SecProbe.io

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 March 31, 2026

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: Richmond Mutual Bancorporation, Inc.

 Request for Acceleration of Effectiveness
of Registration Statement on Form S-4

 (SEC File No. 333-294527)

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
of the United States Securities and Exchange Commission (the "Commission") promulgated under the Securities Act of 1933, as
amended, Richmond Mutual Bancorporation, Inc. (the "Company") hereby requests that the effectiveness of the above referenced
registration statement on Form S-4 be accelerated by the Commission so that it will become effective at 10:00 a.m. Eastern Time on April
3, 2026, or as soon thereafter as practicable.

 Please contact Martin L. Meyrowitz, PC at (202)
295-4527 or mey@sfttlaw.com with any questions you may have. In addition, please notify Mr. Meyrowitz when this request for acceleration
has been granted.

 	 Very truly yours,

 Richmond Mutual Bancorporation, Inc.

 /s/Garry D. Kleer

 Garry D. Kleer

 President and Chief
Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 30, 2026

Garry D. Kleer
Chief Executive Officer
Richmond Mutual Bancorporation, Inc.
31 North 9th Street
Richmond, IN 47374

 Re: Richmond Mutual Bancorporation, Inc.
 Registration Statement on Form S-4
 Filed March 23, 2026
 File No. 333-294527
Dear Garry D. Kleer:

 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: Martin L. Meyrowitz, Esq.
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
June 7, 2021
Donald Benziger
Executive Vice President and Chief Financial Officer
Richmond Mutual Bancorporation, Inc.
31 North 9th Street
Richmond, Indiana 47374
Re:Richmond Mutual Bancorporation, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed March 31, 2021
File No. 001-38956
Dear Mr. Benziger:
            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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Document

P.O. Box 937   s   Richmond, IN  47375-0937

(765) 962-2581

June 4, 2021

VIA EDGAR SUBMISSION

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:  Dave Irving

Michelle Miller

Re:      Richmond Mutual Bancorporation, Inc. (the “Company”)

Form 10-K for the Fiscal Year Ended December 31, 2020

Filed March 31, 2021

File No. 001-38956

Ladies and Gentlemen:

We are writing in response to the comments contained in the Staff’s letter dated May 20, 2021 (the “Comment Letter”) with respect to Richmond Mutual Bancorporation, Inc.’s (the “Company”) Form 10-K for the Fiscal Year Ended December 31, 2020, as filed with the Commission on March 31, 2021 (“2020 Form 10-K”).

For the convenience of the Staff’s review, we have set forth the comments contained in the Staff’s Comment Letter along with the Company’s responses.

Form 10-K for the period ending December 31, 2020

Consolidated Balance Sheets, page 69

1.     In future filings, please disaggregate mortgage loans held for sale and mortgage loans held for long-term investment on your consolidated balance sheet. Refer to ASC 948-310-45- 1. Please provide us with your proposed disclosure.

Response:

In future Form 10-K and Form 10-Q filings, starting with the second quarter 2021 Form 10-Q, we will disaggregate mortgage loans held for sale and mortgage loans held for long-term investment on the Company’s consolidated balance sheet, with the two line items reading as follows:

 March 31,
2021  December 31,
2020

Loans held for sale 889,300   1,986,650

Loans and leases, net of allowance for losses of $10,958,902 and

$10,586,480, respectively

 762,842,114   734,413,448

Note 1: Nature of Operations and Summary of Significant Accounting Policies, page 74

2.    We note that you typically sell most of your conforming fixed-rate one-to-four family loans you originate, that in 2020 you sold $102.9 million one-to-four family loans as well as other loans of $4.3 million and recognized a $3.6 million gain on these sales compared to $0.6 million in 2019. In future filings, please address the following:

•Disclose how you account for loans held for sale; and

•Disclose the method used in determining the lower of cost or fair value of mortgage loans (that is, aggregate or individual loan basis). Refer to ASC 948-310-50-1.

Please provide us with your proposed disclosure.

Response:

In future Form 10-K filings, starting with the Form 10-K for the Company’s year ending December 31, 2021, we will add the following disclosure to “Note 1: Nature of Operations and Summary of Significant Accounting Policies”:

Mortgage Loans Held for Sale – Mortgage loans originated and intended for sale in the secondary market are recorded at the lower of cost or fair value on an individual loan basis.

Note 13. Benefit Plans, page 98

3.    You disclose that you are in the process of terminating your participation in the Pentegra Defined Benefit Plan and that you have accrued approximately $17.5 million for the withdrawal liability which is subject to change upon final termination. You also disclose that one of the risks of participating in a multi-employer plan is if a Company chooses to stop participating in a multi-employer plan, it may be required to pay an amount based on the underfunded status of the plan. Considering the impact of the withdrawal liability which triggered the net loss of $14.1 million in 2019, please enhance future filings to more fully address your obligations under the plan upon termination, how you measured the current liability recognized, and factors that could impact your current accrued liability. Refer to ASC 715-80-35 and ASC 450-20-50.

Please provide us with your proposed disclosure.

Response:

In future Form 10-K and Form 10-Q filings, starting with the second quarter 2021 Form 10-Q, we will provide the following additional disclosure to more fully address the Company’s obligations under the defined benefit plan upon termination, how the Company measured the current liability recognized, and the factors that could impact the Company’s current accrued liability:

The Company is in the process of terminating its participation in the Pentegra Defined Benefits Plan, which will require a payment of an amount based on the underfunded status of the plan, referred to as a withdrawal liability. In 2019, the Company estimated and accrued approximately $17.5 million for this withdrawal liability. This estimated withdrawal liability was calculated by plan administrators based on an interest rate of 2.35%, Pri-2012 mortality tables with white collar adjustments, and an assumed December 31, 2019 withdrawal date.  The Company’s actual termination expense will be based on the cost of purchasing annuities through an insurance company, and may be higher or lower depending on a number of factors, including the interest rate environment and the valuation of plan assets. Due to the current low interest rate environment, terminating the DB Plan at this time would require the Company to incur a substantial additional expense over and above the amount presently accrued, as interest rates are even lower now than they were in 2019.  As a result, the Company’s Board of Directors will continue to monitor and evaluate the timing of, and costs associated with, termination of the DB Plan, and it is currently uncertain when the termination of the DB Plan will be completed or what the actual costs of such termination will be.  Any additional expenses associated with the termination of the DB Plan will negatively impact our results of operations in the future.   We recorded ongoing expenses of $182,706 for the quarter ended March 31, 2021, in connection with the freezing of the DP Plan.

Thank you for your consideration on this matter.

Sincerely,

/s/ Garry D. Kleer

Garry D. Kleer

Chairman, President and Chief Executive Officer

United States securities and exchange commission logo
May 20, 2021
Donald Benziger
Executive Vice President and Chief Financial Officer
Richmond Mutual Bancorporation, Inc.
31 North 9th Street
Richmond, Indiana 47374
Re:Richmond Mutual Bancorporation, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2020
Filed March 31, 2021
File No. 001-38956
Dear Mr. Benziger:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the period ending December 31, 2020
Consolidated Balance Sheets, page 69
1.In future filings, please disaggregate mortgage loans held for sale and mortgage loans held
for long-term investment on your consolidated balance sheet.  Refer to ASC 948-310-45-
1.  Please provide us with your proposed disclosure.

Note 1: Nature of Operations and Summary of Significant Accounting Policies, page 74
2.We note that you typically sell most of your conforming fixed-rate one-to-four family
loans you originate, that in 2020 you sold $102.9 million one-to-four family loans as well
as other loans of $4.3 million and recognized a $3.6 million gain on these sales compared
to $0.6 million in 2019.  In future filings, please address the following:

•Disclose how you account for loans held for sale; and

 FirstName LastNameDonald Benziger
 Comapany NameRichmond Mutual Bancorporation, Inc.
 May 20, 2021 Page 2
 FirstName LastName
Donald Benziger
Richmond Mutual Bancorporation, Inc.
May 20, 2021
Page 2
•Disclose the method used in determining the lower of cost or fair value of mortgage
loans (that is, aggregate or individual loan basis).  Refer to ASC 948-310-50-1.

Please provide us with your proposed disclosure.
Note 13. Benefit Plans, page 98
3.You disclose that you are in the process of terminating your participation in the Pentegra
Defined Benefit Plan and that you have accrued approximately $17.5 million for the
withdrawal liability which is subject to change upon final termination.  You also disclose
that one of the risks of participating in a multi-employer plan is if a Company chooses to
stop participating in a multi-employer plan, it may be required to pay an amount based on
the underfunded status of the plan.  Considering the impact of the withdrawal liability
which triggered the net loss of $14.1 million in 2019, please enhance future filings to
more fully address your obligations under the plan upon termination, how you measured
the current liability recognized, and factors that could impact your current accrued
liability.  Refer to ASC 715-80-35 and ASC 450-20-50.

Please provide us with your proposed disclosure.
            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.
            You may contact Dave Irving at (202) 551-3321 or Michelle Miller at (202) 551-3368
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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May 1, 2019

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 RE: Richmond Mutual Bancorporation, Inc.

   Registration Statement on Form S-1 (File number
333-230184)

   Request for Acceleration

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 Richmond Mutual
Bancorporation, Inc. (the “Company”) in requesting that the Company’s above-referenced registration statement
on Form S-1 be declared effective on Monday, May 6, 2019, at 10:00 a.m., Eastern Time, or as soon thereafter as practicable.

        KEEFE, BRUYETTE & WOODS, INC.

        By:

        /s/ Harold T. Hanley III

        Harold T. Hanley III

        Managing Director

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RICHMOND MUTUAL BANCORPORATION, INC.

31 North 9th St.,

Richmond, Indiana 47375

May 1, 2019

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    RE:

        Richmond Mutual Bancorporation, Inc.

        Registration Statement on Form S-1 (File number 333-230184)

        Request for Acceleration

Gentlemen:

We hereby request acceleration of the effective date of the above-captioned Registration Statement to Monday, May 6, 2019 at 10:00
a.m., Eastern Time, or as soon thereafter as practicable.

Please contact Michael Sadow of Silver, Freedman, Taff &
Tiernan LLP at (202) 295-4526 with any questions concerning this matter.

        RICHMOND MUTUAL BANCORPORATION, INC.

    By:

        /s/ Garry D. Kleer

        Garry D. Kleer

        President and Chief Executive Officer

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LAW OFFICES

Silver,
Freedman, Taff & Tiernan LLP

A LIMITED LIABILITY PARTNERSHIP INCLUDING
PROFESSIONAL CORPORATIONS

3299 K STREET, N.W., SUITE 100

WASHINGTON, D.C. 20007

PHONE: (202) 295-4500

FAX: (202) 337-5502 or (202) 337-5503

WWW.SFTLAW.COM

April 22, 2019

VIA EDGAR

Securities and Exchange Commission

Division of Corporate Finance

Washington, D.C. 20549

Attention: Jessica Livingston

    Re:
    Richmond Mutual Bancorporation, Inc.

    Registration Statement on Form S-1

    Submitted March 11, 2019

    File No: 333-230184

Dear Ms. Livingston:

On behalf of Richmond Mutual Bancorporation,
Inc. (the “Company”), we are filing herewith a revised copy of the above-referenced Registration Statement (the
“Revised Registration Statement”) 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 April 5, 2019 (the “Comment Letter”).

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 Revised Registration Statement. All references to page
numbers and captions (other than those in the Staff’s comments) correspond to the page numbers and captions in the Revised
Registration Statement.

Registration Statement on Form S-1

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.

The marketing materials and stock order and certification
form, the forms of which are filed as Exhibits 99.4 and 99.5, respectively, to the Revised Registration Statement, are the only
additional written communications to be provided to potential investors in the offering.

Securities and Exchange Commission

April 22, 2019

Page 2

Summary, page 1

 2. Please provide a summary of the risks related to your
business and this offering.

The Company has revised the disclosure beginning on
page 17 of the Revised Registration Statement in response to the Staff’s comment.

Business Strategy

Lending, page 3

 3. In order to provide investors with a more balanced picture
of your strategy, briefly discuss the relatively unseasoned nature of your loan portfolio and the percentage of commercial loans
and loans in the Columbus, Ohio market.

The Company has revised the disclosure on pages
3 and 57 of the Revised Registration Statement in response to the Staff’s comment.

How We Intend to Use the Proceeds from the Offering, page
7

 4. For balance, disclose here or elsewhere in the summary
that as a result of the one-time termination fee to terminate the Pentegra DB Plan, you expect to report a net loss for the fiscal
year ending December 31, 2019.

The Company has revised the disclosure on pages
7 and 43 of the Revised Registration Statement in response to the Staff’s comment.

Risk Factors

Risks Related to Our Business

Non-compliance with the USA PATRIOT Act, Bank Secrecy Act, or other laws and regulations could result in fines or sanctions, page
25

 5. Please revise to clarify whether you have been subject to fines or other penalties, or have suffered business or reputational
harm, as a result of money laundering activities in the past.

The Company has revised the disclosure on page
26 of the Revised Registration Statement in response to the Staff’s comment.

We will have broad discretion in using the proceeds, page
28

 6. Revise this risk factor to disclose your current return
on equity, your current equity position, and your expected equity position after the offering.

The Company has revised the disclosure on page
29 of the Revised Registration Statement in response to the Staff’s comment.

Securities and Exchange Commission

April 22, 2019

Page 3

Pro Forma Data, page 44

 7. Please tell us how the adjustments related to the termination
of the Pentegra Defined Benefit Plan gives effect to events that are (i) directly attributable to the transaction, (ii) expected
to have a continuing impact on the company, and are (iii) factually supportable pursuant to Rule 11-02(b)(6) of Regulation S-X.
Also, please include a footnote related to these adjustments as required by Rule 11-02(b)(6) of Regulation S-X in your next amendment.

As discussed in the Revised Registration Statement,
approximately $13.3 million ($9.8 million after tax) of the net proceeds from the offering will be used to terminate First Bank
Richmond’s participation in the Pentegra DB Plan. By terminating the Pentegra DB Plan, First Bank Richmond will eliminate
the ongoing expense associated with funding the plan, which for the year ended December 31, 2018 was $1.3 million. Stockholders’
equity will be reduced by the after-tax amount of the funds used to terminate the plan. The Company has revised the disclosure
on pages 50 - 52 of the Revised Registration Statement in response to the Staff’s comment.

* * * * *

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 feel free to contact me at (202) 295-4526, James Fleischer at (202) 295-4507, or Martin Meyrowitz at (202) 295-4527.

    Sincerely,

    /s/ Michael S. Sadow

    Michael S. Sadow, P.C.

 cc: Garry D. Kleer, President and Chief Executive Officer

April 5, 2019
Garry Kleer
Chairman of the Board, President and Chief Executive Officer
Richmond Mutual Bancorporation, Inc.
31 North 9th Street
Richmond, IN 47374
Re:Richmond Mutual Bancorporation, Inc.
Registration Statement on Form S-1
Filed March 11, 2019
File No. 333-230184
Dear Mr. Kleer:
            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.
Registration Statement on Form S-1
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.
Summary, page 1
2.Please provide a summary of the risks related to your business and this offering.

 FirstName LastNameGarry Kleer
 Comapany NameRichmond Mutual Bancorporation, Inc.
 April 5, 2019 Page 2
 FirstName LastNameGarry Kleer
Richmond Mutual Bancorporation, Inc.
April 5, 2019
Page 2
Business Strategy
Lending, page 3
3.In order to provide investors with a more balanced picture of your strategy, briefly discuss
the relatively unseasoned nature of your loan portfolio and the percentage of commercial
loans and loans in the Columbus, Ohio market.
How We Intend to Use the Proceeds from the Offering, page 7
4.For balance, disclose here or elsewhere in the summary that as a result of the one-time
termination fee to terminate the Pentegra DB Plan, you expect to report a net loss for the
fiscal year ending December 31, 2019.
Risk Factors
Risks Related to Our Business
Non-compliance with the USA PATRIOT Act, Bank Secrecy Act, or other laws and regulations
could result in fines or sanctions, page 25
5.Please revise to clarify whether you have been subject to fines or other penalties, or have
suffered business or reputational harm, as a result of money laundering activities in the
past.
We will have broad discretion in using the proceeds, page 28
6.Revise this risk factor to disclose your current return on equity, your current equity
position, and your expected equity position after the offering.
Pro Forma Data, page 44
7.Please tell us how the adjustments related to the termination of the Pentegra Defined
Benefit Plan gives effect to events that are (i) directly attributable to the transaction, (ii)
expected to have a continuing impact on the company, and are (iii) factually supportable
pursuant to Rule 11-02(b)(6) of Regulation S-X.  Also, please include a footnote related to
these adjustments as required by Rule 11-02(b)(6) of Regulation S-X in your next
amendment.
            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.

 FirstName LastNameGarry Kleer
 Comapany NameRichmond Mutual Bancorporation, Inc.
 April 5, 2019 Page 3
 FirstName LastName
Garry Kleer
Richmond Mutual Bancorporation, Inc.
April 5, 2019
Page 3
            You may contact David Irving at 202-551-3321 or John Nolan at 202-551-3492 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Jessica Livingston at 202-551-3448 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services