Keefe, Bruyette & Woods

November 9, 2020

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Registration Statement on Form S-1 (Registration Number 333-248742)

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, we hereby join Generations Bancorp NY, Inc. in requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 9:00 a.m. on November 12, 2020, or as soon thereafter as may be practicable.

	KEEFE, BRUYETTE & WOODS, INC.
By:	/s/ Patricia A. McJoynt
	Name: Patricia A. McJoynt
	Title:  Managing Director