SecProbe.io

May 18, 2006

Mail Stop 4561

Mr. Thomas E. Hoaglin
Chairman, President, Chief Executive Officer, and Director
Huntington Bancshares Incorporated
41 S. High Street
Columbus, Ohio 43287
Via Mail and Facsimile (614) 480-5485

Re: Huntington Bancshares Incorporated
 Form 10-K for Fiscal Year Ended December 31, 2005
 Form 10-Q for Fiscal Quarter Ended March 31, 2006
 File No. 0-2525

Dear Mr. Hoaglin:

We have reviewed your letter filed on May 1, 2006 and have the following
comments.

Form 10-K for the Fiscal Year Ended December 31, 2005

Note 21, Derivative Financia l Instruments, page 127

1. We note your response to comment 10 of our letter dated April 13, 2006 that you
have used the short-cut method for hedgi ng subordinated debt (but not junior
subordinated debt held by trusts issuing equity  certificates or “trust  preferred” debt).
Please tell us whether any subordinated debt  has interest or other payment deferral
options and if so, how you account for the hedge along with the specific guidance
relied upon in making your determination.

2. Your response indicates that  you use a “quantitative mode l” to assess effectiveness
for both your fair value and cash flow hedges.   Please provide us with a more robust
discussion of the specific model or models used to assess effectiveness both at
inception and on an on going basis and the au thoritative literature you relied upon in
determining that the use of each specific model is appropriate.

3. We note you determined that your fair value hedges of certain mo rtgage loan sale
commitments were expected to be highly e ffective over the period while the loan is
held for sale.  In accordance with SFAS133 Implementation Issue F-11, please more clearly define for us the designate d hedge period over which you intend to
prospectively assess effectiveness as stat ed in your documented risk management

Mr. Thomas E. Hoaglin
Huntington Bancshares Incorporated
May 18, 2006 Page 2
strategy with this hedging relationship.  Pl ease provide us with a sample of this
documentation.

4. We note your response to comment 9 and A ttachment A in response to our letter
dated April 13, 2006.  In Attachment A you de fine the terms of the hedged item as
specifically identified fixed rate installment loans issued by The Huntington Bank.  Please clarify whether you are hedging individu al loans or a  portfolio of loans.  If
you are hedging a portfolio of loans, please provide us with a comprehensive analysis
explaining how you apply SFAS 133 Implem entation Issue F11 to these hedging
relationships.  Provide us with an exam ple demonstrating how you determine that a
pool of installment loans satisfy the re quirements of paragraph 21(a)1 of SFAS 133
regarding the grouping of similar assets and how the documented hedging strategy
meets the requirements of paragraph 20(b) of SFAS 133.

5. We note your response to comment 9 and A ttachment B in response to our letter
dated April 13, 2006 related to your comme rcial loans cash flow hedge.  In
Attachment B you define the terms of th e hedged item as specifically identified
payments on pools of variable rate loans i ssued by Huntington.  Please tell us how
you document the forecasted cash flows with sufficient specificity such that when the transaction occurs it is clear whether th at transaction is or is not the hedged
transaction.  Refer to SFAS Implementation Issue G13.

*****

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested inform ation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your responses to our comments.

You may contact Ben Phippen, Staff Accountant, at (202) 551-3697 or me at
(202) 551-3490 if you have questions.

       S i n c e r e l y ,

Donald A. Walker
        Senior Assistant Chief Accountant