July 12, 2019

Kathryn Austin
President and Chief Executive Officer
Community Bancorp.
4811 US Route 5
Derby, Vermont 05829

       Re: Community Bancorp.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed March 15, 2019
           Form 10-Q for Fiscal Quarter Ended March 31, 2019
           Filed May 9, 2019
           File No. 000-16435

Dear Ms. Austin:

      We have reviewed your filings and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-Q for Fiscal Quarter Ended March 31, 2019

Notes to Consolidated Financial Statements
Note 5. Loans, Allowance for Loan Losses and Credit Quality, page 13

1.    We note disclosure that you chose to reclassify the entire balance of
your held-to-maturity
      investment portfolio consisting of municipal notes into your loan
portfolio during 2019
      and have restated all prior periods accordingly. Please tell us the
following:

          Explain the reason(s) for reclassifying these municipal notes to the
loan portfolio;
          Provide a detailed description of the terms and features of the
municipal notes
          reclassified;
          Tell us the authoritative accounting guidance you relied upon in
support of your
          accounting and disclosure;
          Tell us how you determined these securities are not in the scope of
ASC 320, as
 Kathryn Austin
Community Bancorp.
July 12, 2019
Page 2
             previously accounted for and classified in your historical
financial statements; and
             Tell us how you considered the accounting and disclosure guidance
in ASC 250.



        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.

        You may contact William Schroeder, Staff Accountant, at 202-551-3294 or
John Spitz,
Staff Accountant, at 202-551-3484 if you have questions regarding comments on
the financial
statements and related matters.



FirstName LastNameKathryn Austin                               Sincerely,
Comapany NameCommunity Bancorp.
                                                               Division of
Corporation Finance
July 12, 2019 Page 2                                           Office of
Financial Services
FirstName LastName