March 21, 2019

Curtis C. Griffith
Chairman and Chief Executive Officer
South Plains Financial, Inc..
5219 City Bank Parkway
Lubbock, Texas 79407

       Re: South Plains Financial, Inc.
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted on March 14, 2019
           CIK No. 0001163668

Dear Mr. Griffith:

      We have reviewed your amended draft registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form S-1 Filed March 14,
2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Nonperforming Loans, page 59

1.     Please revise your nonperforming assets table at the bottom of page 60
to include any
       troubled debt restructurings (TDRs) which are not already included in
your nonperforming
       assets categories. Please see III.C.1.(c) of Industry Guide 3,
Statistical Disclosure by
       Bank Holding Companies.
2.     Please revise your disclosure on page 60 to clarify how the commercial
real estate
       relationship in the amount of $5.3m in nonperforming loans was resolved.
 Curtis C. Griffith
South Plains Financial, Inc..
March 21, 2019
Page 2
Consolidated Balance Sheets, page F-3

3.       We note your disclosure on page ii, and elsewhere throughout your
draft registration
         statement, that your prospectus has given effect to a 29-for-1 stock
split and that the split
         has been retroactively applied to all periods presented. Please revise
your financial
         statements and all related footnotes (e.g., subsequent events in Note
1, Earnings Per Share
         data in Note 15, etc.) to reflect the stock split. Refer to ASC
505-20-S50-2 and SAB Topic
         4.C.
Notes to the Consolidated Financial Statements
1. Summary of Significant Accounting Policies, page F-13

4.       Tell us the factors you considered in your determination that this
reclassification was a
         change in accounting principle rather than the correction of an error,
refer to ASC 250 in
         your response. Please advise or revise as necessary.
       You may contact Michael Henderson at 202-551-3364 or Hugh West at
202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Michael Clampitt at 202-551-3434 or Pam Long at 202-551-3765 with any
other
questions.



FirstName LastNameCurtis C. Griffith                           Sincerely,
Comapany NameSouth Plains Financial, Inc..
                                                               Division of
Corporation Finance
March 21, 2019 Page 2                                          Office of
Financial Services
FirstName LastName