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                             February 27, 2023

       Bala Balkrishna
       Chairman and Chief Executive Officer
       Infinity Bancorp
       6 Hutton Centre Drive, Suite 100
       Santa Ana, CA 92707

                                                        Re: Infinity Bancorp
                                                            Offering Statement
on Form 1-A
                                                            Filed on February
17, 2023
                                                            File No. 024-12158

       Dear Bala Balkrishna:

                                                        This is to advise you
that we do not intend to review your offering statement.

               We will consider qualifying your offering statement at your
request. In connection with
       your request, please confirm in writing that at least one state has
advised you that it is prepared
       to qualify or register your offering. If a participant in your offering
is required to clear its
       compensation arrangements with FINRA, please have FINRA advise us that
it has no objections
       to the compensation arrangements prior to qualification.

               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 Robert
Arzonetti at 202-551-8819 with any questions.




                             Sincerely,


                             Division of Corporation Finance

                             Office of Finance
       cc:                                              Richard Knecht