SecProbe.io

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 February 13, 2026

 VIA EDGAR

 United States Securities and Exchange Commission
 Division of Corporation Finance
 100 F. Street, N.E.
 Washington, D.C. 20549
 Attention: Ms. Aisha Adegbuyi, Attorney Advisor

 Re:

 South Plains Financial, Inc.

 Registration Statement on Form S-4
 Filed January 30, 2026
 File No. 333-293068
 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), South Plains Financial, Inc., a
 Texas corporation (the “Registrant”), hereby requests acceleration by the U.S. Securities and Exchange Commission of the effective date of the above-captioned Registration Statement on Form S-4, as amended (the “Registration Statement”).  The
 Registrant respectfully requests that the Registration Statement become effective under the Securities Act as of 4:00 p.m., Eastern Time, on Wednesday, February 18, 2026, or as soon thereafter as practicable.

 Please contact Heather A. Eastep of Hunton Andrews Kurth LLP, the Registrant’s counsel, at (202) 955-1954 with any questions you may
 have concerning this request.  In addition, please notify Mrs. Eastep when this request for acceleration has been granted.

 Thank you for your assistance in this matter.

 Sincerely,

 SOUTH PLAINS FINANCIAL, INC.

 By:

 /s/ Curtis C. Griffith

 Name:

 Curtis C. Griffith

 Title:

 Chairman and Chief Executive Officer

 cc:

 Heather A. Eastep, Hunton Andrews Kurth LLP

 Curtis C. Griffith, South Plains Financial, Inc.

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 February 10, 2026

Curtis C. Griffith
Chief Executive Officer
South Plains Financial, Inc.
5219 City Bank Parkway
Lubbock, TX

 Re: South Plains Financial, Inc.
 Registration Statement on Form S-4
 Filed January 30, 2026
 File No. 333-293068
Dear Curtis C. Griffith:

 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: Heather Eastep, Esq.
</TEXT>
</DOCUMENT>

CORRESP
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      South Plains Financial, Inc.

      5219 City Bank Parkway

      Lubbock, Texas 79407

      October 10, 2024

      Via EDGAR

      U.S. Securities and Exchange Commission

      Division of Corporation Finance

      100 F. Street, N.E.

      Washington, D.C. 20549

      Attention: John Stickel

            Re:

              South Plains Financial, Inc.

      Registration Statement on Form S-3 (File No. 333-282422)

      Ladies and Gentlemen:

      Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), South Plains Financial, Inc., a Texas corporation (the “Registrant”), hereby requests that the effective date for the
        above-referenced Registration Statement on Form S-3 (File No. 333-282422) (the “Registration Statement”) be accelerated so that it will be declared effective under the Securities Act at 9:00 a.m., Eastern Time, on Tuesday, October 15, 2024 or as
        soon thereafter as practicable.  This request shall supersede and replace any previously submitted request for accelerated effectiveness of the Registration Statement.

      Please contact Nathaniel B. Jones of Hunton Andrews Kurth LLP, the Registrant’s legal counsel, at (704) 378-4709 with any questions or comments.  In addition, please notify Mr. Jones via telephone when this request
        for acceleration has been granted.

      Thank you for your assistance in this matter.

              Sincerely,

              South Plains Financial, Inc.

              By:

            /s/ Steven B. Crockett

              Steven B. Crockett

              Chief Financial Officer and Treasurer

              cc:
              Nathaniel B. Jones, Hunton Andrews Kurth LLP

CORRESP
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    South Plains Financial, Inc.

    5219 City Bank Parkway

    Lubbock, Texas 79407

    October 9, 2024

    Via EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    100 F. Street, N.E.

    Washington, D.C. 20549

    Attention: John Stickel

              Re:

              South Plains Financial, Inc.

              Registration Statement on Form S-3 (File No. 333-282422)

    Ladies and Gentlemen:

    Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), South Plains Financial, Inc., a Texas corporation (the “Registrant”), hereby requests that the effective date for the
      above-referenced Registration Statement on Form S-3 (File No. 333-282422) be accelerated so that it will be declared effective under the Securities Act at 9:00 a.m., Eastern Time, on Monday, October 14, 2024 or as soon thereafter as practicable.

    Please contact Nathaniel B. Jones of Hunton Andrews Kurth LLP, the Registrant’s legal counsel, at (704) 378-4709 with any questions or comments.  In addition, please notify Mr. Jones via telephone when this request for
      acceleration has been granted.

    Thank you for your assistance in this matter.

          Sincerely,

            South Plains Financial, Inc.

          By:

            /s/ Steven B. Crockett

            Steven B. Crockett

            Chief Financial Officer and Treasurer

            cc:

          Nathaniel B. Jones, Hunton Andrews Kurth LLP

October 8, 2024
Steven B. Crockett
Chief Financial Officer
South Plains Financial, Inc.
5219 City Bank Parkway
Lubbock, Texas 76407
Re:South Plains Financial, Inc.
Registration Statement on Form S-3
Filed September 30, 2024
File No. 333-282422
Dear Steven B. Crockett:
            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 John Stickel at 202-551-3324 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

July 26, 2024
Steven B. Crockett
Chief Financial Officer
South Plains Financial, Inc.
5219 City Bank Parkway
Lubbock, TX 79407
Re:South Plains Financial, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-38895
Dear Steven B. Crockett:
            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

CORRESP
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              5219 City Bank Parkway

              PO Box 5060

              Lubbock, Texas 79408-5060

              Phone (806) 792-7101

    July 18, 2024

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Finance

    100 F Street, NE

    Washington, DC 20549

              Attention:

              Jee Yeon Ahn

    John Nolan

              Re:

              South Plains Financial, Inc.

    Form 10-K for Fiscal Year Ended December 31, 2023

    File No. 001-38895

    Ladies and Gentlemen:

    This letter is respectfully submitted by South Plains Financial, Inc. (the “Company”) in response to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission by letter
      dated June 28, 2024 (the “Comment Letter”), with respect to the above-referenced Annual Report on Form 10-K for the year ended December 31, 2023 (the “Form 10-K”).

    For the convenience of the Staff’s review, we have set forth the comments contained in the Comment Letter in bold and italics, followed by the responses of the Company.  The numbered responses set out below correspond to the numbered comments from
      the Staff.

    Form 10-K for Fiscal Year Ended December 31, 2023

    Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Loan Portfolio, page 48

          1.

            We note the tabular disclosure on page 48 detailing the composition of your loans held for investment portfolio, which includes commercial real estate (“CRE”) with approximately 35.9% of your
              total loan portfolio as of December 31, 2023. However, you disclose under Risk Factors on page 26 that your non-owner occupied CRE loans totaled approximately 40.1% of your total loan portfolio as of December 31, 2023. In addition, we note
              that the total amount of your CRE portfolio in your earnings presentation (e.g., slide 16 of Exhibit 99.2 from the January 26, 2024 Form 8-K) does not agree to the amount presented on page 48. Please tell us and revise future filings to
              address the following:

          •

            Reconcile these disclosures or explain why there appears to be discrepancies in these disclosures about your CRE portfolio;

          •

            Clearly quantify and discuss your CRE composition, as well as whether and how that composition has changed over the periods presented; and

          •

            Disaggregate your CRE loans into owner occupied and non-owner occupied.

    Response:  The Company respectfully acknowledges the Staff’s comment and advises the Staff that the Company is committed to providing complete and accurate disclosures of our loan portfolio including
      characteristics that are material to an investor’s understanding of the Company’s loan portfolio.

    We advise the Staff that, on page 26 of the Form 10-K, the Company included a Risk Factors noting that 40.1% of the Company’s loan portfolio consists of non-owner-occupied commercial real estate, which would be
      approximately $1,210,246,000.  Furthermore, page 48 of the Form 10-K indicates that the Company has approximately $1,081,056,000 in commercial real estate loans, which is 35.9% of the Company’s loan portfolio.  Importantly, the Risk Factor on page 26
      of the Form 10-K also includes the Company’s construction loans of approximately $129,190,000, which, when combined with the Company’s commercial real estate loans, equals a combined amount of $1,210,246,000, or 40.1% of the Company’s loan
      portfolio.  As noted on page 50 of the Form 10-K, construction loans made by the Company are residential construction loans that are made to developers, builders, or end-users for the construction of single-family properties.  This total agrees to
      the amount disclosed in the Risk Factor on page 26 of the Form 10-K.  The Company will consider whether this Risk Factor description can be improved in future filings to encompass both the Company’s commercial real estate loans and the Company’s
      construction loans as deemed material to an investor’s understanding of these risks.

    Further, page 16 of the earnings presentation included as Exhibit 99.2 from the Company’s Current Report on Form 8-K filed on January 26, 2024 (the “Earnings Presentation”) stated that the Company’s total commercial
      real estate portfolio was $1,108.9 million.  This slide was intended to show commercial real estate non-construction and development loans that were both owner-occupied and nonowner-occupied.  Slide 9 of the Earnings Release details out the portfolio
      with “Owner/Occ.” of $341.1 million, “Nonowner/Occ.” of $548.2 million, and “Multi-Family” of $219.6 million, all of which equals a combined amount of $1,108.9 million.  The Company will further consider whether this slide in future filings should be
      more clearly labeled instead of using the “CRE” title in order to provide greater clarity to investors.

    Nonowner-occupied commercial real estate loans increased $137.4 million, or 12.8%, to $1.21 billion as of December 31, 2023 from $1.07 billion as of December 31, 2022. The increase was primarily driven by an increase
      of $52.0 million in commercial and residential land development loans, an increase of $57.7 million in multi-family property loans, an increase of $24.7 million in office loans, and $34.6 million in other loans, partially offset by a decrease of
      $24.3 million in residential construction loans. Nonowner-occupied commercial real estate are made up of income-producing properties and construction, acquisition, and development properties. As of December 31, 2023, total income-producing property
      loans totaled $767.8 million and was comprised of $219.6 million of multi-family property loans, $171.7 million of retail property loans, $131.9 million of office property loans, $69.3 million in hospitality loans, and $175.3 million in other
      property loans. As of December 31, 2023, total construction, acquisition, and development property loans totaled $442.4 million and was comprised of $129.2 million in residential construction property loans and $313.2 million of commercial
      construction and other land development loans.  The Company will begin further disaggregating the composition of its commercial real estate loan portfolio to help aid investor’s understanding of these loans in future filings if such information, at
      that level of detail, materially provides meaningful information to an investor’s understanding of the Company’s commercial real estate loan portfolio.

    Finally, owner-occupied commercial real estate loans are reported in the “Commercial-general” or “Commercial-specialized” loan categories disclosed throughout the Form 10-K, as the repayment of these loans is generally
      dependent on the operations of the commercial borrower’s business rather than on income-producing properties or the sale of the properties.  Owner-occupied commercial real estate loans totaled $341.1 million at December 31, 2023 as compared to $269.2
      million at December 31, 2022.

      2

    The Company will begin further disaggregating the composition of its commercial real estate loan portfolio to help aid investor’s understanding of these loans in future filings if such information, at that level of
      detail, materially provides meaningful information to an investor’s understanding of the Company’s commercial real estate loan portfolio.

          2.

            Additionally, given the significance of CRE loans in your total loan portfolio, please revise future filings to further disaggregate the composition of these loans to disclose and quantify by
              key borrower type (e.g., multifamily, warehouse, office, retail, etc.), geographic concentrations in your Texas and New Mexico markets, as well as current weighted average and/or range of loan-to-value ratios, and other characteristics (e.g.,
              occupancy rates, etc.) material to an investor’s understanding of these loans.  See Item 303 of Regulation S-K.

    Response:  The Company respectfully acknowledges the Staff’s comment and advises the Staff that, commencing with the Company’s forthcoming Quarterly Report on Form 10-Q for the three months ended June 30, 2024,
      the Company will begin further disaggregating the composition of its commercial real estate loans as well as disclosing and quantifying characteristics to help aid investor’s understanding of these loans in future filings.  Other loan portfolio
      characteristics such as geographic concentrations, weighted average and/or range of loan-to-value ratios, and other characteristics, such as occupancy rates, will be evaluated by the Company and disclosed in future filings as such data becomes
      available and if such data, at that level of detail, materially provides meaningful information to an investor’s understanding of the Company’s loan portfolio.

    * * * * *

    The Company believes this letter provides a complete response to the Comment Letter.  If you have questions regarding the foregoing or require additional information, please feel free to contact me at (806) 792-7101.

    Sincerely,

            By:

            /s/ Steven B. Crockett

            Steven B. Crockett

            Chief Financial Officer and Treasurer

    3

United States securities and exchange commission logo
June 28, 2024
Steven B. Crockett
Chief Financial Officer
South Plains Financial, Inc.
5219 City Bank Parkway
Lubbock, TX 79407
Re:South Plains Financial, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-38895
Dear Steven B. Crockett:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Loan Portfolio, page 48
1.We note the tabular disclosure on page 48 detailing the composition of your loans held for
investment portfolio, which includes commercial real estate (“CRE”) with approximately
35.9% of your total loan portfolio as of December 31, 2023. However, you disclose under
Risk Factors on page 26 that your non-owner occupied CRE loans totaled approximately
40.1% of your total loan portfolio as of December 31, 2023. In addition, we note that the
total amount of your CRE portfolio in your earnings presentation (e.g., slide 16 of Exhibit
99.2 from the January 26, 2024 Form 8-K) does not agree to the amount presented on
page 48. Please tell us and revise future filings to address the following:

•Reconcile these disclosures or explain why there appears to be discrepancies in these
disclosures about your CRE portfolio;
•Clearly quantify and discuss your CRE composition, as well as whether and how that
composition has changed over the periods presented; and

 FirstName LastNameSteven B. Crockett
 Comapany NameSouth Plains Financial, Inc.
 June 28, 2024 Page 2
 FirstName LastName
Steven B. Crockett
South Plains Financial, Inc.
June 28, 2024
Page 2
•Disaggregate your CRE loans into owner occupied and non-owner occupied.
2.Additionally, given the significance of CRE loans in your total loan portfolio, please
revise future filings to further disaggregate the composition of these loans to disclose and
quantify by key borrower type (e.g., multifamily, warehouse, office, retail, etc.),
geographic concentrations in your Texas and New Mexico markets, as well as current
weighted average and/or range of loan-to-value ratios, and other characteristics (e.g.,
occupancy rates, etc.) material to an investor’s understanding of these loans. See Item 303
of Regulation S-K.
            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.
            Please contact Jee Yeon Ahn at 202-551-3673 or John Nolan at 202-551-3492 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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    South Plains Financial, Inc.

    5219 City Bank Parkway

    Lubbock, Texas  79407

    November 25, 2020

    Via EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    100 F. Street, N.E.

    Washington, D.C. 20549

    Attention: Tonya K. Aldave

            Re:

            South Plains Financial, Inc.

            Registration Statement on Form S-4 (File No. 333-250021)

    Ladies and Gentlemen:

    Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), South Plains Financial, Inc., a Texas corporation (the “Registrant”), hereby requests that the effective date for the
      above-referenced Registration Statement on Form S-4 (File No. 333-250021) be accelerated so that it will be declared effective under the Securities Act at 4:00 p.m., Eastern Standard Time, on November 30, 2020, or as soon thereafter as possible.

    Please contact Heather A. Eastep of Hunton Andrews Kurth LLP, the Registrant’s legal counsel, at (202) 955-1954 with any questions or comments.  In addition, please notify Mrs. Eastep via telephone when this request
      for acceleration has been granted.

    Thank you for your assistance in this matter.

            Sincerely,

            South Plains Financial, Inc.

            By:

            /s/ Curtis C. Griffith

            Curtis C. Griffith

            Chairman and Chief Executive Officer

United States securities and exchange commission logo
November 13, 2020
Curtis C. Griffith
Chief Executive Officer
South Plains Financial, Inc.
5219 City Bank Parkway
Lubbock, TX 79407
Re:South Plains Financial, Inc.
Registration Statement on Form S-4
Filed November 12, 2020
File No. 333-250021
Dear Mr. Griffith:
            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 Tonya K. Aldave at (202) 551-3601 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Heather Eastep, Esq.

CORRESP
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  South Plains Financial, Inc.

    5219 City Bank Parkway

  Lubbock, Texas  79407

  November 12, 2020

  BY EDGAR

  U.S. Securities and Exchange Commission

    100 F. Street, N.E.

    Washington, D.C.  20549

  Re:  South Plains Financial, Inc. Exchange Offer.

  Ladies and Gentlemen:

  In connection with the exchange offer (the “Exchange Offer”)
    being made by South Plains Financial, Inc. (the “Issuer”) pursuant to the prospectus contained in the Issuer’s Registration Statement on Form S-4 (File No.
    333-250021) filed with the U.S. Securities and Exchange Commission (the “SEC”) on November 12, 2020, this letter will confirm the following:

  (1)

  The Issuer is registering the Exchange Offer in reliance upon the position of the Staff of the SEC (“Staff”) set forth in the no-action letters issued to:  (i) Exxon Capital Holdings Corporation (available May 13, 1988); (ii) Morgan Stanley & Co. Incorporated
      (available June 5, 1991); and (iii) Shearman & Sterling (available July 2, 1993) (collectively, the “No‑Action Letters”).

  (2)

  The Issuer has not entered into any arrangement or understanding with any person to distribute the
      registered 4.50% Fixed-to-Floating Rate Subordinated Notes due 2030 to be received in the Exchange Offer (the “New Notes”) in exchange for the Issuer’s
      outstanding 4.50% Fixed-to-Floating Rate Subordinated Notes due 2030 (the “Old Notes”), and, to the best of the Issuer’s information and belief, each person
      participating in the Exchange Offer is acquiring the New Notes in the ordinary course of its business, is not participating in, and has no arrangement or understanding with any person to participate in, the distribution of the New Notes to be
      received in the Exchange Offer, is not an “affiliate” of the Issuer within the meaning of Rule 405 under the Securities Act of 1933, as amended (the “Securities Act”),
      and did not purchase any Old Notes to be exchanged for New Notes directly from the Issuer to resell pursuant to Rule 144A under the Securities Act or another exemption under the Securities Act.  In addition, to the best of the Issuer’s information
      and belief, each person participating in the Exchange Offer who is not a broker-dealer is not engaged in and does not intend to engage in a distribution of the New Notes.  In this regard, the Issuer will make each person participating in the Exchange
      Offer aware that if such person is participating in the Exchange Offer with the intention of participating in any manner in a distribution of the New Notes, such person (i) could not rely on the Staff position set forth in the No-Action Letters or
      interpretative letters to similar effect, and (ii) must comply with the registration and prospectus delivery requirements of the Securities Act in connection with any resale transaction, unless an exemption from registration is otherwise available.
      The Issuer acknowledges that such a secondary resale for the purpose of distributing the New Notes should be covered by an effective registration statement containing the selling security holder information required by Item 507 of Regulation S-K.

  U.S. Securities and Exchange Commission
    November 12, 2020

    Page 2

  (3)

  A broker-dealer may participate in the Exchange Offer with respect to Old Notes acquired for its own
      account as a result of market-making or other trading activities, provided that the broker-dealer has not entered into any arrangement or understanding with the Issuer or an affiliate of the Issuer to distribute the New Notes, and the Issuer (i) will
      make each person participating in the Exchange Offer aware (through the Prospectus for the Exchange Offer) that any broker-dealer who holds Old Notes acquired for its own account as a result of market-making or other trading activities, and who
      receives New Notes in exchange for such Old Notes pursuant to the Exchange Offer, must deliver a prospectus meeting the requirements of the Securities Act as described in paragraph (2) above in connection with any resale of such New Notes, and
      (ii) will include in the transmittal letter or similar documentation to be executed by an exchange offeree in order to participate in the Exchange Offer a provision providing that if the exchange offeree is a broker-dealer holding Old Notes acquired
      for its own account as a result of market-making or other trading activities, an acknowledgment that it will deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of the New Notes.  However, by so
      acknowledging and by delivering a prospectus, a broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.

  The transmittal letter to be executed by the exchange offeree in order to participate in the Exchange Offer includes a representation to the
    effect that by accepting the Exchange Offer, the exchange offeree represents that it is not engaged in, and does not intend to engage in, a distribution of the New Notes.

  [Signature Page Follows]

          Sincerely,

          SOUTH PLAINS FINANCIAL, INC.

          By:

          /s/ Curtis C. Griffith

          Name:

          Curtis C. Griffith

          Title:

          Chairman and Chief Executive Officer

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    SOUTH PLAINS FINANCIAL, INC.

    5219 City Bank Parkway

    Lubbock, Texas 79407

    (806) 792-7101

    Via EDGAR

    May 6, 2019

    Securities and Exchange Commission

    Division of Corporation Finance

    100 F Street, N.E.

    Washington, D.C. 20549-4628

    Attn: Michael Clampitt

            Re:

            South Plains Financial, Inc.

            Registration Statement on Form S-1 (as amended)

            File No. 333-230851

    Ladies and Gentlemen:

    Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, South Plains Financial, Inc., a Texas corporation (the
        “Company”), hereby respectfully requests, that the effective date of the above referenced Registration Statement on Form S-1 (File No. 333-230851) be accelerated by the Securities and Exchange Commission to 4:00 p.m., Eastern Time, on May 8, 2019, or as soon as practicable thereafter. By separate letter, the underwriters of the sale of the securities being registered join in this request for
        acceleration.

    The Company hereby authorizes Heather A. Eastep of Hunton Andrews Kurth LLP, the Company’s counsel, to orally modify or withdraw this request
        for acceleration. We request that we be notified of such effectiveness by a telephone call to Ms. Eastep at (214) 597-3080 and that such effectiveness also be confirmed in writing.

    Respectfully,

    SOUTH PLAINS FINANCIAL, INC.

    /s/ Curtis C. Griffith

    Curtis C. Griffith

    Chairman and Chief Executive Officer

            cc:

            Peter G. Weinstock, Hunton Andrews Kurth LLP

            Heather A. Eastep, Hunton Andrews Kurth LLP

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    Via EDGAR

    May 6, 2019

    Securities and Exchange Commission

    Division of Corporation Finance

    100 F Street, N.E.

    Washington, D.C. 20549-4628

    Attn: Michael Clampitt

            Re:

            South Plains Financial, Inc.

            Registration Statement on Form S-1 (as amended)

            File No. 333-230851

    Ladies and Gentlemen:

    Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Act”), as underwriters of the proposed initial public
        offering of the common stock of South Plains Financial, Inc., a Texas corporation (the “Company”), we hereby respectfully join the Company’s request that the effective date of the above referenced Registration Statement on Form S-1 (File No.
        333-230851) be accelerated by the Securities and Exchange Commission to 4:00 p.m., Eastern Time, on May 8, 2019, or as soon as practicable thereafter.

    Pursuant to Rule 460 under the Act, and in connection with the foregoing, we wish to advise you that the underwriters have distributed
        approximately 1,400 copies of the preliminary prospectus dated April 29, 2019, through the date hereof, to prospective underwriters, institutional investors, dealers, and others.

    The undersigned hereby represent on behalf of the underwriters that the underwriters are acting in compliance and will act in compliance with
        the provisions of Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the above issue.

            Respectfully,

            Keefe, Bruyette & Woods, Inc.

            Sandler O’Neill & Partners, L.P.

            KEEFE, BRUYETTE & WOODS, INC.

            By:

            /s/ Craig McMahen

            Craig McMahen

            Managing Director – Investment Banking

            SANDLER O’NEILL & PARTNERS, L.P.

            By:

            Sandler O’Neill & Partners Corp., the sole general partner

            By:

            /s/ Bob Kleinert

            Bob Kleinert

            An Officer of the Corporation

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            HUNTON ANDREWS KURTH LLP

            FOUNTAIN PLACE

            1445 ROSS AVENUE, SUITE 3700

            DALLAS, TX 75202

            TEL          214 •
                  979 • 3000

                  FAX          214 • 880 • 0011

            PETER G. WEINSTOCK

            DIRECT DIAL: 214 • 468 • 3395

            EMAIL: pweinstock@huntonak.com

            HEATHER A. EASTEP

            DIRECT DIAL: 202 • 955 • 1954

            EMAIL: heastep@huntonak.com

            By EDGAR and Overnight Delivery

            April 29, 2019

    Division of Corporation Finance

    United States Securities and Exchange Commission

    100 F. Street, NE

    Washington, DC 20549

    Attn:    Michael Clampitt, Senior Counsel

                RE:

                South Plains Financial, Inc.

                Registration Statement on Form S-1

                  Filed April 12, 2019

                  File No. 333-230851

    Ladies and Gentlemen:

    On behalf of our client, South Plains Financial, Inc. (the “Company”), we are submitting the following response to the
        comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter, dated April 18, 2019, with respect to the above-referenced filing.  The Company has also revised its Registration Statement on
        Form S-1 filed with the Commission on April 12, 2019 (the “Form S-1”) in response to the Staff’s comment and is filing concurrently with this letter an Amendment No. 1 to Registration Statement on Form S-1 (the “Amended Registration Statement”),
        which reflects these revisions.

    For your reference, copies of this letter, clean copies of the Amended Registration Statement, and copies marked to show all
        changes from the Form S-1 are being delivered to the Staff under separate cover.

    For the convenience of the Staff, the numbered paragraphs and headings below correspond to the headings in the letter.  The
        Staff’s comment is set forth in italics, followed by the Company’s response to the comment.  Unless otherwise indicated, all page references in our response correspond to pages in the marked Amended Registration Statement.

      ATLANTA   AUSTIN   BANGKOK   BEIJING   BOSTON   BRUSSELS   CHARLOTTE   DALLAS   DUBAI   HOUSTON   LONDON   LOS ANGELES

      MIAMI   NEW YORK   NORFOLK   RALEIGH/DURHAM   RICHMOND   SAN FRANCISCO   THE WOODLANDS   TYSONS   WASHINGTON, DC

      www.HuntonAK.com

        April 29, 2019

        Page 2 of 2

      Form S-1 filed April 12, 2019

      Our bylaws have an exclusive forum provision . . . , page 39

      1.          Please clarify, here and in your
          disclosure on page 130, whether the exclusive forum provision applies to actions arising under the Securities Act or Exchange Act.  As you have disclosed, while Section 27 of the Exchange Act creates exclusive federal jurisdiction over all suits
          brought to enforce any duty or liability created by the Exchange Act, Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all suits brought to enforce any duty or liability created by the Securities
          act or the rules and regulations thereunder.  If the exclusive forum provision applies to claims arising under the Securities Act, then please disclose that there is uncertainty as to whether a court would enforce such provision in this context,
          and to state that shareholders will not be deemed to have waived the company’s compliance with the federal securities laws and the rules and regulations thereunder.  If this provision does not apply to actions arising under the Securities Act or
          Exchange Act, please also ensure that the exclusive forum provision in your bylaws states this clearly.

      Response:  In response to the Staff’s comment, the Company has revised the disclosure on pages 41 and 131 of the Amended Registration Statement.

      If you or any other members of the Staff have any questions or comments regarding the foregoing or need additional
          information, please contact either Peter G. Weinstock at (214) 468-3395 or pweinstock@huntonak.com or Heather Archer Eastep at (202) 955-1954 or heastep@huntonak.com.

      Sincerely,

      /s/ Peter G. Weinstock

      Peter G. Weinstock

      /s/ Heather Archer Eastep

      Heather Archer Eastep

                cc:

                Curtis C. Griffith

                  Chet A. Fenimore

                  Derek W. McGee

April 18, 2019
Curtis C. Griffith
Chairman and Chief Executive Officer
South Plains Financial, Inc..
5219 City Bank Parkway
Lubbock, Texas 79407
Re:South Plains Financial, Inc.
Registration Statement on Form S-1
Filed April 12, 2019
File No. 333-230851
Dear Mr. Griffith:
            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.  Unless we note
otherwise, our references to prior comments are to comments in our March 21, 2019 letter.
Form S-1 filed April 12, 2019
Our bylaws have an exclusive forum provision . . . , page 39
1.Please clarify, here and in your disclosure on page 130, whether the exclusive forum
provision applies to actions arising under the Securities Act or Exchange Act.  As you
have disclosed, while Section 27 of the Exchange Act creates exclusive federal
jurisdiction over all suits brought to enforce any duty or liability created by the Exchange
Act, Section 22 of the Securities Act creates concurrent jurisdiction for federal and state
courts over all suits brought to enforce any duty or liability created by the Securities Act
or the rules and regulations thereunder.  If the exclusive forum provision applies to claims
arising under the Securities Act, then please disclose that there is uncertainty as to whether
a court would enforce such provision in this context, and to state that shareholders will not

 FirstName LastNameCurtis C. Griffith
 Comapany NameSouth Plains Financial, Inc..
 April 18, 2019 Page 2
 FirstName LastName
Curtis C. Griffith
South Plains Financial, Inc..
April 18, 2019
Page 2
be deemed to have waived the company’s compliance with the federal securities laws and
the rules and regulations thereunder.  If this provision does not apply to actions arising
under the Securities Act or Exchange Act, please also ensure that the exclusive forum
provision in your bylaws states this clearly.
            Please contact Michael Clampitt at 202-551-3434 or Pam Long, Assistant Director at
202-551-3765 with any questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services

CORRESP
1
filename1.htm

            HUNTON ANDREWS KURTH LLP

            FOUNTAIN PLACE

            1445 ROSS AVENUE, SUITE 3700

            DALLAS, TX 75202

            TEL          214 • 979 • 3000

                  FAX          214 • 880 • 0011

            PETER G. WEINSTOCK

            DIRECT DIAL: 214 • 468 • 3395

            EMAIL: pweinstock@huntonak.com

            HEATHER A. EASTEP

            DIRECT DIAL: 202 • 955 • 1954

            EMAIL: heastep@huntonak.com

            By EDGAR and Overnight Delivery

            April 12, 2019

    Division of Corporation Finance

    United States Securities and Exchange Commission

    100 F. Street, NE

    Washington, DC 20549

    Attn:    Michael Clampitt, Senior Counsel

    RE:          South Plains Financial, Inc.

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

    Submitted on March 14, 2019

    CIK No. 0001163668

    Ladies and Gentlemen:

    On behalf of our client, South Plains Financial, Inc. (the “Company”), we are submitting the following responses to the comments of the
        staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in your letter, dated March 21, 2019, with respect to the above-referenced filing.  In response to the Staff’s comments, the Company has also revised its
        Amended Draft Registration Statement on Form S-1 confidentially submitted to the Commission on March 14, 2019 (the “Draft Registration Statement”) and is filing concurrently with this letter a Registration Statement on Form S-1 (the “Revised
        Registration Statement”), which reflects these revisions.

    For your reference, copies of this letter, clean copies of the Revised Registration Statement, and copies marked to show all changes from
        the Draft Registration Statement are being delivered to the Staff under separate cover.

    For the convenience of the Staff, the numbered paragraphs and headings below correspond to the headings in the letter.  Each of the Staff’s
        comments is set forth in italics, followed by the Company’s response to the comment.  Unless otherwise indicated, all page references in our responses correspond to pages in the marked Revised Registration Statement.

      ATLANTA   AUSTIN   BANGKOK   BEIJING   BOSTON   BRUSSELS   CHARLOTTE   DALLAS   DUBAI   HOUSTON   LONDON   LOS ANGELES

      MIAMI   NEW YORK   NORFOLK   RALEIGH/DURHAM   RICHMOND   SAN FRANCISCO   THE WOODLANDS   TYSONS   WASHINGTON, DC

      www.HuntonAK.com

         April 12, 2019

        Page 2 of 4

    Management’s Discussion and Analysis of Financial Condition and Results of Operations

    Nonperforming Loans, page 59

    1.           Please revise your nonperforming assets table at the bottom
        of page 60 to include any troubled debt restructurings (TDRs) which are not already included in your nonperforming assets categories.  Please see III.C.1.(c) of Industry Guide 3, Statistical Disclosure by Bank Holding Companies.

    Response:  In response to the Staff’s comment, the Company has revised the Draft Registration Statement to include troubled debt restructurings which are not already included in the Company’s
        nonperforming assets categories.  Please see the revised table on page 62 of the Revised Registration Statement.

    2.           Please revise your disclosure on page 60 to clarify how the
        commercial real estate relationship in the amount of $5.3m in nonperforming loans was resolved.

    Response:  In response to the Staff’s comment, the Company has revised the Draft Registration Statement to clarify how the commercial real estate relationship in the amount of $5.3 million in
        nonperforming loans was resolved.  Please see the revised disclosure on page 61 of the Revised Registration Statement.

    Consolidated Balance Sheets, page F-3

    3.          We note your disclosure on page ii, and elsewhere throughout
        your draft registration statement, that your prospectus has given effect to a 29-for-1 stock split and that the split has been retroactively applied to all periods presented.  Please revise your financial statements and all related footnotes (e.g,
        subsequent events in Note 1, Earnings Per Share data in Note 15, etc.) to reflect the stock split.  Refer to ASC 505-20-S50-2 and SAB Topic 4.C.

    Response:  In response to the Staff’s comment, the Company has revised its financial statements included with the Draft Registration Statement and all related footnotes to reflect the 29-for-1
        stock split.  Please see the revised financial statements beginning on page F-1 of the Revised Registration Statement.

    Notes to the Consolidated Financial Statements

    1. Summary of Significant Accounting Policies, page F-13

    4.          Tell us the factors you considered in your determination that
        this reclassification was a change in accounting principle rather than the correction of an error, refer to ASC 250 in your response.  Please advise or revise as necessary.

    Response:  Employee Stock Ownership Plan (ESOP) shares are accounted for under ASC 718-40.  A private company that has not previously filed its financial statements with the Commission is not
        required to classify its ESOP shares that are subject to a put option as temporary equity.  As such, the Company classified its ESOP shares as permanent equity in its 2017 financial statements.  However, the guidance issued in SEC Staff Accounting
        Series Release (ASR) 268 requires the Company to classify the ESOP shares as temporary equity rather than permanent equity in connection with the preparation of the registration statement on Form S-1.  As such, the ESOP shares reflected in the 2018
        financials were classified as temporary equity, and the ESOP shares reflected in the 2017 financials were reclassified as temporary equity.

           April 12, 2019

          Page 3 of 4

    ASC 250-10-20 states that a change in accounting principle is a change from one generally accepted accounting principle to another
        generally accepted accounting principle when there are two or more generally accepted accounting principles that apply or when the accounting principle formerly used is no longer generally accepted.  As a private company, it was acceptable for the
        Company to classify the ESOP shares as permanent equity.  As a public company, it will no longer be acceptable for the Company to classify the ESOP shares as permanent equity but rather temporary equity.  We believe that this circumstance satisfies
        the definition of a change in accounting principle.

    In response to the Staff’s comment, the Company has revised the paragraph titled “Change in Accounting Principle” on page F-13 of the
        Revised Registration Statement.

           April 12, 2019

          Page 4 of 4

    If you or any other members of the Staff have any questions or comments regarding the foregoing or need additional information, please
        contact either Peter G. Weinstock at (214) 468-3395 or pweinstock@huntonak.com or Heather Archer Eastep at (202) 955-1954 or heastep@huntonak.com.

    Sincerely,

    /s/ Peter G. Weinstock

    Peter G. Weinstock

    /s/ Heather Archer Eastep

    Heather Archer Eastep

            cc:

            Curtis C. Griffith

            Chet A. Fenimore

            Derek W. McGee

March 21, 2019
Curtis C. Griffith
Chairman and Chief Executive Officer
South Plains Financial, Inc..
5219 City Bank Parkway
Lubbock, Texas 79407
Re:South Plains Financial, Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted on March 14, 2019
CIK No. 0001163668
Dear Mr. Griffith:
            We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to Draft Registration Statement on Form S-1 Filed March 14, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations
Nonperforming Loans, page 59
1.Please revise your nonperforming assets table at the bottom of page 60 to include any
troubled debt restructurings (TDRs) which are not already included in your nonperforming
assets categories.  Please see III.C.1.(c) of Industry Guide 3, Statistical Disclosure by
Bank Holding Companies.
2.Please revise your disclosure on page 60 to clarify how the commercial real estate
relationship in the amount of $5.3m in nonperforming loans was resolved.

 FirstName LastNameCurtis C. Griffith
 Comapany NameSouth Plains Financial, Inc..
 March 21, 2019 Page 2
 FirstName LastName
Curtis C. Griffith
South Plains Financial, Inc..
March 21, 2019
Page 2
Consolidated Balance Sheets, page F-3
3.We note your disclosure on page ii, and elsewhere throughout your draft registration
statement, that your prospectus has given effect to a 29-for-1 stock split and that the split
has been retroactively applied to all periods presented. Please revise your financial
statements and all related footnotes (e.g., subsequent events in Note 1, Earnings Per Share
data in Note 15, etc.) to reflect the stock split. Refer to ASC 505-20-S50-2 and SAB Topic
4.C.
Notes to the Consolidated Financial Statements
1. Summary of Significant Accounting Policies, page F-13
4.Tell us the factors you considered in your determination that this reclassification was a
change in accounting principle rather than the correction of an error, refer to ASC 250 in
your response.  Please advise or revise as necessary.
            You may contact Michael Henderson at 202-551-3364 or Hugh West at 202-551-3872 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Michael Clampitt at 202-551-3434 or Pam Long at 202-551-3765 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services

February 22, 2019
Curtis C. Griffith
Chairman and Chief Executive Officer
South Plains Financial, Inc..
5219 City Bank Parkway
Lubbock, Texas 79407
Re:South Plains Financial, Inc.
Draft Registration Statement on Form S-1
Submitted on January 16, 2019
CIK No. 0001163668
Dear Mr. Griffith:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 filed January 16, 2019
Prospectus Summary
Our Strategy
Growth Through Acquisitions, page 2
1.Revise to disclose that there are no current arrangements, understandings, or agreements
to make any material acquisitions other than the mortgage operations from the Kansas
based company. In addition, disclose the material terms of that acquisition, when expected
to be completed, and file the agreement as an exhibit in your public filing.

 FirstName LastNameCurtis C. Griffith
 Comapany NameSouth Plains Financial, Inc..
 February 22, 2019 Page 2
 FirstName LastNameCurtis C. Griffith
South Plains Financial, Inc..
February 22, 2019
Page 2
Improving Efficiency and Profitability, page 3
2.Revise to disclose the efficiency ratio for the end of 2017 and 2018.
The Offering, page 10
3.Noting the granting of options in connection with the offering, add disclosure to the
Summary of the details including the name(s) of those receiving options, the exercise
price, and, any other material terms.
Selected Historical Consolidated Financail and Operating Information, page 12
4.Please revise to explain how your efficiency ratio is calculated.
Executive Compensation
Director Compensation, page 118
5.Revise to add the disclosures for Richard Bass as required by Item 402(r) (2) (i) of
Regulation S-K.
Description of Capital Stock
Exclusive Forum, page 125
6.Revise to add a risk factor for "Limits on ability of shareholders to obtain favorable
shareholder forum" or similar caption and describe the impact of this provision on
shareholders. In addition, disclose whether this provision applies to actions arising under
the Securities Act or Exchange Act.  In that regard, please note that while Section 27 of
the Exchange Act creates exclusive federal jurisdiction over all suits brought to enforce
any duty or liability created by the Exchange Act, Section 22 of the Securities Act creates
concurrent jurisdiction for federal and state courts over all suits brought to enforce any
duty or liability created by the Securities Act or the rules and regulations thereunder.  If
this provision applies to claims arising under the Securities Act, then please disclose that
there is uncertainty as to whether a court would enforce such provision in this context, and
to state that shareholders will not be deemed to have waived the company’s compliance
with the federal securities laws and the rules and regulations thereunder.  If this provision
does not apply to actions arising under the Securities Act or Exchange Act, please also
ensure that the exclusive forum provision in the governing documents states this clearly.
Consolidated Financial Statements, page F-1
7.We note that you have not provided a footnote presenting your parent only financial
statements.  Refer to Rule 5-04 of Regulation S-X and revise as necessary, or tell us why
this information is not required.

 FirstName LastNameCurtis C. Griffith
 Comapany NameSouth Plains Financial, Inc..
 February 22, 2019 Page 3
 FirstName LastNameCurtis C. Griffith
South Plains Financial, Inc..
February 22, 2019
Page 3
Consolidated Statement of Comprehensive Income, page F-4
8.We note that you have not disclosed earnings per share (EPS) data.  Please address the
following:
•Revise to disclose your historic basic and diluted EPS on the face of this financial
statement.
•Revise your historical financial statements to include a separate column for pro forma
tax and related EPS data.  Refer to section 3410.1 (a) and (b) of the Division of
Corporation Finance Financial Reporting Manual.
•Revise the notes to your consolidated financial statements to include an EPS footnote,
refer to ASC 260-10-50.  See also the guidance relating to the two-class method within
ASC 260-10-45.
Notes to Consolidated Financial Statements
3. Loans, page F-13
9.Please revise to provide the disclosures required by ASC 310-10-50-11C.
10.Please revise your tabular disclosure, here and throughout your registration statement, to
disaggregate your consumer loans into 1-4 family residential loans, indirect auto loans,
and other consumer loans.
8. Employee Benefits, page F-20
11.We note your disclosure here and on page iv that ESOP participants have the right to
require you to repurchase in cash the shares that were distributed to them by the ESOP,
and that your December 31, 2018 consolidated balance sheet will include a line item
appearing between total liabilities and shareholders’ equity.  Please explain your
accounting treatment and presentation within your consolidated financial statements (i.e.
balance sheet, statement of comprehensive income, etc.), and address the applicability of
ASC 480 in your response. Please advise or revise as necessary.
13. Fair Value Disclosures, page F-24
12.For your assets measured at fair value on a recurring and nonrecurring basis, please revise
to provide the disclosure required by paragraphs bbb, c, and f of ASC 820-10-50-2.
13.We note your tabular disclosure of estimated fair values and related carrying amounts of
financial instruments at the bottom of page F-26.  Please revise to provide the disclosures
required by ASC 825-10-50-10.
Item 17 - Undertakings, page II-3
14.Revise to include the undertaking required by Item 512 (f) of Regulation S-K.

 FirstName LastNameCurtis C. Griffith
 Comapany NameSouth Plains Financial, Inc..
 February 22, 2019 Page 4
 FirstName LastName
Curtis C. Griffith
South Plains Financial, Inc..
February 22, 2019
Page 4
            You may contact Michael Henderson (Staff Accountant) at 202-551-3364 or Hugh West
(Branch Chief) at 202-551-3872 if you have questions regarding comments on the financial
statements and related matters.  Please contact Michael Clampitt (Staff Attorney) at 202-551-
3434 or Pam Long (Assistant Director) at 202-551-3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services