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                               April 7, 2021

       John A. Riley, III
       Chairman of the Board, President and Chief Executive Officer
       Cullman Bancorp, Inc. /MD/
       316 Second Avenue SW
       Cullman, Alabama 35055

                                                        Re: Cullman Bancorp,
Inc. /MD/
                                                            Registration
Statement on Form S-1
                                                            Filed March 12,
2021
                                                            File No. 333-254220

       Dear Mr. Riley:

              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 12, 2021

       Risk Factors
       The geographic concentration of our loan portfolio and lending
activities..., page 22

   1.                                                   Please disclose whether
your local market area has experienced any material declines in
                                                        real estate values
during the last year or a material increase in the number of foreclosures.
       Selected Consolidated Financial and Other Data, page 37

   2.                                                   We note the allowance
for loan losses as a percentage of non-performing loans of
                                                        1,788.64% herein, and
on pages 54, 62, and 79. We also note your disclosure of the
                                                        allowance for loan
losses as a percentage of non-performing loans of 92.05% in Risk
                                                        Factors on page 22.
Please revise throughout the document as appropriate, or advise
                                                        accordingly.
 John A. Riley, III
FirstName   LastNameJohn  A. Riley, III
Cullman Bancorp,   Inc. /MD/
Comapany
April       NameCullman Bancorp, Inc. /MD/
       7, 2021
April 27, 2021 Page 2
Page
FirstName LastName
3.       On this note, we calculate the allowance for loan losses as a
percentage of total loans at
         1,935.25% at 12/31/20, and the non-performing loans as a percentage of
total loans at
         0.05% at 12/31/20. This is based on total non-performing loans of
$122,000 at 12/31/20
         (non-accrual loans of $18,000 and accruing loans past due 90 days or
more of $104,000)
         from the table on page 77. Please revise throughout the document as
appropriate, or
         advise accordingly.
Capitalization , page 46

4.       You disclose that the pro forma consolidated capitalization of New
Cullman after giving
         effect to the conversion and offering is based upon the assumptions
set forth in the    Pro
         Forma Data    section and you disclose Pro Forma total stockholders
equity of $81,068
         based upon the sale of 2,770,891 shares at $10.00. Please reconcile
this with Pro Forma
         stockholders equity of $82,412 on page 50 as presented in "Pro Forma
Date" and or revise
         your disclosures accordingly, including for the issuance of the
various number of shares
         sold.
Item 16. Exhibits and Financial Statement Schedules, page II-3

5.       Please also include the participation interests in the Item 5 legal
opinion.
General

6.       Please provide us with supplemental copies of all written 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
         Jessica Livingston at (202) 551-3448 to discuss how to submit the
materials, if any, to us
         for our review.
7.       We note that the cover page of the registration statement indicates
that Cullman Bancorp,
         Inc. and Cullman Savings Bank Profit Sharing Plan are the registrants.
Please advise if
         Cullman Savings Bank Profit Sharing Plan is intended to be a
co-registrant or remove that
         entity as a registrant.
        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.
 John A. Riley, III
Cullman Bancorp, Inc. /MD/
April 7, 2021
Page 3

       You may contact David Irving at 202-551-3321 or Michelle Miller at
202-551-3368 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Livingston at 202-551-3448 or Sandra Hunter Berkheimer at
202-551-3758 with
any other questions.



FirstName LastNameJohn A. Riley, III                      Sincerely,
Comapany NameCullman Bancorp, Inc. /MD/
                                                          Division of
Corporation Finance
April 7, 2021 Page 3                                      Office of Finance
FirstName LastName