July 9, 2024

Paul Nungester
Chief Financial Officer
Premier Financial Corp.
601 Clinton Street
Defiance, OH 43512

       Re: Premier Financial Corp.
           Form 10-K for Fiscal Year Ended December 31, 2023
           File No. 000-26850
Dear Paul Nungester:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended December 31, 2023
Loan Portfolio Composition, page 5

1.     We note your tabular disclosure on page 6 which indicates that your
commercial real
       estate (   CRE   ) loan portfolio comprised 40.5% of total loans as of
December 31, 2023.
       We also note disclosure in your January and April 2024 Investor Update
presentations
       included on your website that provide detailed disclosures of your CRE
loan portfolio.
       Please revise future filings, beginning with your Form 10-Q for the
fiscal quarter ended
       June 30, 2024, to further disaggregate the composition of your CRE loan
portfolio to
       disclose and quantify material geographic and industry concentrations
(e.g., office, retail,
       hotel and multifamily), as well as current weighted average and/or range
of loan-to-value
       ratios and occupancy rates to enhance an investor   s understanding of
these loan
       categories.
2.     We note your disclosure on page 18 that your CRE loans typically have
higher principal
       amounts than residential real estate loans and that many of your CRE
borrowers have
       more than one loan outstanding and as a result, an adverse development
on one loan can
       expose you to a greater risk of loss on other loans. Please revise
future filings, beginning
 July 9, 2024
Page 2

       with your Form 10-Q for the fiscal quarter ended June 30, 2024, to
describe the specific
       details of any risk management policies, procedures or other actions
undertaken by
       management in response to the current environment.
Item 7A. Quantitative and Qualitative Disclosures About Market Risk, page 40

3.     We note your disclosure on page 40 that indicates you monitor interest
rate risk using a
       simulation technique that takes into account prepayment speeds on
amortizing financial
       instruments, loan and deposit volumes and rates, borrowings, derivative
positions and
       non-maturity deposit assumptions and capital requirements. Please revise
future filings,
       beginning with your Form 10-Q for the fiscal quarter ended June 30,
2024, to fully
       describe and define the various identified inputs and assumptions
supporting your market
       risk presentations and sensitivity disclosures. In addition, provide a
discussion of how any
       assumptions have changed from period to period, including any changes to
the data source
       used or significant changes in the actual assumption itself. See Item
305(a)(1)(ii)(B) of
       Regulation S-K.
       In closing, 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 Shannon Davis at 202-551-6687 or John Spitz at
202-551-3484 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance