LUSE GORMAN POMERENK & SCHICK
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
5335 WISCONSIN AVENUE, N.W., SUITE 780
WASHINGTON, D.C. 20015
TELEPHONE (202) 274-2000
FACSIMILE (202) 362-2902
www.luselaw.com
WRITER’S DIRECT DIAL NUMBER (202) 274-2013 | WRITER’S E-MAIL awheeler@luselaw.com |
July 23, 2014
Via Electronic Mail
Todd Schiffman
Assistant Director Office of Financial Services
Division of Corporation Finance
U.S. Securities & Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | Pilgrim Bancshares, Inc. |
| Registration Statement on Form S-1 |
| Filed March 11, 2014 |
| File No. 333- 194485 |
Dear Mr. Schiffman:
On behalf of Pilgrim Bancshares, Inc., (the “Company”), we are hereby transmitting Pre-Effective Amendment No. 2 to the Company’s Registration Statement on Form S-1 (the “Amended Form S-1”). Set forth below are the comments from the Staff’s comment letter dated June 16, 2014, as well as the Company’s responses to those comments. We also enclose four (4) courtesy copies of the Prospectus included in the Amended Form S-1, marked to show changes to the document filed on June 6, 2014.
Part II
Exhibits 8.1 and 8.2
| 1. | Please file dated and signed opinions prior to effectiveness. |
Response: Dated and signed opinions are filed as Exhibits 8.1 and 8.2 to the Amended Form S-1.
* * *
LUSE GORMAN POMERENK & SCHICK
A Professional Corporation
Todd Schiffman
Securities and Exchange Commission
Page 2
Should you have any questions, please do not hesitate to contact the undersigned at (202) 274-2013 or Kent Krudys at (202) 274-2019.
| Very truly yours, |
/s/ Adam P. Wheeler |
| Adam P. Wheeler |
| cc: | Francis E. Campbell, President and Chief Executive Officer |
| Kent M. Krudys, Esq. |
