.  Refer to Question 100.04 of the Division of Corporations Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.

In future filings, the Company will not include the Non-GAAP tangible shareholders’ equity AOCI adjusted and Non-GAAP tangible book value per share AOCI adjusted.

 Closing Comments:

In providing this response, the Company acknowledges that:

•the Company and management are responsible for the adequacy and accuracy of their disclosures, not withstanding any review, comments, actions or absence of action by the staff;

December 18, 2024

2

•staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the Company’s filings; and

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

In the event you have any additional comments or questions on this matter, please do not hesitate to contact the undersigned at (337) 237-1960.

Very truly yours,

/s/ David T. Kirkley

David T. Kirkley

Senior Executive Vice President and Chief Financial Officer

December 6, 2024
David Kirkley
Chief Financial Officer
Home Bancorp, Inc.
503 Kaliste Saloom Road
Lafayette, LA 70508
Re:Home Bancorp, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
Form 8-K filed October 17, 2024
File No. 001-34190
Dear David Kirkley:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 8-K filed October 17, 2024
Exhibit 99.2, page 29
1.We note that your presentation of Non-GAAP tangible shareholders' equity AOCI
adjusted and Non-GAAP tangible book value per share AOCI adjusted
represent individually tailored accounting measures given that the adjustment to
exclude accumulated other comprehensive loss, net has the effect of changing the
recognition and measurement principles required to be applied in accordance with
GAAP. Therefore, please remove the presentation of these non-GAAP measures from
future filings. Refer to Question 100.04 of the Division of Corporation Finance’s
Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule
100(b) of Regulation G.
            In closing, 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.

December 6, 2024
Page 2
            Please contact Marc Thomas at 202-551-3452 or Robert Klein at 202-551-3847 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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CORRESP

HOME BANCORP, INC.

503 Kaliste Saloom Road

Lafayette, Louisiana  70508

(337) 237-1960

August 25, 2022

VIA EDGAR AND E-MAIL

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: David Lin, Esq.

Re:    Home Bancorp, Inc.

    Registration Statement on Form S-4

    File No. 333-266819

Ladies and Gentlemen:

    Pursuant to Rule 461 under the Securities Act of 1933, as amended, Home Bancorp, Inc. (the “Company”) hereby requests that the above captioned Registration Statement be declared effective on Tuesday, August 30, 2022, at 1:00 p.m., Eastern time, or as soon thereafter as is practicable.

    Please contact our counsel, Hugh Wilkinson of Silver, Freedman, Taff & Tiernan LLP at 202-295-4530 should you have any questions with respect to this request and to confirm effectiveness of the Registration Statement.

                    Very truly yours,

                    HOME BANCORP, INC.

                    By:    /s/ John W. Bordelon

                        John W. Bordelon

                        Chairman, President and Chief Executive Officer

United States securities and exchange commission logo
August 19, 2022
John W. Bordelon
Chairman, President and Chief Executive Officer
Home Bancorp, Inc.
503 Kaliste Saloom Road
Lafayette, LA 70508
Re:Home Bancorp, Inc.
Registration Statement on Form S-4
Filed August 12, 2022
File No. 333-266819
Dear Mr. Bordelon:
            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

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 CORRESP.

August 2, 2016

 VIA
EDGAR

 Division of Corporation Finance

 U.S.
Securities and Exchange Commission

 100 F Street, NE

Washington, DC 20549

 Attn: Stephanie Sullivan, Senior Assistant
Chief Accountant

Re:

Home Bancorp, Inc. (the “Company”)

Form 10-K for the Fiscal Year Ended December 31, 2015

Filed March 14, 2016

File No. 001-34190

 Dear Ms. Sullivan,

This letter is to supplement our previous response, dated July 27, 2016, to your comment letter, dated July 13, 2016 (“Comment
Letter”), regarding the Form 10-K, for the year ended December 31, 2015, of Home Bancorp, Inc. (the “Company”). Based on our conversation with the staff, we are hereby supplementing our response to the first bullet point of
Comment No. 1 in the Comment Letter. For ease of reference, the subject portion of the comment from the Comment Letter is reproduced below in bold-face type and our supplemental response thereto follows.

Form 10-K for the Fiscal Year Ended December 31, 2015

Consolidated Financial Statements

 Notes to
Consolidated Financial Statements

 Note 5 –Loans, page 59

1.
We note your disclosure on page 62 that you have $20.0 million and $32.0 million of acquired loans that were accounted for under ASC 310-30 as of December 31, 2015 and 2014, respectively. Please respond to the
following:

•

We note your disclosure on page 67 that states that nonaccrual acquired loans accounted for under ASC 310-30 totaled $4.6 million and $11.8 million as of December 31, 2015 and 2014, respectively. Please clarify
whether you have ceased recognizing interest income on these loans in accordance with ASC 310-30. If so, please explain your basis for being unable to reasonably estimate the cash flows for these loans. Please refer to ASC 310-30-35-3 for guidance.

 The Company proposes to revise the disclosure in the nonaccrual table with respect to loans accounted for under ASC
310-30 since interest is being recognized through accretable yield. In future filings, we propose to revise the presentation as follows (utilizing the December 31, 2015 information for purposes of illustration).

 August 2, 2016

Page 2

December 31, 2015

December 31, 2014

 (dollars in thousands)

Originated

Acquired(1)

Total

Originated

Acquired(1)

Total

 Nonaccrual loans:

 One- to four-family first mortgage

$
928

$
530

$
1,458

$
1,429

$
1,997

$
3,426

 Home equity loans and lines

121

139

260

65

71

136

 Commercial real estate

1,671

1,013

2,684

829

462

1,291

 Construction and land

86

69

155

—

211

211

 Multi-family residential

—

763

763

—

1,560

1,560

 Commercial and industrial

2,374

84

2,458

1,191

18

1,209

 Consumer

471

6

477

329

30

359

 Total

$
5,651

$
2,604

$
8,255

$
3,843

$
4,349

$
8,192

(1)
Table excludes acquired loans which were being accounted for under ASC 310-30 because they continue to earn interest from accretable yield regardless of their status as past due or otherwise not in compliance with their
contractual terms. Acquired loans with deteriorated credit quality, which were being accounting for under ASC 310-30 and which were 90 days or more past due totaled $4.0 million and $5.4 million as of December 31, 2015 and 2014, respectively.

 Closing Comments:

 In providing
this response, the Company acknowledges that:

•

the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

•

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•

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

In the event you have any additional comments or questions on this matter, please do not hesitate to contact the undersigned at (337) 237-1960.

 Very truly yours,

 /s/ Joseph B. Zanco

 Joseph B. Zanco

 Executive Vice President and Chief Financial Officer

Cc:
Hugh T. Wilkinson, Esq.

September 2 3, 2013

Via E -mail
Joseph B. Zanco
Chief Financial Officer
Home Bancorp, Inc.
503 Kaliste Saloom Road
Lafayette, Louisiana 70508

Re: Home Bancorp, Inc.
Form 10-K for Fiscal  Period Ended December 31, 2012
Form 10 -Q for the Quarterly Period Ended June 30, 2013
Filed March 15, 2013
  File No. 001 -34190

Dear Mr. Zanco :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure  in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  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 Exchange Act of 1934 and all applicabl e rules require.

Sincerely,

 /s/ John P. Nolan

John P. Nolan
Senior Assistant Chief Accountant

September 6, 2013

Via E -mail
Joseph B. Zanco
Chief Financial Officer
Home Bancorp, Inc.
503 Kaliste Saloom Road
Lafayette, Louisiana 70508

Re: Home  Bancorp, Inc.
Form 10-K for Fiscal Period Ended December 31, 2012
Form 10 -Q for the Quarterly Period Ended June 30, 2013
Filed March 15, 2013
  File No. 001 -34190

Dear Mr. Zanco :

We have reviewed your filing an d 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 within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
respo nse.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response t o these  comments, we may have  additional comments.

Form 10 -K for the fiscal year ended December 31, 2012
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 5 – Loans, page 62

1. We note your disclosure on page 15  of the June 30, 2013 Form 10 -Q and page 66 of the
December 31, 2012 Form 10 -K that non -accrual non -covered loans were $16.9 million, $12.4
million and $11.0 million at June 30, 2013, December 31, 2012 and 2011, respectively.
Additionally, we also note th at these non -accrual loans include $11.3 million, $10.2 million
and $7.2 million of loans acquired from GSFC in July 2011, respectively.  Given the
significance of these legacy GSFC loans to your total non -accrual loans, please tell us, and
revise future f ilings to address the following:

Joseph B. Zanco
Home Bancorp, Inc.
September 6, 2013
Page 2

 The types of loans (one -to-four family, commercial real estate, etc) included in these non -
accrual loans acquired from GSFC;

 Whether these non -accrual loans were accounted for under ASC 310 -30 (loans acquired
with deterio rated credit quality);

 How you classified these acquired loans at acquisition (accrual, non -accrual, 90 days and
accruing, impaired and troubled debt restructurings).  For example, discuss if these loans
are considered non -accrual and / or impaired immedi ately after acquisition and the
underlying reasons for your determination.  Additionally, in all of your credit quality
disclosures (including disclosures of non -accrual referenced above), please clearly
disclose if purchased credit impaired loans are incl uded and quantify the amount.

 When these loans became non -accrual along with the facts and circumstances related to
the credit quality of these newly acquired loans that resulted in this classification;

 The allowance for loan losses associated with these  loans, as applicable;

 How any changes in credit quality related to these loans, as well as any other key drivers,
impacted each component of the allowance for loan losses; and

 Any other pertinent information deemed necessary to understand your review of  these
loans and related accounting for these loans as of the date of acquisition (July 2011)
through June 30, 2013.

             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 Exchange Act of
1934 and all applicable Exchange 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 accurac y
and adequacy of the disclosures they have made.

            In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filin g;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

Joseph B. Zanco
Home Bancorp, Inc.
September 6, 2013
Page 3

 You may contact Benjamin Phippen, Staff Accountant,  at (202) 551 -3697  or me at (202)
551-3492  if you have questions regarding comments on the financial statements and related
matters.

Sincerely,

 /s/ John P. Nolan

John P. Nolan
Senior Assistant Chief Accountant

Mail Stop 4561

July 2, 2008

By U.S. Mail and Facsimile (202)347-2172

John W. Bordelon President and Chief Executive Officer Home Bancorp, Inc.  503 Kaliste Saloom Road Lafayette, LA 70508
Re: Home Bancorp, Inc.
Registration Statement on Form S-1
Filed June 6, 2008
 File No. 333-151492
Dear Mr. Bordelon:

We have reviewed your filing and have th e following comments.  Where indicated, we
think you should revise your document in response to these comments.  If you disagree, we will
consider your explanation as to why our commen t is inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry in your explanation.  In some  of our comments, we may ask
you to provide us with information so we may better understand your disclosure.  After
reviewing this information, we may or  may not raise additional comments.

The purpose of our review process is to assist you in your compliance with the applicable
disclosure requirements and to enhance the overall  disclosure in your filing.  We welcome any
questions you may have about our comments or on any other aspect of our review.  Feel free to
call us at the telephone numbers lis ted at the end of  this letter.
 General

1. Please file all exhibits with your next amen dment; they are subject to staff review.
2. We note that your Employee Stock Ownership plan intends to purch ase shares in the
offering and then distribute them to employ ees as compensation; please include the Plan
as a Co-Issuer to your registration statement.

John W. Bordelon
Home Bancorp, Inc.
July 2, 2008 Page 2  Risk Factors

General

3. We note that several of your risk factors contemplate hypothetical risks as opposed to
known material risks.  For example, the second risk factor claims that your allowance for
loan losses may not be adequate but it is not clear whether th is is a known risk or merely
the nature of an allowance.  Revise the noted  risk factor, and all other risk factors to
clarify the likelihood of the noted risk occurr ing and discuss any specific concerns that
caused management to decide that  the noted risk was a material risk factor.  For example,
in the second risk factor on page 15, discuss any actual losses due to  Hurricanes during
the past few years.
4. Some of your risk factors c ontain language like: “no assu rance can be given” and “we
can not guarantee.”  The risk fact ors must discuss the nature of  the specific risk, not your
ability to provide assurance.  Please remove all such disclo sure from the risk factors
section and make sure that all risk factors address the particular risk rather than your
ability to offer assurance.
 Market Area and Competition, page 51

5. When providing statistical information, please disclose your source for such information.
 Transactions with Related Persons, page 89

6. Please provide the representations contemplat ed by Instruction 4(c)  of Item 404(a) of
Regulation S-K.

Proposed Management Purchases, page 90
7. Please disclose by footnote to the table how  each director qualif ies to exceed the
individual purchase limitation.

Subscription Offering and Subscription Rights, page 96
8. Please disclose the treatment of joint account holders as to eligibility to purchase shares.  In particular, please explain whether joint account holders will be able to purchase
independently or whether they will they be tr eated as one eligible account holder for the
purpose of purchase limitations.

John W. Bordelon
Home Bancorp, Inc.
July 2, 2008 Page 3  Tax Aspects, page 105

9. Revise the heading so that it is more desc riptive of the information contained in this
section.  For example, consider using th e heading “Material Federal Income Tax
Consequences of the Conversion.”
 Exhibit 8.1; Tax Opinion of Hunton & Williams

10. You can limit reliance on your opinion with re gard to purpose, but not person.  Please
revise the last paragraph.
*      *      *

Closing Comments
As appropriate, please amend your registration statement in response to these comments.
You may wish to provide us with marked copies  of the amendment to expedite our review.
Please furnish a cover letter with  your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have  additional comments after reviewing your
amendment and responses to our comments.

We direct your attention to Rules 460 and 461 regarding requesting acceleration of a
registration statement.  Please a llow adequate time after the fili ng of any amendment for further
review before submitting a request for acceleration.  Please provide this request at least two
business days in advance of the requested effective date.
  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filings reviewed by the staff to be certain  that they have provided all information investors
require for an informed decision.  Since the comp any and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.       Notwithstanding our comments, in the even t the company requests acceleration of the
effective date of the pending registration statement,  it should furnish a letter, at the time of such
request, acknowledging that
 ‚ should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission 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

John W. Bordelon
Home Bancorp, Inc.  July 2, 2008 Page 4
‚ the company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divisi on of Corporation Finance in connection with
our review of your filing or in response to our comments on your filing.

We will consider a written request for acceleration of the effective date of the registration
statement as a confirmation of the fact that those requesting accelerat ion are aware of their
respective responsibilitie s under the Securities Act of 1933 and the Securities Exchange Act of
1934 as they relate to the proposed public offeri ng of the securities specified in the above
registration statement.  We w ill act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.
 Please contact Kate McHale at (202) 551-3464 or me at (202) 551-3419 with any
questions.          S i n c e r e l y ,
        C h r i s t i a n  W i n d s o r
 cc: Raymond Tiernan
Hugh Wilkinson Elias, Matz, Tiernan & Herrick LLP 734 15
th Street, N.W.
12th Floor
Washington, DC 20005