October 31, 2019 Thomas R. Quinn Chief Executive Officer Orrstown Financial Services, Inc. 77 East King Street Shippensburg, PA 17257 Re: Orrstown Financial Services, Inc. Registration Statement on Form S-3 Filed October 25, 2019 File No. 333-234321 Dear Mr. Quinn: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Susan Block at 202-551-3210 with any questions. Sincerely, Division of Corporation Finance Office of Finance