SecProbe.io

December 16, 2011
 Via E-mail

Mr. Stephen D. Steinour Chief Executive Officer Huntington Bancshares Incorporated 41 South High Street Columbus, Ohio 43287
Re: Huntington Bancshares Incorporated
Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 18, 2010
  Form 10-Q for Fiscal Quarter Ended September 30, 2011   Filed October 31, 2011        Response dated December 13, 2011   File No. 001-34073

Dear Mr. Steinour:
 We have reviewed your correspondence f iled with the Commission on December 13,
2011 and have the following additional 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 within ten bus iness days by amending your future filings, by
providing the requested information, or by advi sing us when you will provide the requested
response.  Where we have requested changes in  future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosu res.  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 any amendment to your filing and the information you provide in
response to these comments, including the draf t of your proposed disclosures, we may have
additional comments.             Form 10-Q for the Fiscal Period Ended September 30, 2011

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
NPAs, NALs, and TDRs
TDR Loans, page 40

1. We note your response to our previous comm ent eight in our letter dated December 7,
2011.  Please tell us the following information:

 Mr. Stephen D. Steinour Huntington Bancshares Incorporated December 16, 2011 Page 2

  In your response, you state th at you “routinely make modifi cations such as these in
the normal course of business to borrow ers who are performing according to the
restructured contractual term s of the loan if the borrower is no longer experiencing
financial difficulties.”  Please clarify whet her you also make these modifications for
all borrowers in the normal course of business or whether you only provide these
modifications once a loan has been a pe rforming TDR for an acceptable period of
time or at maturity of the TDR.
 Please clarify whether the market rate of inte rest that typically o ccurs in the new loan
is at a higher rate or lower rate than the rate immediately prior in the restructured
loan.
 Please tell us whether the modifications to these loans are considered more than
minor under ASC 310-20-35-10.

             We urge all persons who are res ponsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
You may contact Rebekah Li ndsey at (202) 551-3303 or me at (202) 551-3512 if you
have questions regarding these comments.
Sincerely,

 /s/ Stephanie L. Hunsaker
Stephanie L. Hunsaker Senior Assistant Chief Accountant