July 11, 2019

Kelly Potes
Chief Executive Officer
ChoiceOne Financial Services, Inc.
109 East Division
Sparta, MI 49345

       Re: ChoiceOne Financial Services, Inc.
           Registration Statement on Form S-4
           Filed June 17, 2019
           File No. 333-232157

Dear Mr. Potes:

       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-4 filed June 17, 2019

General

1.     Please provide us supplementally with copies of any board books or
similar materials that
       the financial advisors presented to the ChoiceOne or County boards in
connection with
       their fairness opinions.
 Kelly Potes
FirstName LastNameKelly Potes
ChoiceOne Financial Services, Inc.
Comapany NameChoiceOne Financial Services, Inc.
July 11, 2019
July 11, 2019 Page 2
Page 2
FirstName LastName
The Merger
Background of the Merger, page 40

2.       You disclose that between February 12, 2019 and early March 2019, the
parties discussed
         and negotiated various terms of the merger agreement. Please revise to
disclose in greater
         detail the terms that were negotiated, revised and agreed upon. In
particular, your revised
         disclosure should disclose and quantify, as applicable:
           the price negotiations between ChoiceOne and County, including the
exchange ratio
             and special dividend amounts; and
           the "unresolved issues" discussed by the County board of directors
on February 20,
             2019.
ProBank Austin's Compensation and Other Relationships with ChoiceOne and
County, page 56

3.       Please revise to quantify the fee that ChoiceOne paid to ProBank
Austin when it rendered
         its fairness opinion and the specific amount and percentage of the fee
that is contingent
         upon completion of the merger. Refer to Item 4(b) of Form S-4 and Item
1015(b)(4) of
         Regulation M-A.
Board of Directors and Management Following the Merger, page 65

4.       We note your disclosure that Bruce J. Cady will serve as the Vice
Chairman of the board
         of directors of ChoiceOne after the merger. Please file the written
consent of Mr. Cady as
         required by Securities Act Rule 438.
Certain Directors and Executive Officers of County Continuing with ChoiceOne
After the
Merger, page 123

5.       Please provide the information required by Item 402 of Regulation S-K
for Mr. Cady and
         Mr. Burke. Refer to Item 18.(a)(7)(ii) of Form S-4.
Exhibits

6.       Please have counsel remove the assumption on page 2 of Exhibit 5.1
that the Articles of
         Amendment will have become effective under the Michigan Business
Corporation Act. It
         is not appropriate for counsel to assume that the registrant is
legally incorporated. For
         more information, refer to Section II.B.3.a. of Staff Legal Bulletin
No. 19.
7.       We note that the tax opinion filed as Exhibit 8.1 is a short-form tax
opinion. Please revise
         the tax disclosure in the proxy statement/prospectus to clearly state
that the disclosure in
         the tax consequences section of the proxy statement/prospectus is the
opinion of the
         named counsel, or provide a long-form tax opinion. For more
information, refer to Section
         III.B. of Staff Legal Bulletin No. 19.
 Kelly Potes
FirstName LastNameKelly Potes
ChoiceOne Financial Services, Inc.
Comapany NameChoiceOne Financial Services, Inc.
July 11, 2019
Page 3
July 11, 2019 Page 3
FirstName LastName
8.       Refer to the following language in Exhibits 99.5 and 99.6: ". . . we
disclaim that we come
         within the category of persons whose consent is required under Section
7 of the Securities
         Act of 1933 . . . ." Please obtain and file revised consents that do
not include this
         disclaimer. Please refer to Securities Act Section 7(a).
        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, Staff Accountant, at (202) 551-3484 or
Michael Volley,
Staff Accountant, at (202) 551-3437 if you have questions regarding comments on
the financial
statements and related matters. Please contact David Lin, Staff Attorney, at
(202) 551-3552 or
Erin Purnell, Staff Attorney, at (202) 551-3454 with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Financial Services