SecProbe.io

CORRESP
 1
 filename1.htm

 Performance Trust Capital Partners, LLC

 May 12, 2025

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

 Re:

 Security Midwest Bancorp, Inc.

 Registration Statement on Form S-1 (Commission File No. 333-282067)

 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 Security Midwest Bancorp, Inc. in
 requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 1:00 p.m. Eastern Time on May 14, 2025, or as soon thereafter as may be practicable.

 PERFORMANCE TRUST CAPITAL PARTNERS, LLC

 /s/ Allan D. Jean

 Allan D. Jean
 Director, Investment Banking

CORRESP
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 filename1.htm

 SECURITY MIDWEST BANCORP, INC.
 510 E. Monroe
 Springfield, Illinois 62701

 May 12, 2025

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

 Re:

 Security Midwest Bancorp, Inc.

 Registration Statement on Form S-1 (Commission File No. 333-282067)

 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, Security Midwest 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 1:00 p.m. Eastern Time, or as soon thereafter as is practicable.

 Please contact Ned Quint of Luse Gorman, PC at (202) 274-2007 if you have any questions concerning this matter.

 Very truly yours,

 /s/ Stephan P. Antonacci
 Stephan P. Antonacci
 President and Chief Executive Officer

CORRESP
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filename1.htm

    Performance Trust Capital Partners, LLC

    November 12, 2024

    Via Edgar

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Re: Security Midwest Bancorp, Inc.

          Registration Statement on Form S-1 (Commission File No. 333-282067)

          Withdrawal of Request for Acceleration of Effective Date

    Ladies and Gentlemen:

    Reference is made to our letter dated November 7, 2024, filed as correspondence via EDGAR on November 7, 2024, in which we joined in the
      request of Security Midwest Bancorp, Inc. to accelerate the effective date of the above-referenced Registration Statement for Tuesday, November 12, 2024 at 3:00 p.m. Eastern time, in accordance with Rule 461 under the Securities Act of 1933, as
      amended. We are no longer requesting that such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

    PERFORMANCE TRUST CAPITAL PARTNERS, LLC

    /s/ Allan D. Jean

    Allan D. Jean

    Director, Investment Banking

CORRESP
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filename1.htm

    SECURITY MIDWEST BANCORP, INC.

    510 E. Monroe

    Springfield, Illinois 62701

    November 12, 2024

    Via Edgar

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Re: Security Midwest Bancorp, Inc.

          Registration Statement on Form S-1 (Commission File No. 333-282067)

          Withdrawal of
          Request for Acceleration of Effective Date

    Ladies and Gentlemen:

    Reference is made to our letter dated November 7, 2024, filed as correspondence via EDGAR on November 7, 2024, in which we requested the
      acceleration of the effective date of the above-referenced Registration Statement for Tuesday, November 12, 2024 at 3:00 p.m. Eastern time, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer requesting that
      such Registration Statement be declared effective at this time and we hereby formally withdraw our request for acceleration of the effective date.

    Security Midwest Bancorp, Inc. represents that none of the 1,256,375 shares of common stock subject to the Registration Statement were sold
      or will be sold as of the date hereof and will not be sold unless and until the Registration Statement covering such shares of common stock is declared effective by the Securities and Exchange Commission.

    Please contact Ned Quint of Luse Gorman, PC at (202) 274-2007 if you have any questions concerning this matter.

    Very truly yours,

    /s/ Stephan P. Antonacci

    Stephan P. Antonacci

    President and Chief Executive Officer

CORRESP
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filename1.htm

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) 274-2007

nquint@luselaw.com

 November 7, 2024

Via EDGAR

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

Re:
 Security Midwest Bancorp, Inc.

Pre-Effective Amendment No. 1 to the Registration Statement on Form S-1

 Filed October 31, 2024

File No. 333-282067

To Whom It May Concern:

 Pursuant to our phone
conversation on November 6, 2024, with the staff of the Division of Corporation Finance of the Securities and Exchange Commission regarding Security Midwest Bancorp, Inc.’s (the “Company”)
Pre-Effective Amendment No. 1 to the Registration Statement on Form S-1, filed herewith is the Company’s Pre-Effective
Amendment No. 2 to Registration Statement on Form S-1, including exhibits (the “Amended Registration Statement”), which is marked pursuant to SEC Rule 472. The Amended Registration Statement has
been revised to annualize the charge-offs in the selected data table at or for the six months ended June 30, 2024 and 2023.

 We trust
the foregoing is responsive to the Staff’s comments. We request that the Staff advise the undersigned at (202) 274-2007 or Kip A. Weismann of this office at (202)
274-2029 as soon as possible if it has any further comments.

Respectfully,

Ned Quint

 Enclosure

cc:
 John Stickel, SEC

Eric Envall, SEC

 Michael
Henderson, SEC

 John Spitz, SEC

Stephan P. Antonacci, Security Midwest Bancorp, Inc.

Kip A. Weismann, Esq.

CORRESP
1
filename1.htm

    Performance Trust Capital Partners, LLC

    November 7, 2024

    Via Edgar

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Re: Security Midwest Bancorp, Inc.

          Registration Statement on Form S-1 (Commission File No. 333-282067)

          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 Security Midwest 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 November 12, 2024, or as soon thereafter as may be practicable.

    PERFORMANCE TRUST CAPITAL PARTNERS, LLC

    /s/ Allan D. Jean

    Allan D. Jean

    Director, Investment Banking

CORRESP
1
filename1.htm

    SECURITY MIDWEST BANCORP, INC.

    510 E. Monroe

    Springfield, Illinois 62701

    November 7, 2024

    Via Edgar

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Re: Security Midwest Bancorp, Inc.

          Registration Statement on Form S-1 (Commission File No. 333-282067)

          Request for Acceleration of Effective Date

    Ladies and Gentlemen:

    In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, Security Midwest Bancorp, Inc. hereby requests
      that the effective date of the above referenced Registration Statement on Form S-1, as amended, be accelerated to November 12, 2024 at 3:00 p.m. Eastern Time, or as soon thereafter as is practicable.

    Please contact Ned Quint of Luse Gorman, PC at (202) 274-2007 if you have any questions concerning this matter.

    Very truly yours,

    /s/ Stephan P. Antonacci

    Stephan P. Antonacci

    President and Chief Executive Officer

CORRESP
1
filename1.htm

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) 274-2007

nquint@luselaw.com

 October 31, 2024

Via EDGAR

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

Re:
 Security Midwest Bancorp, Inc.

Registration Statement on Form S-1

Filed September 12, 2024

File No. 333-282067

To Whom It May Concern:

 On behalf of Security
Midwest 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 comments, transmitted by letter dated October 9, 2024, are reproduced below, followed by the Company’s responses. The Amended
Registration Statement includes a “Recent Developments” section containing unaudited financial information as of and for the three- and nine-month periods ended September 30, 2024, beginning on page 43 of the Prospectus.

Form S-1 filed September 12, 2024

General

 1. Please provide us with supplemental
copies of all written communications, as defined under the Securities Act, that you, or anyone authorized to do so on your behalf, have presented or expect to present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not you retained, or intend to retain, copies of those communications.

 The Company does not intend to provide any written
materials to investors other than the prospectus and the stock order form and the marketing materials that were filed as Exhibits 99.4 and 99.5 to the initial Registration Statement on Form S-1 filed on
September 12, 2024.

 LUSE GORMAN, PC

United States Securities and Exchange Commission

 Division of
Corporation Finance

 October 31, 2024

  Page
 2

 Summary, page 3

2. We note your disclosure on page 116 that depositors of Security Bank have voting rights as to all matters requiring a vote of members, and that upon
completion of the conversion, depositors will no longer have voting rights. Please disclose this in the summary section or include a cross-reference to this section.

Page 4 of the Prospectus has been revised, as requested.

We intend to increase the origination of commercial real estate loans, page 20

3. Please revise this risk factor to discuss, as appropriate, the factors that impact the current Sangamon County, Illinois market 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 on your response.

Page 83 of the Prospectus has been revised to provide additional information with respect to the Company’s primary market area. We
respectfully submit that (i) as indicated in the information added to page 83, the Company’s primary market area is fairly stable, such that it is not a factor in the Company’s ability to grow its commercial real estate loans,
and (ii) the risks related to the Company’s ability to grow any portion of its business (and not merely commercial real estate loans) is described separately under the risk factor on page 24 of the Prospectus entitled “Our
business strategy includes 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. Growing our operations could also cause our expenses to increase
faster than our revenues.” That risk factor has been revised to reflect that general economic conditions can effect Security Bank, s.b.’s growth plans.

We note that page 83 under “Competition” already indicates that “Our ability to compete in our primary market area does
not depend on any existing relationships.” Accordingly, we respectfully submit that related disclosure is not required to be added to the Risk Factors section of the Prospectus.

 LUSE GORMAN, PC

United States Securities and Exchange Commission

 Division of
Corporation Finance

 October 31, 2024

  Page
 3

 How we intend to use the proceeds from the offering, page 43

4. Please revise here to clarify that you will not close the offering if you do not sell the “minimum of 807,500 shares”, as stated on the cover
page. Additionally, please advise us if you will use an escrow consistent with Rule 10b-9.

Page 51 of the Prospectus has been revised, as requested. Consistent with hundreds of mutual-to-stock conversion transactions completed in the past approximately 40 years, and consistent with the well-established “no-action” letter regarding
Trident Securities Incorporated dated November 29, 1985, the Company will not use a separate escrow account with a third party. Rather, as disclosed in the Prospectus, funds submitted for the purpose of purchasing shares will be held in a
segregated account at Security Bank, s.b. and will earn interest until completion or termination of the offering.

 5. Consistent with your disclosure
on page 19, please expand your disclosure here and on page 7 when discussing the $1.8 million costs associated with the planned withdrawal from the multiple employer defined benefit pension plan to clarify that actual cost could be
significantly higher than the estimated cost provided by the plan administrator.

 Pages 7 and 51 of the Prospectus have been
revised, as requested

 Liquidity and Capital Resources, page 71

6. Please revise your disclosure to define the liquidity ratio and how it is calculated.

Page 78 of the Prospectus has been revised, as requested.

Cannabis Banking, page 75

 7. We note
disclosure on page 75 that as of June 30, 2024, loan balances from CRB customers and their associated real estate entities were approximately $14.8 million of your total loan portfolio. However, we also note disclosure on page 5 that loan
balances from CRB customers were approximately $20.3 million of your total loan portfolio as of June 30, 2024. Please revise your disclosures for consistency.

Page 82 of the Prospectus has been revised, as requested.

Allowance for Credit Losses, page 86

 8. Please
revise your filing to disclose net charge-offs to average loans outstanding during the period for both [the] six month periods ended June 30, 2024 and June 30, 2023 on an annualized basis.

The table on page 93 of the Prospectus has been revised, as requested.

*  *  *  *  *

 LUSE GORMAN, PC

United States Securities and Exchange Commission

 Division of
Corporation Finance

 October 31, 2024

  Page
 4

 We trust the foregoing is responsive to the Staff’s comments. We request that the Staff
advise the undersigned at (202) 274-2007 or Kip A. Weismann of this office at (202) 274-2029 as soon as possible if it has any further comments.

Respectfully,

Ned Quint

 Enclosure

cc:
 John Stickel, SEC

Eric Envall, SEC

 Michael
Henderson, SEC

 John Spitz, SEC

Stephan P. Antonacci, Security Midwest Bancorp, Inc.

Kip A. Weismann, Esq.

October 9, 2024
Stephan P. Antonacci
President and Chief Executive Officer
Security Midwest Bancorp, Inc.
510 E. Monroe
Springfield, IL 62701
Re:Security Midwest Bancorp, Inc.
Registration Statement on Form S-1
Filed September 12, 2024
File No. 333-282067
Dear Stephan P. Antonacci:
            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.
Form S-1 filed September 12, 2024
General
1.Please provide us with supplemental copies of all written communication, as defined
under the Securities Act, that you, or anyone authorized to do so on your behalf, have
presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.
Summary, page 3
2.We note your disclosure on page 116 that depositors of Security Bank have voting
rights as to all matters requiring a vote of members, and that upon completion of the
conversion, depositors will no longer have voting rights. Please disclose this in
the summary section or include a cross-reference to this section.

October 9, 2024
Page 2
We intend to increase the origination of commercial real estate loans, page 20
3.Please revise this risk factor to discuss, as appropriate, the factors that impact the
current Sangamon County, Illinois market 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.
How we intend to use the proceeds from the offering , page 43
4.Please revise here to clarify that you will not close the offering if you do not sell the
"minimum of 807,500 shares", as stated on the cover page. Additionally, please advise
us if you will use an escrow consistent with Rule 10b-9.
5.Consistent with your disclosure on page 19, please expand your disclosure here and
on page 7 when discussing the $1.8 million costs associated with the planned
withdrawal from the multiple employer defined benefit pension plan to clarify
that actual cost could be significantly higher than the estimated cost provided by the
plan administrator.
Liquidity and Capital Resources, page 71
6.Please revise your disclosures to define the liquidity ratio and how it is calculated.
Cannabis Banking, page 75
7.We note disclosure on page 75 that as of June 30, 2024, loan balances from CRB
customers and their associated real estate entities were approximately $14.8 million of
your total loan portfolio. However, we also note disclosure on page 5 that loan
balances from CRB customers were approximately $20.3 million of your total loan
portfolio as of June 30, 2024. Please revise your disclosures for consistency.
Allowance for Credit Losses, page 86
8.Please revise your filing to disclose net charge-offs to average loans outstanding
during the period for the both six month periods ended June 30, 2024 and June 30,
2023 on an annualized basis.
            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 Michael Henderson at 202-551-3364 or John Spitz at 202-551-3484 if
you have questions regarding comments on the financial statements and related

October 9, 2024
Page 3
matters. Please contact John Stickel at 202-551-3324 or Eric Envall at 202-551-3234 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance