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Correspondence

August 25, 2011

Stephanie L. Hunsaker

Senior Assistant Chief Accountant

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

HUNTINGTON BANCSHARES INCORPORATED HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN
ACCORDANCE WITH 17 C.F.R. §200.83

    Re:

     Huntington Bancshares Incorporated

File No. 001-34073

Form 10-K for the fiscal year ended December 31, 2010, filed February 18, 2011

Form 10-Q for the fiscal quarter ended March 31, 2011, filed April 29, 2011

Dear Ms. Hunsaker:

This letter is in response to your letter dated July 18, 2011, regarding the Securities and
Exchange Commission Staff’s review of our Annual Report on Form 10-K for the fiscal year ended
December 31, 2010, filed on February 18, 2011, and our Form 10-Q for the fiscal quarter ended March
31, 2011, filed on April 29, 2011. For your convenience, we have included your comments below and
have keyed our responses accordingly.

It is our understanding from a conversation between our counsel and Rebekah Lindsey on July 25,
2011, that your comments were intended to be “futures” comments. Accordingly, in certain of our
responses, we have agreed to include changes or supplements to the disclosures in our future
filings and have included language to facilitate your review of those changes or supplements.
While we believe that these changes and supplements will improve our future disclosures, we do not
believe our prior filings are materially deficient or inaccurate.

Pursuant to 17 C.F.R. §200.83, we are requesting confidential treatment for a portion of our
response below. We request that this portion, as indicated by [***], be maintained in confidence,
not be made part of any public record, and not be disclosed to any person as it contains
confidential information. In the event that the Staff receives a request for access to the
confidential portions herein, whether pursuant to the Freedom of Information Act or otherwise, we
respectfully request that we be notified immediately so that we may further substantiate this
request for confidential treatment. Please address any notification of a request for access to
such information to the undersigned with a copy to General Counsel, Huntington Bancshares
Incorporated, 41 South High Street, HC1002, Columbus, OH 43215.

Form 10-K for the Fiscal Year ended December 31, 2010

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Provision for Income Taxes, page 48

1. Please revise to disclose the reasons for repatriating the $142 million in undistributed
earnings that were previously indefinitely invested outside the country and discuss the impact of
the transaction on your liquidity.

Management’s response

Our response to this request is contained in Exhibit A.

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Loan and Lease Credit Exposure Mix

Residential Loans, page 51

2. Please revise your discussion to disclose how many adjustable rate mortgage loans are in the
initial interest rate period. Disclose the balance of these loans by year of origination and
initial rate period and discuss how you consider upcoming interest rate changes in your
determination of the appropriate level of the allowance for loan losses.

Management’s response

We note your request to disclose how many adjustable rate mortgage loans (ARMs) are in the
initial interest rate period, the balance of these loans by year of origination, and the initial
interest rate period. However, the ARM statistics that we monitor,
and which we believe are more
relevant to the readers of our reports, include the dollar amount of the ARMs that are expected to
have interest rate resets, the date of the reset, and when the loan was originated. This
information, along with how we consider upcoming interest rate changes in determining the
appropriate level of the allowance for loan losses is included in the expanded discussion below.

In future filings, beginning with our Form 10-Q for the fiscal quarter ended June 30, 2011, we
will expand our discussion within MD&A to read as follows (underlining denotes additions to and
strikeouts indicate deletions from our current disclosures):

A majority of the loans in our portfolio are ARMS have
adjustable rates. These ARMs comprised approximately 54% of our total residential mortgage
loan portfolio at June 30, 2011. At June 30, 2011, ARM loans that were expected to have rates
reset through 2014 totaled $1.6 billion. These loans scheduled to reset are primarily associated
with loans originated subsequent to 2007, and as such, are not subject to the most significant
declines in value. Given the quality of our borrowers and the relatively low current interest
rates, we believe that we have a relatively limited exposure to ARM reset risk. Nonetheless, we
have taken actions to mitigate our risk exposure. We initiate borrower contact at least six months
prior to the interest rate resetting, and have been successful in converting many ARMs to
fixed-rate loans through this process. Our ARM portfolio has performed substantially better than
the fixed-rate portfolio in part due to this proactive management process.

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CRE Portfolio, page 55

3. We note your disclosure that 95% of your commercial real estate loans had guarantors. Please
revise your disclosure to address the following:

    •

    Disclose how you consider the guarantor support in your determination of the allowance
for loan losses. Describe your efforts to monitor the credit quality of the guarantor and
how the availability, or lack thereof, of credit quality information related to the
guarantor’s ability to repay the obligation is considered in your determination of the
appropriate level of the allowance for loan losses.

    •

    Disclose how often you pursue repayment from a guarantor and describe how successful
your efforts are to obtain repayment from guarantors. If your efforts are largely
unsuccessful or you typically do not obtain repayment from guarantors, tell us whether
your measure of impairment would materially change if you did not consider guarantor
support.

Management’s response

If our efforts to pursue repayment from guarantors was largely unsuccessful, our measure of
impairment would not materially change if we did not consider guarantor support.

In future filings, beginning with our Form 10-Q for the fiscal quarter ended September 30,
2011, we will expand our discussion of our noncore CRE portfolio within MD&A to read as follows:

Our standardized loan grading system considers many components that directly correlate to
loan quality and likelihood of repayment, one of which is guarantor support. On an annual basis,
or more frequently if warranted, we consider, among other things, the guarantor’s reputation and
creditworthiness, along with various key financial metrics such as liquidity and net worth,
assuming such information is available. Our assessment of the guarantor’s credit strength, or lack
thereof, is reflected in our loan risk ratings for such loans, which is directly tied to, and an
integral component of, our allowance for loan loss methodology. When a loan goes to impaired
status, viable guarantor support is considered in the determination of the recognition of a loan
loss.

If our assessment of the guarantor’s credit strength yields an inherent capacity to
perform, we will seek repayment from the guarantor as part of the collection process and have done
so successfully. However, we do not formally track the repayment success from guarantors.

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Risk Management and Capital

Table 23 — Accruing and Nonaccruing Troubled Debt Restructured Loans, page 64

4. We note your disclosure on page 64 that TDRs can be classified as either accrual or nonaccrual
loans, and that accruing TDRs are excluded from nonaccrual loans because the borrower remains
contractually current. However, we also note that you do not place loans on nonaccrual status until
they reach 90 days past due in the case of C&I and CRE loans, and not until 180 days for the
residential and home equity portfolio. Therefore, please clarify whether the TDR loans must be
contractually current with respect to principal and interest to be classified as an accruing TDR,
or whether your regular nonaccrual policies also apply to your TDR portfolio.

Management’s response

Our delinquency guidelines are the latest dates at which loans must be placed on
nonaccrual unless special circumstances, such as a government guarantee, exist. In many situations
we cease the accrual of interest prior to a loan reaching the stated delinquency because the
collection of principal and interest is in doubt or no longer probable.

Our treatment of nonaccrual TDRs is consistent with our standard nonaccrual policy described
in our financial statements, which is reflected in our response to your question number 22 below.

In future filings, beginning with our Form 10-Q for the fiscal quarter ended June 30, 2011, we
will revise our discussion within MD&A to read as follows:

TDRs are modified loans in which a concession is provided to a borrower experiencing financial
difficulties. Loan modifications are considered TDRs when the concessions provided are not
available to the borrower through either normal channels or other sources. However, not all loan
modifications are TDRs. Our standards relating to loan modifications consider, among other
factors, minimum verified income requirements, cash flow analysis, and collateral valuations. Each
potential loan modification is reviewed individually and the terms of the loan are modified to meet
a borrower’s specific circumstances at a point in time. All loan modifications, including those
classified as TDRs, are reviewed and approved by our Special Assets Department. Our ALLL
is largely driven by updated risk ratings assigned to commercial loans, updated borrower
credit scores on consumer loans, and borrower delinquency history in both the commercial and
consumer portfolios. As such, the provision for credit losses is impacted primarily by changes in
borrower payment performance rather than the TDR classification. TDRs can be classified as either
accrual or nonaccrual loans. Nonaccrual TDRs are included in NALs whereas accruing TDRs are
excluded because the borrower remains contractually current from
NALs as Management believes it is probable that all contractual principal and interest due under
the restructured terms will be collected.

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Table 24 — Accruing Past Due Loans and Leases and Accruing Troubled Debt Restructured
Loans

5. Considering the significance of your government guaranteed loans past due over 90 days and still
accruing to the total past due loans, please revise to disclose how you determined that it was
appropriate to continue the accrual of income on these loans. Discuss the types of losses you are
reimbursed for under the guarantees, whether you have recognized losses in excess of any of the
guarantee caps, and whether you have experienced any delays or denial of payments related to these
claims. Please provide this discussion by guarantee type (e.g. FHA or VA loans). Finally, please
disclose how much of your residential mortgage troubled debt restructurings consist of government
guaranteed loans.

Management’s response

We have determined that it is appropriate to continue to accrue the guaranteed rate of
interest on government guaranteed loans based on historical guarantee performance and our
expectation of future performance.

In future filings, beginning with our Form 10-Q for the fiscal quarter ended June 30, 2011, we
will include the following discussion within MD&A to read as follows:

Loans guaranteed by the U.S. government accrue interest at the rate guaranteed by the
government agency. We are reimbursed from the government agency for reasonable expenses incurred
in servicing loans. The FHA reimburses us for 66% of expenses, and the VA reimburses us at a
maximum percentage of guarantee which is established for each individual loan. We have not
experienced either material losses in excess of guarantee caps or significant delays or rejected
claims from the related government entities.

In addition, as we develop our 2011 third quarter disclosures to meet the requirements of
Accounting Standards Update 2011-02 — Receivables, we will disclose how much of our residential
mortgage troubled debt restructurings consist of government guaranteed loans. Although not a
troubled debt restructuring disclosure, on pages 90 and 91 of our June 30, 2011 Form 10-Q, Note 3
— Loans / Leases and Allowance for Credit Losses, we did quantify the amount of residential
mortgage loans 90 or more days past due and accruing ($110,954,000) that were guaranteed by the
U.S. government ($76,979,000).

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ACL, page 67

6. We note your disclosure that you “maintain two reserves, both of which in (y)our judgment are
adequate to absorb credit losses inherent in (y)our loan and lease portfolio.” Please revise your
disclosure, here and elsewhere as applicable, to state that you maintain your two reserves at a
level that is appropriate, if true.

Management’s response

In future filings, beginning with our Form 10-Q for the fiscal quarter ended June 30, 2011, we
will revise all general discussions of the reserve to include that we maintain reserves at a level
that is appropriate rather than adequate.

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Table 29 — Net Loan and Lease Charge-offs, page 72

7. We note that your charge-offs as a percent of average loans is significantly higher for
residential mortgages than it is for your home equity loans and that the rate of charge-offs do not
appear to be increasing in the same proportion. Please revise your disclosure to address the
following:

    •

    Expand your disclosure to discuss the reasons why you believe this trend is occurring.

    •

    For those loans that are secured by a second lien, disclose whether you have the
ability to track whether the first lien is in default if you do not hold or service it. If
not, disclose the steps you take to monitor the credit quality of the first lien and how
you factor your ability, or lack thereof, to do this in your determination of the
appropriate level of allowance for loan losses.

    •

    Revise to disclose the percentage of borrowers in the initial 10 year interest only
period. Disclose the percentage of borrowers in the initial 10 year period that are only
paying the minimum amounts due.

    •

    Disclose when these loans will begin amortizing. We note your tabular disclosure of the
amount of home equity loans in a first lien position and second lien position and the
delinquency status of each. The delinquency rates of your first and second lien home
equity loans appear to be lower than that of your residential mortgage portfolio. Please
revise your disclosure to discuss the differences in the delinquency rates of each type of
loan and the reasons for differences in these trends. Discuss whether you believe these
trends will change when the home equity loans begin to amortize.

Management’s response

Our residential mortgage portfolio continues to incur a loss rate in excess of the home equity
portfolio. We believe this is occurring due to the following:

    •

    the lower loss rate in the home equity portfolio is a function of a higher
quality customer base as measured by FICO distribution,

    •

    a substantial increase in the percentage of first-lien residential mortgage
loans with low LTVs comprising the continued growth in the home equity portfolio,

    •

    a change in the charge-off policy associated with the residential mortgage
portfolio implemented in 2010 which shortened the maximum timeframe to charge-off,

    •

    two NPL sales in the residential mortgage portfolio with resulting charge-offs,
and

    •

    continued performing residential mortgage sales of the higher quality
performing loans.

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This is not inconsistent with our expect