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SEC Company Response from INDEPENDENT BANK (IBCP) — Oct 28, 2010

INDEPENDENT BANK CORP /MI/ (IBCP) (CIK 0000039311)
Date: Oct. 28, 2010 · CIK: 0000039311 · Accession: 0000926044-10-000336

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File numbers found in text: 333-169200

Date
October 28, 2010
Author
Independent Bank Corporation
Form
CORRESP
Company
INDEPENDENT BANK CORP /MI/ (IBCP) (CIK 0000039311)

Letter

Division of Corporation Finance Securities and Exchange Commission Re: Independent Bank Corporation Registration Statement on Form S-1 File No. 333-169200

Dear Mr. Seaman:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Independent Bank Corporation (the "Company") requests that the effectiveness of the above referenced Registration Statement on Form S-1, as amended, be accelerated to November 1, 2010 at 3:00 p.m. Eastern Time, or as soon as possible thereafter.

In connection with the foregoing request for acceleration of effectiveness, the Company acknowledges that:

· should the Securities and Exchange Commission (the "Commission") or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

· the action of the Commission or staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

· the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Securities and Exchange Commission

Division of Corporation Finance

October 28, 2010

Page 2

Please contact the undersigned at (616) 522-1765 with any questions you may have concerning this request. In addition, please contact the undersigned when this request for acceleration has been granted.

Very truly yours,
Independent Bank Corporation

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CORRESP
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   ibc-corresp_10281021.htm - Generated by SEC Publisher for SEC Filing

October 28, 2010

Filed Via Edgar

Michael Seaman

Special Counsel

Division of Corporation Finance

Securities and Exchange Commission

100 F Street NE

Washington, DC 20549-4561

  Re:

  Independent Bank Corporation

  Registration Statement on Form S-1

  File No. 333-169200

Dear Mr. Seaman:

            Pursuant to Rule 461 promulgated under the
Securities Act of 1933, as amended, Independent Bank Corporation (the
"Company") requests that the effectiveness of the above referenced
Registration Statement on Form S-1, as amended, be accelerated to November 1,
2010 at 3:00 p.m. Eastern Time, or as soon as possible thereafter.

            In connection with the foregoing request for
acceleration of effectiveness, the Company acknowledges that:

·
should the Securities and Exchange Commission (the
"Commission") or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking
any action with respect to the filing;

·
the action of the Commission or staff, acting pursuant to
delegated authority, in declaring the filing effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

·
the Company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

Securities and Exchange Commission

Division of Corporation Finance

October 28, 2010

Page 2

Please contact the undersigned at (616) 522-1765 with any questions you may have concerning this request. In addition, please contact the undersigned when this request for acceleration has been granted.

Very truly yours,

Independent Bank Corporation

/s/ Robert N. Shuster

Robert N. Shuster

Executive VP and Chief Financial Officer

c:         Kimberly Baber, Varnum LLP