By EDGAR – As Correspondence
August 2, 2021
The Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
| Attn: | Division of Corporation Finance |
| RE: | Tompkins Financial Corporation Registration Statement on Form S-3 File No.: 333-258191 |
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effectiveness of the above-referenced Registration Statement on Form S-3 of Tompkins Financial Corporation (the “Issuer”) be accelerated to Wednesday, August 4, 2021, at 4:00 p.m., or as soon thereafter as practicable.
| Very truly yours, | |||
| TOMPKINS FINANCIAL CORPORATION | |||
| By: | /s/ Cynthia M. Manuele | ||
| Cynthia M. Manuele | |||
| Deputy Corporate Secretary | |||