February 6, 2017
Via EDGAR
David Lin
Attorney-Advisor
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: | Community Bank System, Inc. Amendment No. 1 to Registration Statement on Form S-4 Filed January 25, 2017 File No. 333-214961 |
Dear Mr. Lin:
Pursuant to discussions with the Staff, Community Bank System, Inc. is today filing by electronic submission Amendment No. 2 to the above-referenced Registration Statement, including a revised Exhibit 8.1 to reflect the Staff’s comments.
We have provided under separate cover for your convenience a marked copy of such Amendment No. 2.
If you have any questions or comments or require further information with respect to the foregoing, please do not hesitate to call me at (212) 504-6889.
Sincerely,
/s/ Andrew P. Alin
Andrew P. Alin
Partner