SecProbe.io

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November 17, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (410)237-5427

Mr. Edward J. Kelly, III
President and Chief Executive Officer
Mercantile Bankshares Corporation
Two Hopkins Plaza
P.O. Box 1477
Baltimore, MD 21203

Re:	Mercantile Bankshares Corporation
	Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 15, 2005
	File No. 0-5127

Dear Mr. Kelly:

      We have reviewed your filing and have limited our review to
those issues we have addressed in the following comments.  Where
indicated, we think you should revise 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 detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

	Please understand that the purpose of our review 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.

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

Allocation of Allowance for Loan Losses, page 44

1. Please explain in your response letter the methodology used to
determine the unallocated portion of your allowance for loan
losses
and discuss the factors which led to the existence of an
unallocated
allowance for loan losses during 2004 versus no such allowance in
the
prior two years.  For example, you state on page 43 that the total
allowance for loan losses is comprised of specific allocations to
impaired loans, general allocations to pools of loans (not deemed
impaired) and an unallocated amount.  You further state on page 45
that the unallocated portion recognizes the imprecision inherent
in
estimating and measuring loss when allocating the allowance to
individual or pools of loans.  Given the disclosures provided, we
are
unclear how certain years reflect an inherent imprecision in this
determination, while other years have no apparent imprecision.
Please also revise future filing disclosures as necessary.

Non-GAAP Reconciliation, page 54

2. We note you are using a "cash operating efficiency ratio,"
"cash
operating earnings," and "diluted cash operating earnings per
share,"
which are non-GAAP financial measures.  Please explain in your
response letter why management believes that presentation of these
non-GAAP financial measures provides useful information to
investors
as required by Item 10(e)(i)(C) of Regulation S-K and revise your
disclosures as necessary.

3. In addition, please tell us in detail why you believe you have
demonstrated the usefulness to investors of these measures that
exclude recurring items.  Refer to Questions 8 and 9 of the
Frequently Asked Questions Regarding the Use of Non-GAAP Financial
Measures, which indicate that registrants must meet the burden of
demonstrating the usefulness of any measure that excludes
recurring
items, especially if that measure is used to evaluate performance.

Financial Statements as of and for the Years Ended December 31,
2004
and 2003

Note 1 - Significant Accounting Policies, page 65, and Note 18 -
Derivative Instruments and Hedging Activities, page 85

4. Please tell us how you determined the fair values of your
derivative instruments, including details of the method(s) and
significant assumptions used.  Refer to paragraphs 10-11 of FAS
107.
Please also provide these disclosures in future filings.

* * * * *

 As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment 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 cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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.

	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 advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Amanda Roberts, Staff Accountant, at
(202)551-
3417 or me at (202)551-3492 if you have questions.

      Sincerely,

      John P. Nolan
      Accounting Branch Chief

Mr. Edward J. Kelly
Mercantile Bankshares Corporation
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