October 3, 2018

Michael J. Quinn
President and Chief Executive Officer
Rhinebeck Bancorp, Inc.
2 Jefferson Plaza
Poughkeepsie, NY 12601

       Re: Rhinebeck Bancorp, Inc.
           Registration Statement on Form S-1
           Filed September 10, 2018
           File No. 333-227266

Dear Mr. Quinn:

       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.

Form S-1 filed September 10, 2018

General

1.     Please supplementally provide us with copies of all written
communications, as defined in
       Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
       present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
       not they retain copies of the communications.
How We Determined the Offering Range and the $10.00 per Share Offering Price,
page 5

2.     It appears the valuation of peer group companies in the first table on
page 6 is shown on a
       fully-converted basis. If so, please revise to clarify in the table and
in the disclosure
 Michael J. Quinn
Rhinebeck Bancorp, Inc.
October 3, 2018
Page 2
      preceding the table that only the selected pricing ratios for Rhinebeck
Bancorp are
      presented on a non-fully converted basis. Also, please discuss the impact
of full or partial
      conversion on the comparability of the peer group information to the
information about
      the company. If you have made adjustments to the earnings or book values
of the peer
      group companies for purposes of this comparison, please clarify.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Delinquent Loans , page 66

3.    Please disclose delinquent information for the indirect automobile
lending program given
      its significance and your future plans to grow this lending.
Allowance for Loan Losses, page 69

4.    Please disclose indirect automobile loan charge-offs and recoveries for
the periods
      presented.


        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.

       You may contact Marc Thomas at 202-551-3452 or Gus Rodriguez at
202-551-3752 if
you have questions regarding comments on the financial statements and related
matters. Please
contact David Gessert at 202-551-2326 or Pam Long at 202-551-3765 with any
other questions.



                                                            Sincerely,
FirstName LastNameMichael J. Quinn
                                                            Division of
Corporation Finance
Comapany NameRhinebeck Bancorp, Inc.
                                                            Office of Financial
Services
October 3, 2018 Page 2
cc:       Scott A. Brown, Esq.
FirstName LastName