CORRESP 1 filename1.htm

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,
	TOMPKINS FINANCIAL CORPORATION
	By:	/S/ Kathleen A. Manley
		Kathleen A. Manley,
		Assistant Vice President &
		Corporate Secretary