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                           August 12, 2020

       Laura Steele
       Controller
       Arrow Financial Corporation
       250 Glen Street
       Glens Falls, NY 12801

                                                        Re: Arrow Financial
Corporation
                                                            Registration
Statement on Form S-3
                                                            Filed August 10,
2020
                                                            File No. 333-243662

       Dear Ms. Steele:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact John
Stickel at 202-551-3324 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Finance