United States securities and exchange commission logo

                             July 21, 2021

       Michael J. Gilfeather
       President and Chief Executive Officer
       Orange County Bancorp, Inc.
       212 Dolson Avenue
       Middletown, NY 10940

                                                        Re: Orange County
Bancorp, Inc.
Statement on Form S-1
                                                            Filed July 9, 2021
                                                            File No. 333-257781

       Dear Mr. Gilfeather:

              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

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Form S-1 filed July 9, 2021


   1.                                                   We note that you have
registered $1 million worth of common stock. Please confirm that
                                                        this is a bona fide
estimate of the maximum offering price of your offering. Refer to Rule
                                                        457(a) of the
Securities Act.
       Principal and Selling Stockholders, page 126

   2.                                                   We note your response
to comment 5 and revised disclosure on page 127. However, it is
                                                        unclear why footnote 17
continues to state that Banc Fund IX LP has sole voting and
                                                        investment power over
207,649 shares and Banc Fund VIII LP has sole voting and
                                                        investment power over
35,532 shares. Please revise or advise.
 Michael J. Gilfeather
Orange County Bancorp, Inc.
July 21, 2021
Page 2

        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

        You may contact William Schroeder at (202) 551-3294 or Michael Volley
at (202) 551-
3437 if you have questions regarding comments on the financial statements and
related matters.
Please contact Eric Envall at (202) 551-3234 or David Lin at (202) 551-3552
with any other

FirstName LastNameMichael J. Gilfeather                    Sincerely,
Comapany NameOrange County Bancorp, Inc.
                                                           Division of
Corporation Finance
July 21, 2021 Page 2                                       Office of Finance
FirstName LastName