[LETTERHEAD OF KILPATRICK TOWNSEND & STOCKTON LLP]
Suite 900 607 14th St., NW Washington DC 20005-2018 t 202 508 5800 f 202 508 5858 www.KilpatrickTownsend.com |
February 8, 2011 | direct dial 202 639 4734 direct fax 202 585 0070 ehellmold@kilpatricktownsend.com |
Mr. John Nolan
Senior Assistant Chief Accountant
Securities and Exchange Commission
Washington, DC 20549
Re: | Fraternity Community Bancorp, Inc. |
Registration Statement on Form S-1
Amendment Number 5
File Number 333-170215
Dear Mr. Nolan:
On behalf of Fraternity Community Bancorp, Inc. (the “Company”), please find the Company’s response to the staff’s comment letter issued on February 8, 2011 regarding Pre-effective Amendment No. 5 to the Registration Statement on Form S-1 filed on February 7, 2011 (the “Registration Statement”). To aid in your review, we have repeated the staff’s comments followed by the Company’s responses. As discussed with the staff, no amendment is required in connection with these responses.
Financial Statements, page F-2
Comment No. 1:
Please note the updating requirements for the financial statements and related disclosures pursuant to Rules 3-12 of Regulation S-X.
Response to Comment No. 1:
The comment is noted.
Exhibit 23
Comment No. 2:
Provide a current consent of the independent accountant in any amendment.
Mr. John Nolan
February 8, 2011
Page 2
Response to Comment No. 2:
A current consent of Stegman & Company was filed with the Registration Statement and appears immediately following the signature page of the Registration Statement.
* * * *
If you have any questions or further comments, please contact the undersigned at (202) 639-4734.
Very truly yours, |
/s/ Erich M. Hellmold |
Erich M. Hellmold |
Enclosures
cc: | Thomas K. Sterner, Fraternity Community Bancorp, Inc. |
Babette Cooper, Securities and Exchange Commission
David Lyon, Securities and Exchange Commission
Gary R. Bronstein, Esq.
Joel E. Rappoport, Esq.