United States securities and exchange commission logo





                             April 7, 2021

       Joseph B. Zanco
       President and Chief Executive Officer
       Catalyst Bancorp, Inc.
       235 N. Court Street
       Opelousas, Louisiana 70570

                                                        Re: Catalyst Bancorp,
Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed March 12,
2021
                                                            File No. 333-254200

       Dear Mr. Zanco:

              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

       Cover Page

   1.                                                   We note that you are
making the subscription offer to eligible depositors. Please note on
                                                        the cover page the
minimum balance required to be eligible to participate in the offer, if
                                                        any, or state that no
minimum balance is required.
       Summary, page 1

   2.                                                   Consistent with your
disclosure on page 97, please disclose in the summary that upon
                                                        completion of the
conversion, St. Landry Homestead Federal Savings Bank will cease to
                                                        have members and former
members will no longer have voting rights, and that all voting
                                                        rights in St. Landry
Homestead Federal Savings Bank will be vested in Catalyst Bancorp
                                                        as the sole shareholder
of St. Landry Homestead Federal Savings Bank.
 Joseph B. Zanco
FirstName   LastNameJoseph B. Zanco
Catalyst Bancorp,  Inc.
Comapany
April       NameCatalyst Bancorp, Inc.
       7, 2021
April 27, 2021 Page 2
Page
FirstName LastName
How We Determined the Offering Range and the $10.00 per Share Offering Price,
page 4

3.       Please briefly summarize the primary differences between the
registrant and the peer
         group used by the appraiser and the reasons for the downward
adjustments made for
         profitability growth and viability of earnings, and for primary market
area as discussed on
         page 98.
Our emphasis on residential mortgage loans exposes us to lending risks, page 14

4.       We note from your disclosure here and on page 58 that a "significant"
portion of your
         one- to four-family residential loans are considered non-conforming
loans. Please clarify
         the percentage of such loans that are non-conforming, and discuss
further any associated
         risk with originating a significant number of non-conforming loans.
The geographic concentration of our loan portfolio, page 15

5.       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.
The building of market share through our branch office strategy, page 17

6.       We note your plan to open a new branch office by the end of 2021, with
additional
         offices possible after conversion. Please disclose the anticipated
costs to open new
         branches as well as the anticipated and/or historical timeframe before
branch offices
         become profitable.
Security breaches and cybersecurity threats could compromise our information
and expose us to
liability, page 19

7.       Please clarify whether you have experienced any material breaches of
the types you
         reference. Refer to CF Disclosure Guidance: Topic No. 2 -
Cybersecurity,
         and Commission Statement and Guidance on Public Company Cybersecurity
Disclosures,
         Release No. 33-10459. Also, to the extent cybersecurity risks are
material to your
         business, please disclose under another appropriately captioned
section the nature of the
         board   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.
Comparison of Financial Condition At December 31, 2020 and December 31, 2019
Borrowings, page 47

8.       We note disclosure that during the fourth quarter of 2020 you repaid
$25 million of
         outstanding FHLB advances, of which $10 million was treated as a debt
modification. As
         a result, prepayment penalties of $1.5 million were charged to
earnings with $1.2 million
         in prepayment penalties being deferred and amortized as an adjustment
to interest
         expense. Please tell us and revise your filing to explain how you
determined the $10
 Joseph B. Zanco
Catalyst Bancorp, Inc.
April 7, 2021
Page 3
         million in restructured FHLB debt represented a modification rather
than an
         extinguishment of debt. Please refer to ASC 470-50-40-9 through 40-10
for guidance.
Transactions With Related Persons, page 93

9.       Please disclose in this section the loans made to officers and
directors discussed on pages
         F-26, to the extent that these meet the criteria for transactions with
related persons
         pursuant to Item 404 of Regulation S-K.
        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 John Spitz at 202-551-3484 or Ben Phippen at
202-551-3697 if you
have questions regarding comments on the financial statements and related
matters. Please
contact John Stickel at 202-551-3324 or John Dana Brown at 202-551-3859 with
any other
questions.



FirstName LastNameJoseph B. Zanco                              Sincerely,
Comapany NameCatalyst Bancorp, Inc.
                                                               Division of
Corporation Finance
April 7, 2021 Page 3                                           Office of
Finance
FirstName LastName