ARROW FINANCIAL CORP — Capital/Financing Update 2021

Aug 18, 2021

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August 18, 2021

VIA EDGAR AND EMAIL

Securities and Exchange Commission

100 F. Street, NE

Washington, DC 20549-4720

Attention: Ms. Jessica Livingston

Division of Corporate Finance

Re: Arrow Financial Corporation

Registration Statement on Form S-3 filed August 6, 2021

File No. 333-258552

Dear Ms. Livingston:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Arrow Financial Corporation (the “Company”) hereby requests acceleration of effectiveness of the above-referenced Registration Statement so that it will be declared effective at 4:00 p.m. Eastern Time on August 23, 2021, or as soon as practicable thereafter.

If you have any questions with respect to the foregoing, please contact me at (518) 745-1000. Thank you very much.

Very truly yours,

ARROW FINANCIAL CORPORATION

By: /s/ Edward J. Campanella

Senior Vice President, Treasurer and

Chief Financial Officer

cc: Michele C. Kloeppel, Thompson Coburn LLP