0001144204-16-105431.txt : 20160629 0001144204-16-105431.hdr.sgml : 20160629 20160527140600 ACCESSION NUMBER: 0001144204-16-105431 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20160527 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Victory Bancorp Inc CENTRAL INDEX KEY: 0001509302 STANDARD INDUSTRIAL CLASSIFICATION: STATE COMMERCIAL BANKS [6022] IRS NUMBER: 270897883 STATE OF INCORPORATION: PA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 548 N LEWIS ROAD CITY: LIMERICK TOWNSHIP STATE: PA ZIP: 19468 BUSINESS PHONE: 484-941-3869 MAIL ADDRESS: STREET 1: 548 N LEWIS ROAD CITY: LIMERICK TOWNSHIP STATE: PA ZIP: 19468 CORRESP 1 filename1.htm

[Victory Bancorp Letterhead]

May 27, 2016

VIA EDGAR AND EMAIL (DunhamC@SEC.GOV)

Mr. Christopher Dunham

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

	Re:	The Victory Bancorp, Inc.
		Amendment No. 2 to Offering Statement on Form 1-A
		Filed May 19, 2016
		File No. 024-10447
		Request for Qualification

Dear Mr. Dunham:

Pursuant to your conversation on May 26, 2016 with Erich M. Hellmold of Kilpatrick Townsend & Stockton LLP advising that there were no comments on the Amendment No. 2 to the Offering Statement on Form 1-A of The Victory Bancorp, Inc. (the “Amendment”), we respectfully request that the Amendment be declared qualified on June 1, 2016 at 4:30 p.m., or as soon as practicable thereafter.

Furthermore, The Victory Bancorp, Inc. hereby acknowledges the following:

We have been advised by the State of New Jersey and Commonwealth of Pennsylvania that they are prepared to qualify or register the offering;

should the Commission or the staff, acting pursuant to delegated authority, qualify the filing, it does not foreclose the Commission from taking any action with respect to the filing;

the action of the Commission or the staff, acting pursuant to delegated authority, in qualifying the filing, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

Mr. Christopher Dunham

Securities and Exchange Commission

May 27, 2016

Page 2

the Company may not assert staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact Christina M. Gattuso of Kilpatrick Townsend & Stockton LLP at (202) 508-5884, Erich M. Hellmold of Kilpatrick Townsend & Stockton LLP at (202) 639-4734 or the undersigned upon the declaration of qualification, or if you have any questions regarding this matter.

	Sincerely,

	/s/ Joseph W. Major

	Joseph W. Major
	Chairman and Chief Executive Officer

cc:

Michael Clampitt, Securities and Exchange Commission

Christina M. Gattuso, Esq., Kilpatrick Townsend & Stockton LLP

Erich M. Hellmold, Esq., Kilpatrick Townsend & Stockton LLP