September 16, 2024

Joseph D. Perillo
Executive Vice President and Chief Financial Officer
Patriot National Bancorp Inc
900 Bedford Street
Stamford, CT 06901

        Re: Patriot National Bancorp Inc
            Form 10-K for the Fiscal Year Ended December 31, 2023
            Form 10-Q for the Quarterly Period Ended June 30, 2024
            File No. 000-29599
Dear Joseph D. Perillo:

       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 the Fiscal Year Ended December 31, 2023
Loans Held for Investment, page 22

1.      We note the tabular disclosure on page 22 detailing the composition of
your gross loan
        portfolio, which includes commercial real estate (   CRE   ). Given the
significance of CRE
        in your total loan portfolio, please revise your disclosures, in future
filings, to quantify
        owner-occupied and non owner-occupied amounts and further disaggregate
the
        composition of your CRE loan portfolio by borrower type (e.g., by
office, hotel,
        multifamily, etc.), geographic concentrations and other characteristics
(e.g., current
        weighted average and/or range of loan-to-value ratios, occupancy rates,
etc.), if any. In
        addition, revise to describe the specific details of any risk
management policies,
        procedures or other actions undertaken by management in response to the
current
        environment. For example, we note disclosure on pages 45 and 57 of your
June 30, 2024
        Form 10-Q indicating that you are restricting loan growth and reducing
your total and
        risk-based assets.
Allowance for Credit Losses, page 24
 September 16, 2024
Page 2

2.     We note a significant increase in net charge-offs and ratio of net
charge-offs to average
       loans to $17.3 million and 1.93% for the year ended December 31, 2023,
respectively,
       from $1.5 million and 0.18% for the year ended December 31, 2022,
respectively.
       Further, we note that a significant component of these increases
occurred within your
       Consumer and Other loan portfolio segment. Please revise your
disclosures, in future
       filings, to provide a discussion of the factors that drove material
changes in this ratio or
       the related components, during the periods presented. For example,
clarify whether this
       increase was directly related to the consumer loans purchased from a
third party you
       discuss on page 64. Refer to Item 1405(b) of Regulation S-K.
Form 10-Q for the Quarterly Period Ended June 30, 2024
Consolidated Statements of Cash Flows (Unaudited), page 8

3.     We note your presentation of a single line item for representing the net
(decrease) increase
       in FHLB, FRB and correspondent bank borrowings within financing
activities. Please
       revise your presentation, in future filings, to separately present the
gross proceeds and
       repayment amounts associated with your borrowings for each reporting
period. Refer to
       ASC 230-10-45-14 and 15.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Allowance for Credit Losses on Loans, page 46

4.     We note your disclosure of credit ratios for allowance for credit losses
to total loans, net
       charge-offs to average loans and nonperforming loans to total loans,
net. Please address
       the following:
           Revise your disclosures, in future filings, to also disclose the
ratio of allowance for
           credit losses to nonaccrual loans at each period end. Refer to Item
1405(a)(3) of
           Regulation S-K.
           For each ratio, revise your disclosures, in future filings, to
provide a discussion of the
           factors that drove material changes in the ratios, or the related
components, during the
           periods presented. Where appropriate and applicable, include
discussion for each loan
           category and the factors, trends and activities impacting that loan
category. Refer to
           Item 1405(b) of Regulation S-K.
Deposits, page 49

5.     We note your disclosure of uninsured deposits, as well as ratios for
uninsured deposits to
       total deposits and uninsured deposits to total deposits excluding
Digital Payments
       deposits. Please address the following.
           Revise your disclosures in future filings, here or where
appropriate, to clearly
           describe the nature and terms of the Digital Payment deposits and
explain how
           they are determined to qualify or not qualify for FDIC insurance.
           In regards to your ratio of uninsured deposits to total deposits
excluding Digital
           Payments deposits, tell us how you considered this as a potential
non-GAAP financial
           measure and whether it represents an individually tailored
accounting methodology.
           Refer to Question 100.04 of the non-GAAP C&DI.
           Revise your disclosures, in future filings, to include the detailed
calculation and
 September 16, 2024
Page 3

           reconciliation of the above measure.
Provision for Credit Losses, page 56

6.     We note your discussion of changes in the provision for credit losses
for the three and six
       months ended June 30, 2024 compared to the three and six months ended
June 30, 2023,
       which appear to primarily be due to the decline in classification of a
single CRE loan
       along with the impact of a decline in valuation of a previously
classified CRE loan. Please
       revise your discussion, in future filings, to provide more details
associated with the
       referenced CRE loans, such as the principal amount of the loans, and
factors driving the
       changes in the provision for credit losses from period to period.
Non-interest Income, page 56

7.     We note that your non-interest income increased for the six months ended
June 30, 2024
       compared to the six months ended June 30, 2023 primarily attributable to
higher non-
       interest income from the Bank's Digital Payments division. Please tell
us and revise your
       disclosures, here and elsewhere as appropriate, in future filings to
explain the nature of the
       digital payments income, including the contractual terms, how it is
calculated, when it
       began, what exact services are being provided and how. In addition,
revise your
       significant accounting policies disclosures, in future filings, in
footnote 2 beginning on
       page 10 to include disclosure of your accounting policy for the digital
payments income.
Liquidity, page 56

8.     We note your disclosure on page 50 that as of June 30, 2024, Patriot
borrowed a total of
       $69.0 million under the Bank Term Funding Program ("BTFP"). Please
revise your
       disclosures, in future filings, to include more robust discussion of
your sources of
       liquidity, capital resources and your plans to repay the borrowings
under the BTFP when
       they come due with accompanying discussion of any impacts it could have
on your results
       of operations, net interest income and other ratios to the extent
applicable.
9.     Please provide a more informative discussion and analysis of cash flows
from operating,
       investing and financing activities, including changes in working capital
components, for
       the periods presented. In doing so, explain the underlying reasons and
implications of
       material changes between periods to provide investors with an
understanding of trends
       and variability in cash flows. For example, we note that there were
significant increases in
       the originations of loans held for sale in 2024 compared to 2023, and
significant decreases
       in the originations of loans held for investment. Ensure that your
disclosures are not
       merely a recitation of changes evident from the financial statements.
Refer to Item
       303(a) of Regulation S-K.
10.    We note your disclosures regarding available sources of liquidity and
       narrative disclosures regarding outstanding FHLB and FRB borrowings. In
future filings,
       please consider expanding your disclosure for the following:
           include tabular disclosure of all available sources of liquidity by
type of borrowing
           capacity (e.g., Federal Home Loan Bank borrowings, FRB borrowing
capacity, etc.),
           with the table showing total borrowing capacity, less borrowings
outstanding,
           remaining capacity, and additional sources of liquidity (e.g., cash,
securities, etc.) to
           arrive at total available liquidity; and
 September 16, 2024
Page 4

             discuss available sources of liquidity measured against levels of
uninsured or total
           deposits, to the extent that you consider this internally in
managing your liquidity
           levels.
Capital, page 57

11.    We note that as of June 30, 2024, the Bank did not meet all of its
regulatory capital
       requirements and during the second quarter, the Bank significantly
reduced its total and
       risk-based assets to work towards achieving the IMCR targets, which the
trend is expected
       to continue into the remainder of 2024 with a goal of
achieving/exceeding the IMCR
       ratios by the end of 2024. Please revise your disclosure, in future
filings, to provide
       specific details of management's plans and policies to reduce total and
risk-based assets.
       In addition, include discussion of any impacts that result from not
meeting the regulatory
       capital requirements. Please also revise, in future filings, the related
disclosure in your
       Risk Factors as appropriate to address any risks associated with not
meeting your
       regulatory capital requirements and any additional policies or
procedures that have been
       or are expected to be adopted.
       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 Lory Empie at 202-551-3714 or Robert Klein at
202-551-3847 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance