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                             October 2, 2020

       Edward J. Cooney
       Chief Executive Officer
       Affinity Bancshares, Inc.
       3175 Highway 278
       Covington, Georgia 30014

                                                        Re: Affinity
Bancshares, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed September 11,
2020
                                                            File No. 333-248745

       Dear Mr. Cooney:

              We have reviewed your registration statement and have the
following comments. In
       some of our comments, we may ask you to provide us with information so
we may better
       understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Form S-1 filed September 11, 2020

       Summary
       How We Determined the Offering Range, the Exchange Ratio and the $10.00
Per Share Purchase
       Price, page 7

   1.                                                   Please briefly
summarize the primary differences between the registrant and the peer
                                                        group used by the
appraiser and the reasons for the slight downward adjustments made by
                                                        the appraiser for
profitability, growth and viability of earnings and for marketing of the
                                                        issue.
       Business of Newton Federal Bank
       Allowance for Loan Losses, page 103

   2.                                                   We note your table
setting forth activity in the allowance for loan losses on page 104. The
 Edward J. Cooney
Affinity Bancshares, Inc.
October 2, 2020
Page 2
         activity included in the columns for the three months ended December
31, 2019 and 2018
         does not reconcile to other relevant disclosures throughout the
filing. Please explain and
         revise as necessary.
Description Of Capital Stock Of Affinity Bancshares, page 168

3.       Please revise to discuss your exclusive forum provision, including its
application to
         federal securities law claims.
Legal Matters, page 170

4.       Please revise to include the disclosure required by Item 103 of
Regulation S-K.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Ben Phippen at 202-551-3697 or Amit Pande at
202-551-3423 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Livingston at 202-551-3448 or Michael Clampitt at 202-551-3434
with any other
questions.



FirstName LastNameEdward J. Cooney                             Sincerely,
Comapany NameAffinity Bancshares, Inc.
                                                               Division of
Corporation Finance
October 2, 2020 Page 2                                         Office of
Finance
FirstName LastName