By EDGAR – As Correspondence

August 2, 2021

The Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549

Attn: Division of Corporation Finance

RE: Tompkins Financial Corporation
Registration Statement on Form S-3
File No.: 333-258191

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effectiveness of the above-referenced Registration Statement on Form S-3 of Tompkins Financial Corporation (the “Issuer”) be accelerated to Wednesday, August 4, 2021, at 4:00 p.m., or as soon thereafter as practicable. 

Very truly yours,
TOMPKINS FINANCIAL CORPORATION
By:	/s/ Cynthia M. Manuele
	Cynthia M. Manuele
	Deputy Corporate Secretary