SecProbe.io

CORRESP
 1
 filename1.htm

 May 12, 2026

 VIA
EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-0303
 Attention: Aisha Adegbuyi

 Re:
 Rhinebeck Bancorp, Inc.

 Registration Statement on Form
 S-1 – File No. 333-294283 (the "Registration Statement")

 Request
 for Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461
of Regulation C promulgated under the Securities Act of 1933, as amended, we hereby join Rhinebeck Bancorp, 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 Thursday, May 14, 2026, at 3:00 p.m., Eastern Time, or as soon thereafter as is practicable.

 Very truly yours,

 Keefe, Bruyette & Woods, Inc.

 /s/ Robin P. Suskind

 Name: Robin P. Suskind

 Title:   Managing Director

CORRESP
 1
 filename1.htm

 May 12, 2026

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-0303

 Attention: Aisha Adegbuyi

 Re:
 Rhinebeck Bancorp,
 Inc.

 Registration Statement on Form
 S-1 – File No. 333-294283 (the "Registration Statement")

 Request
 for Acceleration of Effectiveness

 Ladies and Gentlemen:

 In accordance with Rule 461
of Regulation C promulgated under the Securities Act of 1933, as amended, Rhinebeck Bancorp, Inc. hereby requests that the effectiveness
of the above-referenced Registration Statement on Form S-1, as amended, be accelerated so that it will become effective on Thursday,
May 14, 2026, at 3:00 p.m., Eastern Time, or as soon thereafter as is practicable.

 Please contact Elizabeth
Cook, Esq., of Luse Gorman, PC at (202) 274-2022 if you have any questions concerning this matter.

 Very truly yours,

 /s/ Matthew J. Smith

 Name: Matthew J. Smith

 Title: President and Chief
 Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 23, 2026

Matthew Smith
President and Chief Executive Officer
Rhinebeck Bancorp, Inc.
2 Jefferson Plaza
Poughkeepsie, NY 12601

 Re: Rhinebeck Bancorp, Inc.
 Registration Statement on Form S-1
 Filed March 13, 2026
 File No. 333-294283
Dear Matthew Smith:

 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: Scott Brown, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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Sandler O’Neill + Partners, L.P.

1251 Avenue of the Americas

6th Floor

New York, NY 10020

November 7, 2018

Via Edgar

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Rhinebeck Bancorp, Inc.

    Registration Statement on Form S-1

    File No. 333-227266

    Request for Acceleration of Effective Date

Dear Sir or Madam:

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
Rhinebeck Bancorp, Inc. (the “Company”) in requesting that the effective date of the Company’s above-referenced
registration statement on Form S-1 be accelerated to November 9, 2018 at 3:00 p.m., Eastern Time, or as soon thereafter as
practicable.

    SANDLER O’NEILL & PARTNERS, L.P.

    By:
    Sandler O’Neill & Partners Corp.,

    the sole general partner

    By:
    /s/ Jennifer Docherty

    Jennifer Docherty

    Authorized Signatory

CORRESP
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RHINEBECK BANCORP, INC.

2 Jefferson Plaza

Poughkeepsie, NY 12601

November 7, 2018

Via Edgar

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Rhinebeck Bancorp, Inc.

    Registration Statement on Form S-1 (Commission File No. 333-227266)

    Request for Acceleration of Effective Date

Ladies and Gentlemen:

Rhinebeck Bancorp, Inc. hereby requests
that the effective date of the above referenced Registration Statement on Form S-1, as amended, be accelerated to November 9, 2018
at 3:00 p.m. EST, or as soon thereafter as is practicable.

Please contact Scott A. Brown, of Luse Gorman,
PC. ((202) 274-2013), if you have any questions concerning this matter.

    Very truly yours,

    /s/ Michael J. Quinn

    Michael J. Quinn

    President and Chief Executive Officer

CORRESP
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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) 274-2013
    sbrown@luselaw.com

October 23, 2018

Via EDGAR

David Gessert

Special Counsel

Office of Financial Services

United States Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

 Re: Rhinebeck Bancorp, Inc.

Registration
Statement on Form S-1

Filed September 10, 2018

File No. 333-227266

Dear Mr. Gessert:

On behalf of Rhinebeck Bancorp, Inc. (the
 “Company”), filed herewith is Pre-Effective Amendment No. 1 to Registration Statement on Form S-1, including exhibits
(the “Amended Registration Statement”), which has been marked pursuant to SEC Rule 472 in response to the Staff’s
comment letter dated October 3, 2018. To aid your review, the Staff’s comments are reproduced below, followed by the Company’s
responses. The Amended Registration Statement also includes a “Recent Developments” section containing unaudited financial
information as of and for period ended September 30, 2018, beginning on page 30 of the prospectus.

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.

Neither the Company nor any person authorized
to act on its behalf has provided or intends to provide potential investors with any written communications contemplated by Section
5(d) of the Securities Act.

David Gessert

October 23, 2018

Page 2

How We Determined the Offering Range and the $10.00 per
Share Offering Price, page 5

2.            It appears the valuation of peer group companies in the first table on page 6 is shown on a fully-converted basis. If so, please
revise to clarify in the table and in the disclosure preceding the table that only the selected pricing ratios for Rhinebeck Bancorp
are presented on a non-fully converted basis. Also, please discuss the impact of full or partial conversion on the comparability
of the peer group information to the information about the company. If you have made adjustments to the earnings or book values
of the peer group companies for purposes of this comparison, please clarify.

Additional disclosure has been added on
page 6 of the prospectus.

Management's Discussion and Analysis of Financial Condition
and Results of Operations Delinquent Loans, page 66

 3.           Please disclose delinquent information for the indirect automobile lending program given its significance and your future plans to grow this lending.

The delinquency table on page 72 of the
prospectus has been revised to provide information for the indirect automobile lending program.

Allowance for Loan Losses, page 69

 4.            Please disclose indirect automobile loan charge-offs and recoveries for the periods presented.

The table on page 75 of the prospectus has
been revised to provide information for the indirect automobile lending program.

* * *

If you have any questions, please contact
the undersigned.

    Very truly yours,

    /s/ Scott A. Brown

    Scott A. Brown

Enclosure

 cc: Pam Long, Securities and Exchange Commission

Marc
Thomas, Securities and Exchange Commission

Gus Rodriguez, Securities and Exchange Commission

Michael J. Quinn, Rhinebeck Bancorp, Inc.

Eric Luse, Luse Gorman, PC

Elizabeth A. Cook, Luse Gorman, PC

October 3, 2018
Michael J. Quinn
President and Chief Executive Officer
Rhinebeck Bancorp, Inc.
2 Jefferson Plaza
Poughkeepsie, NY 12601
Re:Rhinebeck Bancorp, Inc.
Registration Statement on Form S-1
Filed September 10, 2018
File No. 333-227266
Dear Mr. Quinn:
            We have reviewed your 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 amending your registration statement and providing the
requested information.  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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Form S-1 filed September 10, 2018
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.
How We Determined the Offering Range and the $10.00 per Share Offering Price, page 5
2.It appears the valuation of peer group companies in the first table on page 6 is shown on a
fully-converted basis.  If so, please revise to clarify in the table and in the disclosure

 FirstName LastNameMichael J. Quinn
 Comapany NameRhinebeck Bancorp, Inc.
 October 3, 2018 Page 2
 FirstName LastName
Michael J. Quinn
Rhinebeck Bancorp, Inc.
October 3, 2018
Page 2
preceding the table that only the selected pricing ratios for Rhinebeck Bancorp are
presented on a non-fully converted basis.  Also, please discuss the impact of full or partial
conversion on the comparability of the peer group information to the information about
the company.  If you have made adjustments to the earnings or book values of the peer
group companies for purposes of this comparison, please clarify.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Delinquent Loans , page 66
3.Please disclose delinquent information for the indirect automobile lending program given
its significance and your future plans to grow this lending.
Allowance for Loan Losses, page 69
4.Please disclose indirect automobile loan charge-offs and recoveries for the periods
presented.

            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.
            You may contact Marc Thomas at 202-551-3452 or Gus Rodriguez at 202-551-3752 if
you have questions regarding comments on the financial statements and related matters.  Please
contact David Gessert at 202-551-2326 or Pam Long at 202-551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services
cc:       Scott A. Brown, Esq.