February 14, 2019 Francisco Atalig Senior Vice President and Chief Financial Officer BankGuam Holding Co P.O. Box BW Hagatna, Guam 96932 Re: BankGuam Holding Co Form 10-K for the fiscal year ended December 31, 2017 Filed June 29, 2018 Form 10-Q for the quarterly period ended September 30, 2018 Filed November 9, 2018 File No. 000-54483 Dear Mr. Atalig: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Financial Services