United States securities and exchange commission logo October 26, 2020 David Morris Chief Financial Officer RBB Bancorp 1055 Wilshire Boulevard Suite 1200 Los Angeles, California 90017 Re: RBB Bancorp Form 10-K for Fiscal Year Ended December 31, 2019 Response dated August 26, 2020 File No. 001-38149 Dear Mr. Morris: We have reviewed your August 26, 2020 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to our comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2019 Risks Related to an Investment in Our Common Stock, page 48 1. We note your response to comment one in our letter dated August 12, 2020. In your response, you state that the Company plans to adopt ASU 2016-13, Measurement of Credit Losses on Financial Instruments (Topic 326), commonly referred to as CECL, on January 1, 2023. We also note that you state you will cease being an emerging growth company ( EGC ) as of the end of 2022 given your 2017 initial public offering of common stock. Given that you will cease to be an EGC as of December 31, 2022, you are required to adopt Topic 326 in your December 31, 2022 Form 10-K, and not as of January 1, 2023. Please revise your disclosures in future filings and plan accordingly. David Morris RBB Bancorp October 26, 2020 Page 2 You may contact John Spitz, Staff Accountant, at (202) 551-3484 or Michael Volley, Staff Accountant, at (202) 551-3437 with any other questions. FirstName LastNameDavid Morris Sincerely, Comapany NameRBB Bancorp Division of Corporation Finance October 26, 2020 Page 2 Office of Finance FirstName LastName