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Edward J.
Kelly, III

Chairman, President and

Chief Executive Officer

December 9, 2005

Securities and Exchange
Commission

450 Fifth Street, N.W.

Washington, DC  20549

  RE:

  Mercantile
  Bankshares Corporation

  Form 10-K
  for the Fiscal Year Ended December 31, 2004

  Filed
  March 15, 2004

  File
  No. 0-5127

Ladies and Gentlemen:

On
behalf of Mercantile Bankshares Corporation (‘Mercantile”) we hereby provide
below responses to comments set forth in John Nolan’s letter to Mr. Edward
J. Kelly, III, dated November 17, 2005.  We do not believe there is a need to revise
our above referenced document, but we will modify future filings as indicated
below.

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

Allocation
of Allowance for Loan Losses

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 loss 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
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.

Management’s
Response

Mercantile has not
changed its basic methodology during the four year period ended December 31,
2004.  The reference to “the inherent imprecision”
relates to the quantitative factors, qualitative factors and judgments by
management that are taken into consideration in calculating the overall
allowance and the allocation thereof.  In
a normalized period the application of our model would produce an unallocated
element of our allowance for loan losses.
In 2002 and 2003 we experienced a deterioration
in our commercial and leasing portfolios.
Some large credits were placed into the monitored category.  This category represents credits that are
still performing and may perform for some time, but display additional risk
characteristics suggesting they may be classified as nonperforming loans in the
near future.  As a result, based on
management’s judgment as to presentation, the unallocated reserve was allocated
to the commercial and leasing portfolio.
Mercantile had two credit exposures to a commercial loan customer, which
were secured by two airplanes being leased by a regional commercial
airline.  It was primarily this exposure
that led to the allocation of the unallocated portion of the allowance to the
commercial portfolio for the years ended December 31, 2002 and 2003.  Although these aircraft-related loans were
performing, Mercantile placed them on the “monitored loan list” and assigned a
portion of the unallocated allowance ($10.4 million) to these loans.  A payment to settle the largest loan ($14.1
million) was accepted in the fourth quarter of 2004, removing the uncertainty
surrounding this credit exposure.  The
smaller loan ($2.6 million) was settled in the second quarter of 2005.  The total loss recognized on these loans was
approximately $9 million.  In the year
ended December 31, 2004 we applied our model consistent with prior
years.  An improving economy, lower loss
experience and delinquencies reduced the qualitative factors utilized in the
determination of the allowance for loan losses.   The resulting unallocated portion of the
allowance was comparable to what was reported at December 31, 2001.  Since there were no significant loans
reported as monitored at December 31, 2004, Mercantile did not allocate
any of its unallocated allowance to portfolio loans.

Non-GAAP
Reconciliation

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 disclosure 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 Question 8 and 9 of the
Frequently Asked Questions Regarding the Use of Non-GAAP Financial Measures,
which indicated 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.

Management’s
Response

We believe these non-GAAP
measures provide information useful to investors in understanding our core
business, operational performance and trends.
Certain of the excluded items have historically been recurring in nature
such as gains and losses on the sale of securities and amortization of
intangibles and others have been non-recurring such as restructuring changes
and merger related expenses.  We believe
that our approach in excluding these items from the cash operating metrics is
consistent with the guidance provided in Items 8 and 9 of the FAQ.  These items are not excluded to “smooth” earnings, they are excluded because we believe that
excluding such items facilitates evaluation and comparison of results for our
core, ongoing business operations.  We
believe these measures are consistent with how investors and analysts typically
evaluate our industry and by providing them we facilitate their analysis.  We will continue to assess the relevance of
these disclosures on an ongoing basis.

Financial
Statement as of and for the Years ended December 31, 2004 and 2003

Note 1 -
Significant Accounting policies & Note 18 - Derivative Instruments and
Hedging Activities

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

Management’s
Response

Fair value for
derivatives is determined based on the following:

•              Position valuation, estimated by
using pricing models that incorporate quoted market prices for swap rates and
futures contracts, as well as market volatility, and assumes all counterparties
have the same credit rating;

•              Option valuation, estimated by
using standard market models (such as modified Black Scholes model on interest
rate options), incorporating quoted market prices and volatilities.

This fair value
disclosure for derivative instruments will be included in all future filings.

  Sincerely,

  /s/ Edward J.
  Kelly, III

  By: Edward J.
  Kelly, III

  Chairman of the
  Board,

  President and

  Chief Executive
  Officer