SecProbe.io

June 30, 2008

Mail Stop 4561  Mr. R. Scott Smith, Jr.  Chairman, Chief Executive Officer, and President Fulton Financial Corporation  One Penn Square P.O. Box 4887 Lancaster, Pennsylvania 17604
Re: Fulton Financial Corporation
 Form 10-K for Fiscal Year Ended December 31, 2007
 Filed February 29, 2008  Form 10-Q for Fiscal Quarter Ended March 31, 2008  File Number: 000-10587
  Dear Mr. Smith:

We have reviewed your filings and have the following comments.  Please be as
detailed as necessary in your explanation.  In our comments, we may ask you to provide
us with supplemental information so we ma y better understand your disclosure.  After
reviewing this information, we may or  may not 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.

Mr. R. Scott Smith, Jr.
Fulton Financial Corporation
June 30, 2008 Page 2  Form 10-K, filed February 29, 2008

 Item 7A. Quantitative and Qualitative Disclosures About Market Risk

 Equity Market Price Risk, page 44

 1. We note your disclosure that you hold equity  securities of financial institutions
with a cost basis of $92.7 million and unrealized losses of $23.6 million as of
December 31, 2007.  We further note that you recorded an other than temporary
impairment charge of $292,000 in 2007 and $3.8 million in the first quarter of 2008 related to some of these equity securities, and that the cost basis and unrealized losses of these securities were $88.2 million and $21.6 million, respectively, at March 31, 2008. Please te ll us how you determined the amounts
of other-than-temporary impairment ch arges recorded during the year ended
December 31, 2007, and the quarter ended March 31, 2008, and your consideration of the guidance in Staf f Accounting Bulletin No. 59, SFAS 115, and
FASB Staff Position Nos. FAS 115-1 and FAS 124-1.  In your response, please
address the following:

• Provide us with a detail of each of the financial institution equity securities
you hold as of December 31, 2007, March 31, 2008 and June 30, 2008 with the attributable cost basis, fair values , unrealized gains/losse s, and duration of
unrealized loss, as applicable;
• How you considered the financial conditi on and near term prospects of the
issuers, and the severity and duration of the unrealized losses in determining
that no additional other-than-temporary impairment was required for each period; and
• How you determined the “reasonable period of time sufficient for a recovery
of fair value” with respect to these securities given the current market
conditions.
  Form 10-Q, filed May 12, 2008

 Notes to Consolidated Financial Statements, page 7

 2. Please tell us how you have complied with the disclosure requirements of paragraphs 19-22 of SFAS 115 or re vise future filings accordingly.

Mr. R. Scott Smith, Jr.
Fulton Financial Corporation
June 30, 2008 Page 3  Form 8-K, filed May 29, 2008

 Item 8.01 – Other Events, page 2

 3. We note your disclosure regarding your in tent to purchase student loan auction
rate certificates (ARCs) held  on behalf of customers of  Fulton Financial Advisors,
N.A. (FFA), given the failed auctions in the ARC markets and the resulting illiquidity that exists.  Please address the following:

• Tell us further the specific conditions or  events that would result in your
purchase of these investments from your customers.  We note your disclosure
that you intend to purchase these inve stments from time to time based on
when each customers’ liquidity need arises;
• Describe the methodology a nd tell us the specific assumptions used in
determining a $13 million liability rela ted to your expected purchases of
ARCs and the estimated fair values of those ARCs.  As necessary, please
consider providing us with a copy of the valuation report used in estimating the liability;
• Tell us the “other available inform ation” you relied upon to support your
estimate of this liability and whether this information resulted in an adjustment to the amount determined in the valuation report;
• How you determined that the fair value of the ARCs held by FFA customers
would be approximately 95% of their par value;
• Tell us how you considered the credit  quality of the ARC issuer(s) in
determining the FV and also in dete rmining whether to buyback these ARCs;
and
• Tell us if you have purchased or have formally committed to purchase any of
these ARCs from your customers.  If  so, please tell us the amount of the
purchase price, the purchase discount, and the estimated fair value of these
ARCs.

Additionally, please provide us  with the disclosures that you intend to include in
your Form 10-Q for the period ended J une 30, 2008, related to these purchases.

 As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Pl ease furnish a cover letter that keys your
response to our comments and provides a ny requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please understa nd that we may have
additional comments after reviewin g your response to our comments.

Mr. R. Scott Smith, Jr.
Fulton Financial Corporation June 30, 2008 Page 4    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing review ed by the staff to be certain that they have provided all
information investors require for an inform ed decision.  Since the company and its
management are in possession of all facts re lating 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities 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 comment on your filing.

You may contact John Spitz, Staff Accountant at (202) 551-3484, or me at (202)
551-3423, if you have questions re garding these comments.

Sincerely,

Amit Pande Assistant Chief Accountant