SecProbe.io

CORRESP
 1
 filename1.htm

 August 8, 2025

 Via Edgar

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Seneca Bancorp,
 Inc.

 Registration Statement
 on Form S-1 (Commission File No. 333-288044)

 Request for Acceleration
 of Effective Date

 To Whom It May Concern:

 Seneca Bancorp, Inc. hereby requests that the effective
date of the above referenced Registration Statement on Form S-1, as amended, be accelerated to August 12, 2025, at 3:00 p.m., Eastern
time, or as soon thereafter as is practicable.

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

 Sincerely,

 /s/ Joseph
 G. Vitale

 Joseph G.
 Vitale

 President
 and Chief Executive Officer

CORRESP
 1
 filename1.htm

 August 8, 2025

 Via Edgar

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Re: Seneca Bancorp, Inc.
 Registration Statement on Form S-1 (Registration Number 333-288044)

 Request for Acceleration of Effectiveness

 To Whom It May Concern:

 In accordance with Rule 461 of Regulation C promulgated
under the Securities Act of 1933, we hereby join Seneca 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 August 12, 2025, or as soon thereafter as may
be practicable.

 KEEFE, BRUYETTE
 & WOODS, INC.

 By:
 /s/ Robin Suskind

 Robin Suskind

 Managing Director

CORRESP
 1
 filename1.htm

 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 EMAIL

 (202) 274-2010
 bazoff@luselaw.com

 July 31, 2025

 Via EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

 Re: Seneca Bancorp, Inc.

 Registration Statement
on Form S-1

 Filed June 13, 2025,
as amended on July 25, 2025

 File No. 333-288044

 On behalf of Seneca Bancorp, Inc. (the "Company"),
filed herewith is its Pre-Effective Amendment No. 2 to the 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 July
30, 2025, are reproduced below, followed by the Company's responses.

 Amendment No. 1 to Registration Statement on Form S-1

 General

 1. We note your amended disclosure that Seneca Financial Corp's common stock is quoted on the OTCID Market. We also note your disclosure
on the prospectus supplement cover page that Seneca Financial Corp's common stock is quoted on the OTC Pink Market. Please revise for
consistency.

 References to the OTC Pink Market have been updated
to make reference to the OTCID Market on the cover page of the prospectus supplement and the cover page of the stockholder proxy statement/prospectus
in response to this comment.

 Luse Gorman, PC

 United States Securities and Exchange Commission

 Division of Corporation Finance

 July 31, 2025

 Page 2

 Financial Position and Results of Operations of Our Wealth Management
Business Segment, page 72

 1. We note that your assets under management ("AUM") increased from $82.1 million at December 31, 2023 to $233.6 million
at December 31, 2024 and the increase was primarily due to your acquisition of a $133.9 million retirement plan book of business in October
2023. Please revise your disclosure to clarify the reason for the period-end amount of your AUM at December 31, 2023 being lower
than the amount acquired in October 2023.

 While the acquisition agreement was executed in
October 2023, the transfer of customer assets to Financial Quest described above was completed in February 2024. At the time of transfer,
the value of those assets totaled $131.6 million. At March 31, 2025, the value of those assets was $133.9 million. In response to this
comment, disclosure on pages 3, 23, 59, 70, 72 and 93 of the prospectus has been updated to clarify that the acquisition was completed
in February 2024 and the value of the acquired assets under management was $131.6 million at that time.

 * * *

 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: Joseph Vitale, President and CEO, Seneca Bancorp, Inc.

 Madeleine Joy Mateo, SEC

 Eric Envall, SEC

 Jee Yeon Ahn, SEC

 Amit Pande, SEC

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 30, 2025

Joseph Vitale
President and Chief Executive Officer
Seneca Bancorp, Inc.
35 Oswego Street
Baldwinsville, NY 13027

 Re: Seneca Bancorp, Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed July 25, 2025
 File No. 333-288044
Dear Joseph Vitale:

 We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our July 9, 2025
letter.

Amendment No. 1 to Registration Statement on Form S-1
General

1. We note your amended disclosure that Seneca Financial Corp's common
stock is
 quoted on the OTCID Market. We also note your disclosure on the
prospectus
 supplement cover page that Seneca Financial Corp's common stock is
quoted on the
 OTC Pink Market. Please revise for consistency.
Financial Position and Results of Operations of Our Wealth Management Business
Segment,
page 72

2. We note that your assets under management ("AUM") increased from $82.1
million at
 December 31, 2023 to $233.6 million at December 31, 2024 and the
increase was
 primarily due to your acquisition of a $133.9 million retirement plan
book of business
 July 30, 2025
Page 2

 in October 2023. Please revise your disclosure to clarify the reason for
the period-end
 amount of your AUM at December 31, 2023 being lower than the amount
acquired in
 October 2023.
 Please contact Jee Yeon Ahn at 202-551-3673 or Amit Pande at
202-551-3423 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Eric Envall at 202-551-3234 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Benjamin M. Azoff, Esq.
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 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 EMAIL

 (202) 274-2010
 bazoff@luselaw.com

 July 25, 2025

 Via EDGAR

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, DC 20549

 Re: Seneca Bancorp, Inc.

 Registration
Statement on Form S-1

 Filed
June 13, 2025

 File
No. 333-288044

 On behalf of Seneca
Bancorp, Inc. (the "Company"), filed herewith is its Pre-Effective Amendment No. 1 to the 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 July 9, 2025, 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 six-month periods ended June 30, 2025 and 2024.

 Registration Statement on Form S-1
filed June 13, 2025

 Cover Page

 1. We note that the Seneca Savings
 401(k) Plan is offering participation interests of up to 135,438 shares of your common
 stock. As such, please include Seneca Savings 401(k) Plan as a co-registrant on the
 cover page.

 The cover page has been
revised as requested in response to this comment.

 2. Please revise your disclosure on
 the cover page of the prospectus and prospectus supplement to clarify if the offering
 is contingent on receipt of approval to be quoted on the OTCQX Market.

 The cover pages of
the prospectus and prospectus supplement have been revised as requested in response to this comment. Additional disclosure has also been
added to pages 11 and 49 of the prospectus in response to this comment.

 Luse Gorman,
PC

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 July 25, 2025

 Page 2

 Our Business, page 2

 3. We note your disclosure here and
 throughout that you purchased land in Clay, New York and intend to establish a future branch
 office on this property. Please revise your discussion regarding this site to provide more
 details of the status of development of the future branch office, including what actions,
 if any that you have taken beyond the land purchase, and any anticipated opening date.

 Additional disclosure
has been added to pages 2, 4, 22, 60, 77, 78 and 96 of the prospectus in response to this comment.

 Management's Discussion and Analysis
of Financial Condition and Results of Operations Comparison of Results of Operations, page 58

 4. We note your disclosure on page F-64
 that you have two reportable segments, Seneca Savings and Financial Quest. Please revise
 your Management's Discussion and Analysis section to expand the discussion of your operating
 results for each period presented at the segment level, including significant factors materially
 affecting your segment results. Refer to Item 303(b) of Regulation S-K.

 Additional disclosure
has been added to pages 71-72 of the prospectus in response to this comment.

 5. We note your disclosure on page 21
 that you had approximately $223 million in assets under management ("AUM") at
 March 31, 2025, and generated approximately 46% of your non-interest income from your
 wealth management activities for the three months ended March 31, 2025. Please revise
 to quantify your AUM as of each period end presented and discuss any significant trends or
 concentrations within your AUM, as well as related drivers impacting your revenues and operating
 results from wealth management activities.

 Additional disclosure
has been added to pages 71-72 of the prospectus in response to this comment.

 Luse Gorman,
PC

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 July 25, 2025

 Page 3

 Transactions with Certain Related
Persons, page 100

 6. We note your disclosure that Seneca
 Savings makes certain loans through an employee loan program pursuant to which loans are
 made at reduced rates. For loans made under the employee loan program to officers, directors
 and other related parties exceeding the threshold amount, please provide the information
 required by Item 404(a) of Regulation S-K.

 Additional disclosure
has been added to page 110 of the prospectus in response to this comment.

 Director Compensation, page 106

 7. Please confirm that the Director
 Compensation Table figures include the fees earned for serving on the boards of Seneca Financial
 MHC and Seneca Savings Insurance Agency, Inc. in 2024 or revise the table to include
 those fees.

 Additional disclosure
has been added to page 116 of the prospectus in response to this comment.

 Table of Contents, page F-1

 8. Please revise your filing to provide
 relevant subsequent event disclosures required by ASC 855-10-50.

 Additional disclosure
has been added to page F-67 of the prospectus in response to this comment.

 9. We note that the registrant for
 this offering is Seneca Bancorp, Inc. which was recently formed; however, the financial
 statements included in the offering are for Seneca Financial Corp. and subsidiaries. Please
 revise to include financial statements of the registrant or revise to disclose why they are
 not required to be filed.

 Additional disclosure
has been added to page F-1 of the prospectus in response to this comment.

 Luse Gorman,
PC

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 July 25, 2025

 Page 4

 Note 2. Summary of Significant
Accounting Policies Allowance for Credit Losses – Loans, page F-14

 10. We note that loans are charged
 off when management believes the uncollectibility of a loan balance is confirmed. Please
 revise to expand your charge-off policy for recognizing write-offs within the allowance for
 credit losses and clarify the criteria for when a loan is deemed uncollectible. Refer to
 ASC 326-20-50-17.

 Additional disclosure
has been added to page F-14 of the prospectus in response to this comment.

 Note 17. Segment Information,
page F-66

 11. We note your disclosure on page F-64
 that for each of the two reportable segments, compensation and employee benefits are significant
 segment expenses. We note from page F-66 that your line item of Other expense for Financial
 Quest represented approximately 31% of total segment noninterest expense for the year ended
 December 31, 2024. Please revise your disclosure to provide a qualitative description
 of the composition of Other segment item. Refer to ASC 280-10-50-26B.

 Additional disclosure
has been added to page F-64 of the prospectus in response to this comment.

 Exhibits

 12. Please include the participation
 interests in the Exhibit 5 legal opinion.

 Exhibit 5 has been revised
as requested in response to this comment.

 * * *

 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: Joseph Vitale, President and CEO,
Seneca Bancorp, Inc.

 Madeleine
Joy Mateo, SEC

 Eric
Envall, SEC

 Jee
Yeon Ahn, SEC

 Amit
Pande, SEC

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 9, 2025

Jospeh Vitale
President and Chief Executive Officer
Seneca Bancorp, Inc.
35 Oswego Street
Baldwinsville, NY 13027

 Re: Seneca Bancorp, Inc.
 Registration Statement on Form S-1
 Filed June 13, 2025
 File No. 333-288044
Dear Jospeh Vitale:

 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 filed June 13, 2025
Cover Page

1. We note that the Seneca Savings 401(k) Plan is offering participation
interests of up to
 135,438 shares of your common stock. As such, please include Seneca
Savings 401(k)
 Plan as a co-registrant on the cover page.
2. Please revise your disclosure on the cover page of the prospectus and
prospectus
 supplement to clarify if the offering is contingent on receipt of
approval to be quoted
 on the OTCQX Market.
 July 9, 2025
Page 2
Our Business, page 2

3. We note your disclosure here and throughout that you purchased land in
Clay, New
 York and intend to establish a future branch office on this property.
Please revise your
 discussion regarding this site to provide more details of the status of
development of
 the future branch office, including what actions, if any that you have
taken beyond the
 land purchase, and any anticipated opening date.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Comparison of Results of Operations, page 58

4. We note your disclosure on page F-64 that you have two reportable
segments, Seneca
 Savings and Financial Quest. Please revise your Management's Discussion
and
 Analysis section to expand the discussion of your operating results for
each period
 presented at the segment level, including significant factors materially
affecting your
 segment results. Refer to Item 303(b) of Regulation S-K.
5. We note your disclosure on page 21 that you had approximately $223
million in assets
 under management ( AUM ) at March 31, 2025, and generated
approximately 46% of
 your non-interest income from your wealth management activities for the
three
 months ended March 31, 2025. Please revise to quantify your AUM as of
each period
 end presented and discuss any significant trends or concentrations
within your AUM,
 as well as related drivers impacting your revenues and operating results
from wealth
 management activities.
Transactions with Certain Related Persons, page 100

6. We note your disclosure that Seneca Savings makes certain loans through
an
 employee loan program pursuant to which loans are made at reduced rates.
For loans
 made under the employee loan program to officers, directors and other
related parties
 exceeding the threshold amount, please provide the information required
by Item
 404(a) of Regulation S-K.
Director Compensation, page 106

7. Please confirm that the Director Compensation Table figures include the
fees earned
 for serving on the boards of Seneca Financial MHC and Seneca Savings
Insurance
 Agency, Inc. in 2024 or revise the table to include those fees.
Table of Contents, page F-1

8. Please revise your filing to provide relevant subsequent event
disclosures required by
 ASC 855-10-50.
9. We note that the registrant for this offering is Seneca Bancorp, Inc.
which was
 recently formed; however, the financial statements included in the
offering are for
 Seneca Financial Corp. and subsidiaries. Please revise to include
financial statements
 of the registrant or revise to disclose why they are not required to be
filed.
 July 9, 2025
Page 3
Note 2. Summary of Significant Accounting Policies
Allowance for Credit Losses Loans, page F-14

10. We note that loans are charged off when management believes the
uncollectibility of a
 loan balance is confirmed. Please revise to expand your charge-off
policy for
 recognizing write-offs within the allowance for credit losses and
clarify the criteria for
 when a loan is deemed uncollectible. Refer to ASC 326-20-50-17.
Note 17. Segment Information, page F-66

11. We note your disclosure on page F-64 that for each of the two reportable
segments,
 compensation and employee benefits are significant segment expenses. We
note from
 page F-66 that your line item of Other expense for Financial Quest
represented
 approximately 31% of total segment noninterest expense for the year
ended December
 31, 2024. Please revise your disclosure to provide a qualitative
description of the
 composition of Other segment item. Refer to ASC 280-10-50-26B.
Exhibits

12. Please include the participation interests in the Exhibit 5 legal
opinion.

 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 Jee Yeon Ahn at 202-551-3673 or Amit Pande at
202-551-3423 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Eric Envall at 202-551-3234 with
any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Benjamin M. Azoff, Esq.
</TEXT>
</DOCUMENT>