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By EDGAR – As Correspondence

August 1, 2024

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.: 333-281027

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 Tuesday, August 6, 2024, at 4:30 p.m., or as soon thereafter as practicable.

	Very truly yours,
	TOMPKINS FINANCIAL CORPORATION
	By:	/s/ Cynthia M. Manuele
		Cynthia M. Manuele
		Deputy Corporate Secretary