August 10, 2021
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: Isabella Bank Corporation
Registration Statement on Form S-4
File No. 333-258102
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above-referenced Registration Statement be accelerated so that the same will become effective at 4:00 p.m. on Thursday, August 12, 2021, or as soon thereafter as is practicable.
| Very truly yours, | ||||||||
| ISABELLA BANK CORPORATION | ||||||||
| By: | /s/ Jae A. Evans | |||||||
| Name: | Jae A. Evans | |||||||
| Title: | President & CEO | |||||||