February 27, 2020

Steven E. Shelton
President and Chief Executive Officer
California BanCorp
1300 Clay Street
Suite 500
Oakland, California 94612

       Re: California BanCorp
           Draft Registration Statement on Form 10
           Submitted on January 31, 2020
           CIK No. 1752036

Dear Mr. Shelton:

       We have reviewed your filing 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Draft Registration Statement on Form 10

Lending Limits, page 6

1.    Please revise this section to indicate what the highest aggregate secured
and unsecured
      loan-to-one borrower balances were at September 30, 2019.
Real Estate Loans, page 8

2.    We note your disclosure under this heading that as of September 30, 2019,
loans secured
      by real estate made up approximately 52% of your loan portfolio. We
further note your
      disclosure on page 21 that as of September 30, 2019, 57% of your loan
portfolio was
      comprised of loans with real estate as a primary or secondary component
of collateral.
      Please revise to reconcile these numbers or revise to clarify why the
percentages differ.
 Steven E. Shelton
FirstName BanCorp
California LastNameSteven E. Shelton
Comapany NameCalifornia BanCorp
February 27, 2020
Page 2
February 27, 2020 Page 2
FirstName LastName
Data Privacy and Cybersecurity, page 18

3.       We note your disclosure that you are required to have adopted policies
and procedures to
         comply with cybersecurity laws and regulations and to protect the
personal privacy of
         your customers and the security of their data. We also note your risk
factor on page 25
         regarding cyber-attacks and data security breaches. Here or under
another appropriately
         captioned heading, pease revise to disclose the nature of the board of
director's role in
         overseeing your cybersecurity risk management, the manner in which the
board
         administers this oversight function and any effect this has on the
board's leadership
         structure.
Our deposit portfolio includes significant concentrations..., page 24

4.       We note your discussion of the risks related to your large percentage
of deposits being
         attributable to a relatively small number of customers. If material,
please provide a
         similar risk factor that discloses any significant concentration of
loans that you may have
         to your 10 largest lending relationships.
Item 2. Financial Information
Management's Discussion and Analysis of Financial Condition and Results of
Operations
As of and for the Year Ended December 31, 2018 Compared to the Year Ended
December 31,
2017
Financial Condition
Nonperforming Assets, page 45

5.       We note your disclosure on page 46 and elsewhere (e.g., page 161) that
non-accrual loans
         grew from $484,000 at December 31, 2017 to $4.46 million at December
31, 2018, with
         the increase coming from the Commercial and Industrial loan category.
Please tell us, and
         revise your disclosures here and elsewhere as appropriate, to explain
the causal factors for
         this increase. Quantify, where possible, the number of loans driving
the change as well as
         their amounts.
Deposits, page 49

6.       Please revise this section to disclose the extent (i.e., amount and
percentage of total
         deposits) to which you rely on brokered deposits as a source of
funding.
Director Compensation, page 79

7.       We note your disclosure that your non-employee directors receive cash
compensation in
         the form of a retainer fee for attending board and committee meetings.
Please revise your
         disclosure to quantify this retainer fee.
 Steven E. Shelton
California BanCorp
February 27, 2020
Page 3
Item 7. Certain Relationships and Related Transactions
Policies and Procedures for Approval of Related Person Transactions, page 81

8.       We note your disclosure that as of September 30, 2019, the Bank had
loans outstanding to
         some of your officers and directors and the business organizations
with which they are
         associated in the amount of $7,343,420. Please revise to ensure that
your disclosure
         includes the information required by Item 404(d) of Regulation S-K,
including the name
         of each related person, the related person's interest in the
transaction, the approximate
         dollar value of the amount involved in each transaction, and the
related person's
         position(s) or relationship(s) with the entity that is party to the
transaction.
        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.

        You may contact Cara Lubit at (202) 551-5909 or Hugh West, Accounting
Branch Chief
at (202) 551-3872 if you have questions regarding comments on the financial
statements and
related matters. Please contact Eric Envall at (202) 551-3234 or Sandra Hunter
Berkheimer,
Legal Branch Chief at (202) 551-3758 with any other questions.



FirstName LastNameSteven E. Shelton                          Sincerely,
Comapany NameCalifornia BanCorp
                                                             Division of
Corporation Finance
February 27, 2020 Page 3                                     Office of Finance
FirstName LastName