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                                                            September 19, 2024

Josephine Iannelli
Chief Financial Officer
Bar Harbor Bankshares
PO Box 400, 82 Main Street
Bar Harbor, ME 04609-0400

        Re: Bar Harbor Bankshares
            Form 10-K for Fiscal Year Ended December 31, 2023
            File No. 001-13349
Dear Josephine Iannelli:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2023
Non-GAAP Financial Measures, page 45

1.      We note your presentation of a non-GAAP financial measure for "Tangible
book value
        per share, excluding securities adjustment," which represents the
exclusion of the total
        unrealized loss on available-for-sale securities recorded within total
common
        shareholders' equity. This represents an individually tailored
accounting measure given
        that the adjustment to exclude the unrealized (loss) gain on securities
has the effect of
        changing the recognition and measurement principles required to be
applied in accordance
        with GAAP. Therefore, please remove the presentation of this non-GAAP
measure from
        your future filings. Refer to Question 100.04 of the Division of
Corporation Finance   s
        Compliance & Disclosure Interpretations on Non-GAAP Financial Measures
and Rule
        100(b) of Regulation G.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
 September 19, 2024
Page 2

       Please contact Mengyao Lu at 202-551-3471 or Robert Klein at
202-551-3847 with any
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Finance
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