SecProbe.io

May 3, 2012
 Via E-mail

Charles Nugent Chief Financial Officer Fulton Financial Corporation One Penn Square P.O. Box 4887 Lancaster, PA 17604
Re: Fulton Financial Corporation
Form 10-K for the Fiscal Year ended December 31, 2011 Filed February 29, 2012 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 with  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.  Where we have requested changes in future filings, please incl ude a draft of your proposed disclosures that
clearly identifies new or revise d disclosures.  If you do not be lieve our comments apply to your
facts and circumstances, please tell  us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
            Form 10-K for the Fiscal Year ended December 31, 2011

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Provision and Allowance for Credit Losses, page 31

1. Please tell us and revise your disclosure on page 35 to clarify why the $55.5 million of
accruing TDRs described in footnote 3 to the non-accrual and past due loans and OREO
table is different from the $66.1 million of accruing TDR’s as of December 31, 2011
described in the TDR table at the bottom of the page.

 Charles Nugent Fulton Financial Corporation May 3, 2012 Page 2

Financial Statements

 Note A – Summary of Significant Accounting Poli cies - Allowance for Credit Losses, page 63

2. On page 64, you disclose that only impaired  TDRs are evaluated for impairment under
ASC 310-10-35.  We believe the guidance in ASC 310 indicates that a TDR is always
considered impaired and therefore impairment should be measured individually using the
guidance in ASC 310-10-35 for all TDRs.  Please tell us the amount of TDRs not
evaluated for impairment under ASC 310-10-35 at December 31, 2011 and the impact on your financial statements if you measured im pairment on these loans using the guidance
in ASC 310-10-35.
3. You disclose that prior to April 1, 2011 you evaluated impaired loans for impairment
every 12 months or, if necessary, on a more frequent basis based on significant changes
in expected future cash flows or signif icant changes in collateral values.

a. Please provide us additional details regarding your cont rols and procedures under
your prior methodology to measure impairm ent under ASC 310-10 at each quarter
end.

b. Specifically, explain to us how you ensured th at you identified all impaired loans that
had significant changes in expected future cash flows or significant changes in
collateral values at each quarter end.
c. Please tell us why you believe your  new methodology is preferable.
 Note D – Loans and Allowance for Credit Losses

 Credit Quality Indicators and N on-performing Assets, page 78

4. Please tell us and revise future filings to de scribe your credit quality  indicators including
qualitative information on how they relate to  the likelihood of loss.  Refer to ASC 310-
10-50-29(a) and 30.
              We urge all persons who are res ponsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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.

 Charles Nugent Fulton Financial Corporation May 3, 2012 Page 3

             In responding to our comments, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of  the United States.

You may contact Michael Volley at 202- 551-3437 or me at 202-551-3423 with any
questions.
Sincerely,
  /s/ Amit Pande
Amit Pande Accounting Branch Chief