Orange County Bancorp, Inc.

212 Dolson Avenue

Middletown, New York 10940

July 17, 2024

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:       Orange County Bancorp, Inc.

Registration Statement on Form S-3 (Registration No. 333-280793)

Ladies and Gentlemen:

Orange County Bancorp, Inc., a Delaware corporation (the “Company”), hereby requests that the above-referenced Registration Statement on Form S-3 be declared effective at 1:30 p.m., Eastern time, on July 19, 2024, or as soon thereafter as is practicable.

Very truly yours,

Michael Lesler

Executive Vice President and Chief Financial Officer

(Duly Authorized Representative)