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                             October 8, 2020

       Menzo D. Case
       President and Chief Executive Officer
       Generations Bancorp NY, Inc.
       20 East Bayard Street
       Seneca Falls, NY 13148

                                                        Re: Generations Bancorp
NY, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed September 11,
2020
                                                            File No. 333-248742

       Dear Mr. Case:

              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.

       Registration Statement on Form S-1 submitted September 11, 2020

       Prospectus
       Terms of the Offering, page 6

   1.                                                   We note your disclosure
of the maximum, midpoint and minimum price-to-earnings
                                                        multiples on page 7.
Please also disclose the multiples for each of the peer companies
                                                        listed.
       Risk Factors
       As a result of the decline in cash flow . . ., page 22

   2.                                                   We note that on page 22
of the prospectus you disclose that, at June 30, 2020, 227
                                                        customers remain on
your deferral program with a balance of $28.9 million. Elsewhere,
                                                        such as on pages 97 and
100, disclosures indicate that, as of June 30, 2020, 168 customers
 Menzo D. Case
FirstName
GenerationsLastNameMenzo  D. Case
            Bancorp NY, Inc.
Comapany
October    NameGenerations Bancorp NY, Inc.
        8, 2020
October
Page 2 8, 2020 Page 2
FirstName LastName
         remain on the deferral program with a balance of $19.9 million. Please
amend your
         disclosures to reconcile this discrepancy.
How we intend to use the proceeds from the offering, page 42

3.       We note that you plan to distribute either $9 million or $10 million
of net proceeds from
         this offering to Generations Bank. We also note a general description
of how Generations
         Bank plans to use the proceeds on page 43 to "expand its banking
franchise by
         establishing or acquiring new branches or by acquiring other financial
institutions or other
         financial services companies." In this regard, please tell us if
Generations Bank has any
         specific plans to acquire new branches or other financial
institutions. If so, please provide
         the disclosure required by Instructions 5 and 6, as applicable, to
Item 504 of Regulation S-
         K.
4.       For the subordinated debt to be repaid with the use of proceeds please
specify the interest
         rate and maturity of the debt. Refer to Instruction 4 to Item 504 of
Regulation S-K.
Business of Generations Bancorp and Seneca-Cayuga Bancorp
Forbearances Programs in Response to Government Actions and the Covid-19
Pandemic, page
97

5.       We note your disclosure here that "all of these loans, [loans for
which payments are
         deferred due to the Covid-19 pandemic], are expected to return to
their regular
         payment cycles by September 2020." Please update this disclosure with
the most
         recent information.
Transactions with Certain Related Persons, page 132

6.       We note your disclosure relating to the loan for which Mr. Jones is
the guarantor. Please
         disclose the largest aggregate amount of principal outstanding during
the period for which
         disclosure is provided, the amount of principal paid during the
periods for which
         disclosure is provided, the amount of interest paid during the period
for which disclosure
         is provided, and the rate or amount of interest payable on the
indebtedness. Refer to Item
         404(a)(5) of Regulation S-K. In addition, please explain who continues
to make payment
         on the the loan if the company to which it was made is no longer in
business.
7.       Please disclose in this section the loans made to officers, directors
and their affiliates
         listed on pages F-60 and F-61, to the extent that these meet the
criteria for transactions
         with related persons pursuant to Item 404 of Regulation S-K. In
addition, describe your
         policies and procedures for the review, approval, or ratification of
the related party
         transactions. Refer to Item 404(b) of Regulation S-K.
Questions and Answers, page II-1

8.       We note that in several places in this section you refer to
"super-majority," and that in
         some situations it appears to mean two-thirds of the votes, while in
other cases it may
 Menzo D. Case
Generations Bancorp NY, Inc.
October 8, 2020
Page 3
         mean 80% of the votes. Please revise throughout to disclose the
specific percentages of
         votes required when referring to a"super-majority."
General

9.       Please provide us with supplemental copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone authorized to
do so on your behalf,
         have presented or expect to present to potential investors in reliance
on Section 5(d) of the
         Securities Act, whether or not you retained, or intend to retain,
copies of those
         communications. Please contact Tonya K. Aldave at (202) 551-3601 to
discuss how to
         submit the materials, if any, to us for our review.
        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 Cara Lubit at 202-551-5909 or Hugh West at 202-551-3872
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Tonya Aldave at 202-551-3601 or John Dana Brown at 202-551-3859 with any other
questions.



FirstName LastNameMenzo D. Case                                Sincerely,
Comapany NameGenerations Bancorp NY, Inc.
                                                               Division of
Corporation Finance
October 8, 2020 Page 3                                         Office of
Finance
FirstName LastName