SecProbe.io

CORRESP
 1
 filename1.htm

 HOYNE BANCORP, INC.

 810 S. Oak Park Avenue

 Oak Park, Illinois 60304

 September 25, 2025

 VIA EDGAR

 Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ms. Aisha Adegbuyi and Mr. Christian Windsor

 Re:
 Hoyne Bancorp, Inc.

 Registration Statement on Form S-1 (Registration Number 333-288102)

 Request for Acceleration of Effectiveness

 Dear Ms. Adegbuyi and Mr. Windsor:

 Pursuant to Rule 461 under the Securities
Act of 1933, Hoyne Bancorp, Inc. (the "Company") hereby requests acceleration of the effective date of its Registration
Statement on Form S-1 (File No. 333-288102), as amended, to September 30, 2025 at 4:00 p.m. E.T., or as soon thereafter
as is practicable.

 Please contact Jennifer D. King of Vedder Price
P.C. at (312) 609-7835 as soon as practicable following the Registration Statement being declared effective or if you have any questions
concerning this matter.

 Very truly yours,

 /s/ Walter F. Healy

 Walter F. Healy

 President and Chief Executive Officer

CORRESP
 1
 filename1.htm

 September 25, 2025

 VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Ms. Aisha Adegbuyi
and Mr. Christian Windsor

 Re: Hoyne Bancorp, Inc.

 Registration
Statement on Form S-1 (Registration Number 333-288102)

 Request for Acceleration
of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461 of
the Rules and Regulations of the Securities and Exchange Commission promulgated under the Securities Act of 1933, as amended, we
hereby join Hoyne Bancorp, Inc. in requesting the above-referenced Registration Statement on Form S-1, as amended, be accelerated
so that it will become effective at 4:00 pm Eastern Time, on September 30, 2025 or as soon thereafter as practicable.

 Very truly yours,

 /s/ Patricia A. McJoynt

 Patricia A. McJoynt

 Managing Director

CORRESP
 1
 filename1.htm

 Chicago

 New York

 Washington, DC

 London

 San Francisco

 Los Angeles

 Singapore

 Dallas

 Miami

 vedderprice.com

 September 17, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Ms. Aisha Adegbuyi and Mr. Christian Windsor

 Re: Hoyne Bancorp, Inc.
 Amendment No. 1 to
Registration Statement on Form S-1 filed August 20, 2025
File No. 333-288102 (as amended, the "Registration Statement")

 Dear Ms. Adegbuyi and Mr. Windsor:

 On behalf of Hoyne Bancorp, Inc. (the "Company"),
we are hereby transmitting for filing via EDGAR a Pre-Effective Amendment No. 2 to the Company's Registration Statement on
Form S-1 (File No. 333-288102) (the "Amended Registration Statement"). Simultaneously therewith, the Company is
submitting via EDGAR this letter in response to the comment letter it received from the Staff dated September 4, 2025 with respect
to the Registration Statement. We have included below the comment set forth in the Staff's letter, as well as the Company's
response to that comment.

 Amendment No. 1 to Form S-1 filed August 20, 2025

 Management's Discussion and Analysis

 Comparison of Financial Condition

 Real Estate Owned, page 54

 1. Please refer to prior comment 4. We note your response that revised entries have been made to the audited consolidated financial
statements for the year ended December 31, 2024 and the three month period ended March 31, 2025, and that such statements have
been "restated" to now reflect the branch locations in other real estate at their carrying value at the time of transfer. Please
confirm that your "restated" financial statements represent a correction of an error pursuant to ASC 250-10-45-22 through 45-24
and revise your filing to present all of the disclosures required by ASC 250-10-50-7 through 50-11. To the extent you believe that these
corrections are not material to your financial statements, please provide us with a materiality analysis in support of your determination
to not restate your financial statements.

 222 North LaSalle Street   |  
Chicago, Illinois 60601   |   T +1 312 609 7500   |   F +1 312 609 5005

 Vedder Price P.C.
is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, Vedder
Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.

 Ms. Aisha Adegbuyi

 Mr. Christian Windsor

 September 17, 2025

 Page 2

 Response : The Company acknowledges the
Staff's comment and hereby confirms that the "restated" financial statements represent a correction of an error pursuant to
ASC 250-10-45-22 through 45-24, and accordingly, the Company has revised the filing to present the disclosures required by ASC
250-10-50-7 through 50-11. Specifically, the Company has included Note 4. "Restatement of Previously Issued Consolidated
Financial Statements" to both the audited consolidated financial statements as of and for the years ended December 31,
2024 and 2023 on page F-40 of the Amended Registration Statement and to the unaudited consolidated interim financial
statements as of and for the six months ended June 30, 2025 and 2024 on page F-12 of the Amended Registration Statement.
The Company has also included an explanation of the restatement and a reference to the restated financial statements and to these financial statement notes in the forepart of the MD&A section on
page 50 of the Amended Registration Statement.

 We believe the foregoing is responsive to the Staff's comment
and requests for additional information. Please be advised that the Company wishes to have the registration statement declared effective
as soon as possible. Accordingly, should you have any questions or need any additional information, please do not hesitate to contact
the undersigned at (312) 609-7835 or Daniel C. McKay, II at (312) 609-7762.

 Very truly yours,

 /s/ Jennifer Durham King

 Jennifer Durham King

 Shareholder, Corporate Practice Area Leader

 cc: Walter F. Healy, Hoyne Bancorp, Inc.
 Thomas S. Manfre, Hoyne Bancorp, Inc.

 Daniel C. McKay, II, Vedder Price P.C.

 John F. Breyer, Jr., Breyer & Associates
PC

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 4, 2025

Walter F. Healy
Chief Executive Officer
Hoyne Bancorp, Inc.
810 S. Oak Park Avenue
Oak Park, IL 60304

 Re: Hoyne Bancorp, Inc.
 Amendment No. 1 to
 Registration Statement on Form S-1
 Filed August 20, 2025
 File No. 333-288102
Dear Walter F. Healy:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our July 14,
2025 letter.

Amendment No. 1 to Form S-1 filed August 20, 2025
Management's Discussion and Analysis
Comparison of Financial Condition
Real Estate Owned, page 54

1. Please refer to prior comment 4. We note your response that revised
entries have been
 made to the audited consolidated financial statements for the year ended
 December 31, 2024 and the three month period ended March 31, 2025, and
that such
 statements have been "restated" to now reflect the branch locations in
other real estate
 at their carrying value at the time of transfer. Please confirm that
your "restated"
 financial statements represent a correction of an error pursuant to ASC
250-10-45-22
 through 45-24 and revise your filing to present all of the disclosures
required by ASC
 September 4, 2025
Page 2

 250-10-50-7 through 50-11. To the extent you believe that these
corrections are not
 material to your financial statements, please provide us with a
materiality analysis in
 support of your determination to not restate your financial statements.
 Please contact Lory Empie at 202-551-3714 or John Spitz at 202-551-3484
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Aisha Adegbuyi at 202-551-8754 or Christian Windsor at 202-551-3419
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Jennifer Durham King, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Chicago
 New York
 Washington, DC
 London
 San Francisco
 Los Angeles
 Singapore
 Dallas
 Miami
 vedderprice.com

 August 20,
2025

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:
Ms. Aisha Adegbuyi and Mr. Christian Windsor

 Re: Hoyne
 Bancorp, Inc.
 Registration
 Statement on Form S-1 filed June 17, 2025

 File
 No. 333-288102 (the "Registration Statement")

 Dear
Ms. Adegbuyi and Mr. Windsor:

 On
behalf of Hoyne Bancorp, Inc. (the "Company"), we are hereby transmitting for filing via EDGAR a Pre-Effective Amendment
No. 1 to the Company's Registration Statement on Form S-1 (File No. 333-288102) (the "Amended Registration
Statement"). Simultaneously therewith, the Company is submitting via EDGAR this letter in response to the comment letter it received
from the Staff dated July 14, 2025 with respect to the Registration Statement. We have included below the comments set forth in
the Staff's letter, as well as the Company's responses to those comments.

 Registration
Statement on Form S-1

 Risk
Factors

 The
level of our commercial real estate loan portfolio may subject us to additional regulatory scrutiny, page 16

 1. We
 note your reference to a number of commercial real estate loans, including multifamily loans.
 Please tell us, with a view towards enhanced disclosure in the risk factors and in your management's
 discussion, about any significant factors that impact your commercial loan portfolio. For
 instance, discuss whether any particular loan type is dependent on a small number of borrowers,
 or if the properties that secure your multi-family loans are subject to rent regulation.

 Response :
The Company acknowledges the Staff's comment and respectfully notes a discussion of risks associated with commercial real
estate loans under the risk factors titled " We intend to increase the origination of our commercial loan portfolio which
could expose us to increased lending risks and related loan losses " and " The geographic concentration of our loan
portfolio and lending activities makes us vulnerable to a downturn in our local market area " on pages 15 and 16 of
the Amended Registration Statement. The Company also notes that none of the properties that secure its multifamily loans are subject
to rent regulation. The Company has included additional disclosure in the Amended Registration Statement in the risk factors on
page 16 regarding significant factors affecting its primary market area and that may impact its commercial loan portfolio and
in the section captioned "Business of Hoyne Savings Bank – Loan Originations and Sales – Commercial Real
Estate" on page 67.

 222
North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005

 Vedder
Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California,
Vedder Price Pte. Ltd., which operates in Singapore, and Vedder Price (FL) LLP, which operates in Florida.

 Ms. Aisha
Adegbuyi

 Mr. Christian
Windsor

 August 20,
2025

 Page 2

 A
deterioration in economic conditions in our markets, page 17

 2. Please
 revise this risk factor to discuss, as appropriate, the factors that impact the Chicago Metropolitan
 area in which you focus. For instance, discuss any changes in occupancy for office, industrial
 or retail real estate. Discuss the extent to which the ability to compete in this area is
 dependent on existing relationships, and how this might impact your business strategy to
 increase your commercial real estate loan portfolio. Consider making appropriate changes
 to your MD&A, business and/or other risk factors based upon your response.

 Response :
The Company acknowledges the Staff's comment and respectfully notes a discussion of the Chicago Metropolitan area and the competition
the Company faces in its primary market under the section captioned "Market Area and Competition" on page 63 of the
Amended Registration Statement. The Company has also included additional disclosure in the Amended Registration Statement in this risk
factor and the risk factor tiled " Our business strategy includes commercial real estate (including commercial construction)
and commercial and industrial loan growth, and our financial condition and results of operations could be negatively affected if we fail
to grow or fail to manage our growth effectively " on page 17 as well as a cross reference on page 50 in the MD&A
section to the discussion under the section captioned "Market Area and Competition."

 We
are subject to certain risk if we are able to grow through opportunistic mergers and acquisitions, page 18

 3. We
 note that you have completed two mergers while still a mutual holding company. Revise this
 risk factor to discuss any difficulties you overcame in those mergers that might help investors
 better understand this risk. Similarly, please clarify if you believe that the risks from
 an attempt to grow through acquisitions might be changed once you have the ability to offer
 your common stock as part of an acquisition strategy.

 Response :
The Company acknowledges the Staff's comment. The Company has revised the disclosure in the Amended Registration Statement in this
risk factor on page 18 to seek to address the Staff's comment. The Company also respectfully notes the disclosure included
in the second paragraph of this risk factor regarding the possibility of an increase in the number of the Company's shares of common
stock outstanding and, accordingly the dilution of stockholders' equity and earnings per share, which could occur as a result of
any acquisition.

 Ms. Aisha
Adegbuyi

 Mr. Christian
Windsor

 August 20,
2025

 Page 3

 Real
Estate Owned, page 53

 4. We
 note your disclosure that the increase in Real Estate Owned during the three months ended
 March 31, 2025 was due to the net change in valuation upon transfer from premises and
 equipment from a net book value of $730,000 to market value of $2.2 million for a branch
 location. We also note similar disclosure on page 54 related to another branch location
 during the fiscal year ended December 31, 2024. As a result, you recorded a "Gain
 on REO" of $675,573 and $698,850 in your Consolidated Statement of Income during the
 quarterly and annual periods ended March 31, 2025 and December 31, 2024, respectively.
 Please tell us the authoritative guidance relied upon which resulted in the "Gain on
 REO" recorded for each period presented and how you considered the guidance in ASC
 360-10-35-37 through 35-43. In your response, please also tell us how you considered these
 closed branch locations to be held for sale pursuant to ASC 360-10-45-9 through 45-11.

 Response :
The Company acknowledges the Staff's comment and notes that the Company originally reviewed the accounting literature regarding
the closing of decades-old branch locations pursuant to an approach to classify the transaction under the "Long Lived Asset"
accounting guidelines. After further consideration of the authoritative guidance mentioned in this comment letter (ASC 360-10-35-37 through
35-43), revised entries have been made to the audited consolidated financial statements for the year ended December 31, 2024, and
the three month period ended March 31, 2025, and such statements have been restated to now reflect the branch locations in other
real estate at their carrying value at the time of transfer. In addition, the unaudited consolidated financial statements included in
the Amended Registration Statement as of and for the six months ended June 30, 2025 and 2024 also reflect the branch locations in
other real estate at their carrying value at the time of transfer. The disclosure in the MD&A section on page 53 of the Amended
Registration Statement as of June 30, 2025, has been similarly revised to reflect this change.

 Consolidated
Statement of Equity, page F-4

 5. Please
 tell us and revise your filing, as necessary, to explain what "acquired equity"
 represents and why it is separately presented within Retained Earnings in your Consolidated
 Statement of Equity for all periods presented.

 Response :
The Company acknowledges the Staff's comment. "Acquired Equity" represents a separate tracking of acquired equity from
previous acquisitions to differentiate from the Company's retained earnings. The Company has removed the separate line item for
acquired equity and included this item as part of overall retained earnings in the Consolidated Statement of Equity included in the audited
financial statements as of and for the years ended December 31, 2024 and 2023, as well as the unaudited consolidated financial statements
as of and for the six months ended June 30, 2025 and 2024.

 Ms. Aisha
Adegbuyi

 Mr. Christian
Windsor

 August 20,
2025

 Page 4

 Notes
To The Consolidated Financial Statements, page F-28

 6. Please
 revise to include segment reporting disclosures required by ASU 2023-07 and ASC 280.

 Response :
The Company acknowledges the Staff's comment and has revised Note 3 to the audited consolidated financial statements as of and
for the years ended December 31, 2024 and 2023 on page F-39 and Note 3 to the unaudited interim consolidated financial statements
as of and for the six months ended June 30, 2025 and 2024 on page F-12 to include segment reporting disclosures required by
ASU 2023-07 and ASC 280.

 We
believe the foregoing is responsive to the Staff's comments and requests for additional information. Please be advised that the
Company wishes to have the registration statement declared effective as soon as possible. Accordingly, should you have any questions
or need any additional information, please do not hesitate to contact the undersigned at (312) 609-7835 or Daniel C. McKay, II at
(312) 609-7762.

 Very
truly yours,

 /s/Jennifer Durham King

 Jennifer Durham King

 Shareholder, Corporate Practice Area
 Leader

 cc: Walter
 F. Healy, Hoyne Bancorp, Inc.

 Thomas S. Manfre, Hoyne Bancorp, Inc.

 Daniel
 C. McKay, II, Vedder Price P.C.

 John
 F. Breyer, Jr., Breyer & Associates PC

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 14, 2025

Walter Healy
Chief Executive Officer
Hoyne Bancorp, Inc.
810 S. Oak Park Avenue
Oak Park, Illinois 60304

 Re: Hoyne Bancorp, Inc.
 Registration Statement on Form S-1
 Filed June 17, 2025
 File No. 333-288102
Dear Walter Healy:

 We have reviewed your registration statement and have the following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-1
Risk Factors
The level of our commercial real estate loan portfolio my subject us to
additional regulatory
scrutiny, page 16

1. We note your reference to a number of commercial real estate loans,
including multi-
 family loans. Please tell us, with a view towards enhanced disclosure in
the risk
 factors and in your management's discussion, about any significant
factors that impact
 your commercial loan portfolio. For instance, discuss whether any
particular loan
 type is dependent on a small number of borrowers, or if the properties
that secure your
 multi-family loans are subject to rent regulation.
A deterioration in economic conditions in our markets, page 17

2. Please revise this risk factor to discuss, as appropriate, the factors
that impact the
 Chicago Metropolitan area in which you focus. For instance, discuss any
changes in
 July 14, 2025
Page 2

 occupancy for office, industrial or retail real estate. Discuss the
extent to which the
 ability to compete in this area is dependent on existing relationships,
and how this
 might impact your business strategy to increase your commercial real
estate loan
 portfolio. Consider making appropriate changes to your MD&A, business
and/or other
 risk factors based upon your response.
We are subject to certain risk if we are able to grow through opportunistic
mergers and
acquisitions, page 18

3. We note that you have completed two mergers while still a mutual holding
company.
 Revise this risk factor to discuss any difficulties you overcame in
those mergers that
 might help investors better understand this risk. Similarly, please
clarify if you believe
 that the risks from an attempt to grow through acquisitions might be
changed once
 you have the ability to offer your common stock as part of an
acquisition strategy.
Real Estate Owned, page 53

4. We note your disclosure that the increase in Real Estate Owned during
the three
 months ended March 31, 2025 was due to the net change in valuation upon
transfer
 from premises and equipment from a net book value of $730,000 to market
value of
 $2.2 million for a branch location. We also note similar disclosure on
page 54 related
 to another branch location during the fiscal year ended December 31,
2024. As a
 result, you recorded a Gain on REO of $675,573 and $698,850 in
your Consolidated
 Statement of Income during the quarterly and annual periods ended March
31, 2025
 and December 31, 2024, respectively. Please tell us the authoritative
guidance relied
 upon which resulted in the Gain on REO recorded for each period
presented and
 how you considered the guidance in ASC 360-10-35-37 through 35-43. In
your
 response, please also tell us how you considered these closed branch
locations to be
 held for sale pursuant to ASC 360-10-45-9 through 45-11.
Consolidated Statement of Equity, page F-4

5. Please tell us and revise your filing, as necessary, to explain what
acquired equity
 represents and why it is separately presented within Retained Earnings
in your
 Consolidated Statement of Equity for all periods presented.
Notes To The Consolidated Financial Statements, page F-28

6. Please revise to include segment reporting disclosures required by ASU
2023-07 and
 ASC 280.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Lory Empie at 202-551-3714 or John Spitz at 202-551-3484
if you
 July 14, 2025
Page 3

have questions regarding comments on the financial statements and related
matters. Please
contact Aisha Adegbuyi at 202-551-8754 or Christian Windsor at 202-551-3419
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
</TEXT>
</DOCUMENT>