February 5, 2026 Martin K. Birmingham Chief Executive Officer Financial Institutions, Inc. 220 Liberty Street Warsaw, NY 14569 Re: Financial Institutions, Inc. Registration Statement on Form S-4 Filed January 30, 2026 File No. 333-293081 Dear Martin K. Birmingham: 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 Robert Arzonetti at 202-551-8819 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: Benjamin M. Azoff