September 4, 2024

Rachel Miller
Senior Vice President, Counsel and Corporate Secretary
Chain Bridge Bancorp, Inc.
1445-A Laughlin Avenue
McLean, VA 22101

       Re: Chain Bridge Bancorp, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted August 19, 2024
           CIK No. 0001392272
Dear Rachel Miller:

     We have reviewed your amended draft registration statement and have the
following
comments.

        Please respond to this letter by providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement on EDGAR.
If you do not believe a comment applies to your facts and circumstances or do
not believe an
amendment is appropriate, please tell us why in your response.

        After reviewing the information you provide in response to this letter
and your amended
draft registration statement or filed registration statement, we may have
additional
comments. Unless we note otherwise, any references to prior comments are to
comments in our
July 29, 2024 letter.

Amendment No. 1 to Draft Registration Statement on Form S-1 filed August 19,
2024
Prospectus Summary, page 2

1.     We note your response to prior comment 4. We also note your growth
presentation
       calculates CAGR for six-year increments for all but the most recent
period. We note that
       your assets appear to have continued to nearly match their historical
growth trend through
       the end of the six-year period ending with fiscal year 2023, before
dramatically increasing
       in the first six months of 2024, resulting in the presented 10.8% rate.
Revise your
       disclosure to clarify the impact of your growth in the first six months
of 2024 on the
       amounts presented.
2.     We note your response to prior comment 6. In order for investors to
fully appreciate your
       business model, please revise your disclosure to address the service
level your
 September 4, 2024
Page 2

       relationship officers can provide to clients without the need for those
clients to visit your
       branch, limiting your need for a more extensive investment in a branch
network.
Risk Factors, page 27

3.     We note your response to prior comment 29, your disclosure that a
significant portion of
       your commercial borrowers are required to maintain deposit accounts with
you as part of
       their loan agreements, and that the degree to which this overlap
contributes to the stability
       and profitability of these relationships may vary depending on several
factors. If material,
       please include a risk factor discussing the risks to your business and
results of operations
       associated with the overlap between your loan clients and your
transactional depositors.
Liquidity risks could adversely affect our business, financial condition and
results of operations,
page 29

4.     We note your response to prior comment 15. Please revise your risk
factor to disclose that
       the Federal Home Loan Bank Advance had no collateral pledged and,
consequently, you
       would have to identify and pledge collateral before you could utilize
the FHLB as a
       source of additional liquidity, which might slow your access to
additional funding.
We may need to raise additional capital, page 33

5.     We note your discussion of the $10 million borrowed on a line of credit
in order to
       contribute capital to your banking subsidiary. To the extent that the
capital infusion was
       created by the rapid increase in deposits and other assets in 2023 and
2024, consider
       adding a specific risk factor to discuss the potential need to raise
capital to support the
       growth of the bank, particularly in the run-up to election cycles when
your short-term
       deposits and assets grow dramatically.
Capitalization, page 69

6.     The amounts presented in the    Actual    column do not appear to
represent amounts as of
       June 30, 2024. Please revise your filing to include the appropriate
balances as of the most
       recent interim period presented in your financial statements.

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 78

7.     We note that you discuss your results of operations for the six months
ended June 30,
       2024 compared to the same period in 2023. Please revise your filing to
also include a
       discussion of your results of operations for the three months ended June
30, 2024
       compared to the same period in 2023 or to the most recent quarter. See
Item 303(c)(2)(ii)
       of Regulation S-K.
Trust and wealth management income, page 85

8.     Refer to prior comment 23. We note your disclosure on page 86 which
states that you
          employ distinct fee structures    for assets under management (   AUM
  ) and assets under
       custody (   AUC   ). Please revise your filing, here or elsewhere, to
clarify what is meant by
       the term    distinct fee structures    (e.g., management versus
performance-based fees,
       whether fees differ based on product type, security type, or other
factors, etc.) and to
 September 4, 2024
Page 3

       disclose weighted average fee rates for AUM each period. In addition,
disclose the extent
       to which fee rates for AUM or AUC have changed period-over-period, and,
if material,
       discuss the drivers of those changes.
Deposits, page 100

9.     We note your disclosure on page 102 that you estimate your total
uninsured deposits
       increased from $648.0 million as of December 31, 2023, or 58.3% of your
deposit
       portfolio, to $1.0 billion as of June 30, 2024, or 78.3% of your deposit
portfolio. In
       addition, we note your disclosure on page 76 that in order to manage the
risks associated
       with uninsured deposits, you aim to maintain high levels of liquidity,
asset quality and
       financial strength. Understanding the seasonality associated with your
deposits in general,
       to the extent applicable, please revise your filing to disclose whether
you have policies or
       internal limits regarding concentrations in uninsured deposits, in total
or by type of
       depositor, and whether you have complied with any such internal
requirements for the
       periods presented.
Short-Term Borrowings, page 102

10.    Refer to prior comment 31. We note your updated disclosure on page 102
that provides
       details surrounding your federal funds line of credit agreements with
certain
       correspondent banks. Please revise your filing to also include this and
any other material
       information related to your borrowings in a footnote to your unaudited
consolidated
       financial statements as of and for the three and six months ended June
30, 2024. Refer to
       Regulation S-X 9-03.13.
Notes to Consolidated Financial Statements
Note 1. Organization and Summary of Significant Accounting Policies
Reclassification, page F-32

11.    In your response to our prior comment 38, you state that you
reclassified certain expense
       items between various components of noninterest expense and that    none
of those
       reclassifications were material to stockholders    equity or net income.
   If true, please
       revise your disclosures to state definitively that there was no impact
to stockholders
       equity or net income as a result of this reclassification. To the extent
there were other
       reclassifications that had non-material impacts on these line items,
please disclose the
       nature and magnitude of the additional change(s).
       Please contact Shannon Davis at 202-551-6687 or Cara Lubit at
202-551-5909 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Christian Windsor at
202-551-3419 with any
other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance
 September 4, 2024
Page 4
cc:   Catherine M. Clarkin