SecProbe.io

CORRESP
 1
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 LAKE SHORE BANCORP, INC.
 31 East Fourth Street
 Dunkirk, New York 14048

 May 12, 2025

 Via Edgar
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Re:        Lake Shore Bancorp, Inc.
 Registration Statement on Form S-1 (Commission File No. 333-285836)
 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, Lake Shore Bancorp, Inc. hereby requests that the
 effective date of the above referenced Registration Statement on Form S-1, as amended, be accelerated to May 14, 2025 at 3:00 p.m. Eastern Time, or as soon thereafter as is practicable.

 Please contact Benjamin Azoff of Luse Gorman, PC at (202) 274-2010 if you have any questions concerning this matter.

 Very truly yours,

 /s/ Kim C. Liddell
 Kim C. Liddell
 President and Chief Executive Officer

CORRESP
 1
 filename1.htm

 May 12, 2025

 Via Edgar
 Securities and Exchange Commission
 100 F Street, N.E.
 Washington, D.C. 20549

 Re:        Lake Shore Bancorp, Inc.
 Registration Statement on Form S-1 (Commission File No. 333-285836)
 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, we hereby join Lake Shore Bancorp, Inc. in
 requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 3:00 p.m. Eastern Time on May 14, 2025, or as soon thereafter as may be practicable.

 Raymond James & Associates, Inc.

 /s/ Sanjay Patel
 Sanjay Patel
 Managing Director

CORRESP
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 CORRESP

 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) 274-2010

 bazoff@luselaw.com
 April 29, 2025
 Via EDGAR United States Securities and Exchange
Commission Division of Corporation Finance 100 F Street, NE
 Washington, DC 20549

 Re:
 Lake Shore Bancorp, Inc.
 Registration Statement on Form S-1
 Filed March 14, 2025
 File No. 333-285836 To Whom
It May Concern: On behalf of Lake Shore Bancorp, Inc. (the “Company”), filed herewith is its Pre-Effective Amendment No. 1
to Registration Statement on Form S-1, including exhibits (the “Amended Registration Statement”), which is marked pursuant to SEC Rule 472. The Staff’s comment, transmitted by letter dated April 2, 2025, is reproduced below,
followed by the Company’s response. The Amended Registration Statement includes a “Recent Developments” section containing unaudited financial information as of and for the three-month periods ended March 31, 2025 and 2024.
 Form S-1 filed March 14, 2025 How We
Intend To Use The Proceeds From The Stock Offering, page 36 1. We note that you may, “potentially restructure Lake Shore Bank’s
investment securities portfolio.” Either here or elsewhere, as appropriate, provide additional details about this potential restructuring.
 Response: Page 43 has been revised to provide additional information regarding the potential securities restructuring.

 L USE G ORMAN , PC
 United States Securities and Exchange Commission Division of
Corporation Finance April 29, 2025 Page 2
 We trust the foregoing is responsive to the Staff’s comments. We request that the Staff advise the undersigned at (202) 274-2010 as
soon as possible if it has any further comments.

 Respectfully,

 /s/ Benjamin Azoff

 Benjamin Azoff
 Enclosure

 cc:
 Todd Schiffman, Esq., SEC
 Christian Windsor, Esq., SEC Kim
C. Liddell, President and CEO, Lake Shore Bancorp, Inc.

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

Kim C. Liddell
President and CEO
Lake Shore Bancorp, Inc. /MD/
31 East Fourth Street
Dunkirk, New York 14048

 Re: Lake Shore Bancorp, Inc. /MD/
 Form S-1 filed March 14, 2025
 File No. 333-285836
Dear Kim C. Liddell:

 We have conducted a limited review of your 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 our 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.

Form S-1 filed March 14, 2025
How We Intend To Use The Proceeds From The Stock Offering, page 36

1. We note that you may, "potentially restructure Lake Shore Bank s
investment
 securities portfolio." Either here or elsewhere, as appropriate, provide
additional
 details about this potential restructuring.
 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.
 April 2, 2025
Page 2

 Please contact Todd Schiffman at 202-551-3491 or Christian Windsor at
202-551-
3419 with any other questions.

 Sincerely,

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