SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

June 28, 2010
By U.S. Mail and Facsimile to: (717) 295-5312

Charles J. Nugent Senior Executive Vice Presiden t and Chief Financial Officer
Fulton Financial Corporation One Penn Square P.O. Box 4887 Lancaster, Pennsylvania 17604
Re: Fulton Financial Corporation
Form 10-K for the Fiscal Year Ended December 31, 2009 Form 10-Q for the Quarterly Period Ended March 31, 2010 File No. 000-10587

Dear Mr. Nugent:

We have reviewed your filings and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circumstan ces, please tell us why in
your response.
 After reviewing the information you provide  in response to these comments, we
may have additional comments.

Form 10-K for the Fiscal Year Ended December 31, 2009

Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note D – Loans and Allowance for Credit Losses, page 67
 1. We note your disclosures on pages 38  and 56 describing your methodology for
measuring loans for impairment and your  disclosure on page 68 that you had
approximately $474.3 million of impaired loans with a specific valuation
allowance of $127.0 million and $295.6 million in  impaired loans without specific
valuation allowances at December 31, 2009.  Please provide us with the following
information and revise your future filings accordingly:

Charles J. Nugent
Fulton Financial Corporation June 28, 2010 Page 2

• The amount and / or percentage of lo ans that were considered collateral
dependent;

• The amount of loans measured using each  of the methodologies described on
pages 38 and 56 (i.e., presen t value of expected futu re cash flows discounted
at the loan’s effective interest rate, or at the loan’s observable market price or at the fair value of the collateral if the loan is collateral dependent);

• As it relates to collateral  dependent loans, a compre hensive discussion of the
methods used to estimate the fair value.  When describing the appraisal
process, please address how often you obtain updated appraisals for your
collateral and in the event you use automated valuation methodologies,
explain the procedures you perform to va lidate the results of these valuation
methodologies in the event they are not based on current appraisal data;

• The approximate amount or percentage  of impaired loans for which the
company relied on current third party apprai sals of the collateral to assist in
measuring impairment versus those for which current appraisals were not
available;

• The typical timing surrounding the recogni tion of a collateral dependent loan
as nonperforming, when you order and receive an appraisal, and the
subsequent recognition of a ny provision or related charge-off. In this regard,
tell us if there have been any signifi cant time lapses during this process;
 • In more detail, the procedures you perf orm to monitor thes e loans between the
receipt of an original apprai sal and the update d appraisal;

• Whether you have charged-off an amount different from what was determined
to be the fair value of the collateral as  presented in the appraisal for any period
presented.  If so, please tell us the am ount of the difference and corresponding
reasons for the difference, as applicable;

• How you account for any partially charged- off loans subsequent to receiving
an updated appraisal. In this regard, sp ecifically tell us your policies regarding
whether or not these loans return to performing or remain in a non-performing
status, in addition to whethe r or not any of the terms of  the original loans have
been modified (e.g. loan extension, changes to interest rates, etc);

• In the event that you do not use external appraisals to  fair value the underlying
collateral for impaired loans or in cases where the appraisal has not been
updated to reflect current market conditions, please provide us with a

Charles J. Nugent
Fulton Financial Corporation June 28, 2010 Page 3

comprehensive response which discusses your process and procedures for
estimating the fair value of the collateral for these loans; and

• For those loans where you determined that no specific valuation allowance
was necessary, the substantive reas ons to support this conclusion.

In the event these policies vary by lo an type, please consider providing
disaggregated disclosures to  explain your policy for measuring impairment.  In
addition, please provide sim ilarly enhanced disclosure in your fair value footnote
as it relates to these assets that are meas ured at fair value on a nonrecurring basis.

2. As a related matter, we were unable to locate disclosure in  your March 31, 2010
Form 10-Q quantifying the amount of speci fic reserve associated with your
impaired loans.  Please tell us the am ount of the specific reserve at March 31,
2010 and revise future filings to disclose as of each balance sh eet date presented,
the amount of impaired loans for which there is a related allowance for credit
losses determined in accordance with ASC 310-10-35 and the amount of that allowance and the amount of impaired lo ans for which there is no allowance for
credit losses.  Refer to ASC 310-10-50-15.

Note I – Short-term borrowings and long-term debt, page 72

3. Please tell us, and revise future filings to disclose, whether you account for your
repurchase agreements as collateralized fi nancing transactions or sales.  If you
have any repurchase agreements account ed for as sales, please quantify the
amount sold for each period presented and the accounting guidance on which you relied for this treatment.

Exhibits and Financial Statement Schedules, page 102

4. We note your disclosure on pages 23-25 of your definitive proxy statement
regarding a Variable Compensation Plan.  It does not appear, however, that you
have filed this plan as an exhibit to the Form 10- K.  Please tell us how you
concluded that you were not required to file the plan as an exhib it.  Refer to Item
601(b)(10)(iii)(A) of  Regulation S-K.
 Form 10-Q for the Quarterly Period Ended March 31, 2010

Exhibits 31.1 and 31.2

5. We note that Exhibits 31.1 and 31.2 to th e Form 10-Q contain modifications of
the exact form of certification as set fort h in Item 601(b)(31) of Regulation S-K.
In particular, you omitted “(the registrant’s fourth fiscal quarter in the case of an

Charles J. Nugent
Fulton Financial Corporation June 28, 2010 Page 4

annual report)” from paragraph 4(d).  In future filings, please ensure that the
certifications are in the exact form as set forth in Item 601(b) (31) of Regulation
S-K, except as otherwise indicated in Commission statements or staff
interpretations.

Closing 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 the information the Securities
Exchange Act of 1934 and all applicable Exch ange Act rules require.  Since the company
and its management are in possession of all f acts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy  of the disclosures they have made.
 In responding to our comments, please provide a written 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.
You may contact Benjamin Phippe n at (202) 551-3697 or Amit Pande,
Accounting Branch Chief, at (202) 551-3423 if you have questions regarding comments
on the financial statements and related matte rs.  Please contact Justin Dobbie at (202)
551-3469 or me at (202) 551-3434 with any other questions.

Sincerely,

Michael R. Clampitt Senior Attorney Advisor