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By EDGAR – As Correspondence
July 26, 2018
The Securities and Exchange Commission Division of Corporation Finance 100 F. Street, N.E. Washington, D.C. 20549
Attn: Division of Corporation Finance
RE: Tompkins Financial Corporation Registration Statement on Form S-3 File No.: 333-226312
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effectiveness of the above-referenced Registration Statement on Form S-3 of Tompkins Financial Corporation (the “Issuer”) be accelerated to Monday, July 30, 2018, at 4:00 p.m., or as soon thereafter as practicable.
| Very truly yours, |
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| TOMPKINS FINANCIAL CORPORATION |
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| By: |
/S/ Kathleen A. Manley |
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Kathleen A. Manley, |
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Assistant Vice President & |
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Corporate Secretary |
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