April 4, 2019

James W. Blake
Chief Executive Officer
HarborOne NorthEast Bancorp, Inc.
770 Oak Street
Brockton, MA 02301

       Re: HarborOne NorthEast Bancorp, Inc.
           Registration Statement on Form S-1
           Filed March 11, 2019
           File No. 333-230183

Dear Mr. Blake:

       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 March 11, 2019

Selected Consolidated Financial and Other Data, page 34

1.     Please revise the presentation of tangible book value per share and
tangible common
       equity to label the items as a non-GAAP measures.
Pro Forma Data, page 44

2.     Please supplementally provide supporting calculations for amounts
determined from
        footnotes (1), (2), and (3) for both the pro forma net income and pro
forma basic earnings
       per share amounts.
 James W. Blake
FirstName LastNameJames W. Blake
HarborOne NorthEast Bancorp, Inc.
Comapany NameHarborOne NorthEast Bancorp, Inc.
April 4, 2019
April 2 2019 Page 2
Page 4,
FirstName LastName
Management
Transactions with Related Parties, page 113

3.       Please revise to provide disclosure on your related party transactions
since January 1,
         2016 consistent with the requirements of Instruction to Item 404 of
Regulation S-K.
Exhibit Index
Exhibit 8.1, page II-4

4.       Please direct counsel to delete its assumption "that each of the
merger of the MHC into
         Old HarborOne and the merger of Old HarborOne into New HarborOne will
qualify as a
         merger under the applicable laws of Massachusetts." It is
inappropriate to assume any
         legal conclusion underlying these opinions. Please refer to Section
III.C.3. of Staff Legal
         Bulletin No.19 for guidance.
General

5.       Please revise to clarify the maximum number of shares of common stock
to be issued in
         exchange to existing public shareholders in your conversion. In this
regard we note
         apparently conflicting disclosure on page 155 and in the legal opinion
attached as Exhibit
         5.1, as compared to the disclosure elsewhere in your prospectus,
including but not limited
         to the cover page and your registration fee table.
        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 Michael Henderson, Staff Accountant, at (202) 551-3364
or John P.
Nolan, Senior Assistant Chief Accountant, at (202) 551-3492 if you have
questions regarding
comments on the financial statements and related matters. Please contact
Christopher Dunham,
Staff Attorney, at (202) 551-3783 or Michael Clampitt, Senior Counsel, at (202)
551-3434 with
any other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Financial Services
cc:      Samantha M. Kirby, Esq.