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Mail Stop 4561      July 29, 2008   Thomas E. Hoaglin Chief Executive Officer Huntington Bancshares Incorporated 41 S. High Street Columbus, OH 43287

Re: Huntington Bancshares Incorporated
 Form 10-K
Filed February 26, 2008  and Documents Incorporated by Reference
 File No. 000-02525

Dear Mr. Hoaglin:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K

Properties, page 15

1. It appears that you have not  previously filed the agr eement governing the lease of
your company headquarters.  Please either f ile it as an exhibit or advise the staff
as to why you believe Item 601(b)(10)(ii )(D) of Regulation S-K does not apply.

Thomas E. Hoaglin
Chief Executive Officer
Huntington Bancshares Incorporated Page 2  Risk Management and Capital, page 35

 2. We note from page 37 in Table 14 that  you have large concentrations of
commercial real estate loans in your loan portfolio.  Given this concentration, the
increased risks associated with this type of lending and the well-publicized
slowdown and stresses in the commercial r eal estate market in certain states
(including Michigan and Ohio ), please revise your future filings to provide
detailed disclosure regarding your risk management practices with respect to
commercial real estate lending.  Please pr ovide us with your proposed disclosure.
Consider addressing the following in your revised disclosures:

• Describe the significant terms of each t ype of commercial real estate loan
product offered, including underwriting standards used for each product,
maximum loan-to-value ratios and ho w credit management monitors and
analyzes key features, such as loan-t o-value ratios and collateral values,
and changes from period to period;

• Explain how often you obtain updated appraisals;

• Describe risk mitigation transactions used to reduce credit risk exposure,
such as insurance arrangements, credit default agreements or credit
derivatives, and disclose the impact that such mitigation strategies have had on your financial statements;

• Disclose the degree to which you perfo rm portfolio-level stress tests or
sensitivity analysis to quantify the impact of changing economic
conditions on asset quality, earnings and capital; and

• Disclose trends related to commercial real estate loans that may result in
higher credit risk that are reasonably likely to have a material favorable or
unfavorable impact on net in terest income after the provision for loan loss.

3. We refer to your disclosure in Table 16 on page 39 concerning your commercial
real estate loans by property type a nd borrower location.  In light of the
significant deterioration in the commercial real estate markets in certain geographical areas, including Michigan a nd Ohio, please revise future filings to
disclose your credit quality indicators (e.g. charge-offs, nonperforming, accruing past due 90 days) by geographic region (s tate or locality) and product type
(middle market commercial real estate loans and small business commercial real
estate loans).  Please provide us  with your proposed disclosure.

Thomas E. Hoaglin
Chief Executive Officer
Huntington Bancshares Incorporated Page 3  Table 21- Summary of Allowance for Credit  losses and Related Statistics, page 45

 4. We note from your disclosure on page 23 in Table 2 that you recorded $280
million and $117 million related to the Fra nklin restructuring and the Franklin
facility C loan, respectively.  It is not clear, however, where such charge-offs are included in Table 21.  Please advise in future filings to clarify.

Credit Ratings, page 55 of the Annual Report

 5. You have included in this section the cr edit ratings assigned by S&P, Moody’s,
and Fitch.  In the future, please consider including a statement informing investors
that a security rating is not a recommenda tion to buy, sell or hold securities, that it
may be subject to revision or withdraw al at any time by the assigning rating
organization, and that each rating should be evaluated independently of any other
rating.  Refer to Item 10(c)(2)(i) of Regulation S-K.
 Notes to Consolidated Financial Statements

 Note 4.  Investment Securities, page 87

 6. We note you recognized losses relating to Asset-backed securities that were
identified as other-than-temporarily impaired of $43.3 million and $26.4 million in 2007 and 2006, respectively.  Please tell us  the facts and circumstances related
to, and the specific distinguish ing characteristics of, the se curities that were other
than temporarily impaired during the pe riods presented.  Specifically highlight
why certain securities were considered other than tem porarily impaired while the
remainder of your Asset-backed securities portfolio was not and indicate the literature that the impairments were taken under.
   *  *  *  *  *
 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are

Thomas E. Hoaglin
Chief Executive Officer Huntington Bancshares Incorporated Page 4  responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     You may contact William Schroeder, Staff Accountant, at (202) 551-3294 or
David Irving, Staff Accountant, at (202) 551-3321 if you have questions regarding
comments on the financial statements and related matters.  Please contact Matt McNair, Staff Attorney, at (202) 551-3583 or me at  (202) 551-3419 with any other questions.

Sincerely,

Christian Windsor Special Counsel