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Confidential treatment of portions of this letter has been requested by Fulton Financial
Corporation pursuant to 17 C.F.R. § 200.83. Exhibits I, II, III and IV to this letter, for which
confidential treatment has been requested, have been omitted and filed separately with the
Securities and Exchange Commission.

(717) 291-2473

July 25, 2008

Mr. Amit Pande

Assistant Chief Accountant

Mail Stop 4561

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

    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. Pande:

Fulton Financial Corporation (the “Company”) submits this letter in response to comments of the
staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated June 30,
2008 relating to the above-referenced filings. In this letter, we have recited the comments from
the staff in italicized, bold type and have followed each comment with the Company’s response.

    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 $3.6 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 tell us how you determined the amounts of
other-than-temporary impairment charges recorded during the year ended December 31, 2007, and
the quarter ended March 31, 2008, and your consideration of the guidance in Staff Accounting
Bulletin No. 59, SFAS 115, and FASB Staff Position Nos. FAS 115-1 and FAS 124-1.

    Response — The Company has a policy regarding evaluation of other-than-temporary
impairment of bank stocks that we believe is consistent with the guidance contained in Staff
Accounting Bulletin No. 59, SFAS 115 and FASB Staff Position Nos. FAS 115-1 and FAS 124-1. Our
policy provides the following —

Prior to each quarter end a review will be performed of all holdings that
exhibit an unrealized loss greater than $50,000 and 20% of cost,
regardless of how long that unrealized loss has existed. These thresholds
are determined based upon materiality due to cost-benefit analysis of
reviewing every single security that may have a decline in value. In
addition, holdings that exhibit an unrealized loss greater than $50,000
and greater than 10%, where an unrealized loss has existed on a continuous
basis for more than 18 months, will also be reviewed.

In assessing whether a decline in market price is other-than-temporary, it
is important to consider the difference between a decline in market price
that results from an adverse change in the issuer, as contrasted with a
decline that results from a downward movement of the market as a whole,
sector rotations or other similar events common to other issuers.
Other-than-temporary impairment exists when the decline in price arises in
conjunction with specific adverse conditions affecting a particular
investment and its near-term prospects, including specific adverse
conditions that have developed in the industry or in a geographic area.
Additional indicators include the deterioration in the

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financial condition of the issuer or a reduction or elimination of
dividends. Hence, for other-than-temporary impairment to exist, something
more than just a decline in market price (below that at which the
investment is recorded) has to have occurred. The following factors will
be considered in evaluating whether an individual holding has experienced
a decline that is other-than-temporary -

    •

    The length of time and the extent to which the market value has
been less than cost.

    •

    The financial condition and near-term prospects of the issuer,
including any specific events which may influence the operations of
the issuer.

    •

    Our intent and ability to retain the investment security for a
period of time sufficient to allow for any anticipated recovery in
market value.

    •

    The performance of the security relative to broader market
indices.

    •

    Recent losses of the issuer, if any.

    •

    Independent auditors’ report on most recent financial statements.

    •

    Dividend policy of the issuer at the date of acquisition relative
to dividend policy at date of evaluation.

    •

    Relationship of market prices per share to book value per share at
date of acquisition vs. evaluation date.

    •

    Buy/hold/sell recommendations of investment analysts as well as
price targets.

We recorded other-than-temporary impairment charges totaling $292,000 in 2007, attributable to
$117,000 on FirstMerit Corp. and $175,000 on FHLMC preferred stock.

During the quarter ended March 31, 2008, we recorded other-than-temporary impairment charges
totaling $3.6 million, as detailed in Exhibit I attached.

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/losses, and duration of unrealized loss, as applicable;

Response — The requested security detail is provided as Exhibits II and III. Exhibit
II contains the June 30, 2008 security holdings with the historical trading levels. Exhibit III
contains the security holdings and pricing as of March 31, 2008 and December 31, 2007. Because
our policy specifically addresses impairment levels of 10% and 20%, we have included those
thresholds as well. Please note that these schedules present our investments in financial
institutions stocks. Also included in the amounts disclosed in our financial statements is
$280,000 representing shares of Atlantic Central Bankers Bank which are redeemable at par.

    •

    How you considered the financial condition 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

Response — As presented above, our policy specifically addresses holdings that are
impaired by greater than 20% of our cost, with an additional level of review for holdings that
are impaired by greater than 10% of our cost if the time period exceeds 18 months. The severity
and duration of the unrealized loss influences the nature and extent of the analysis described
below.

As part of our process, we review information published by bank analysts on expectations for
bank stocks in general. For the specific holdings within the scope of review under our policy,
we perform an analysis of financial position and core earnings, including profitability and
asset quality measures and trends. We review information available from issuer filings and
conference calls as well as information published by covering analysts to assess future
prospects. In some cases, we hold discussions with the applicable bank analysts. We also
consider historical and current trading multiples.

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    •

    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.

Response — We have believed that a time horizon of up to two years would be a
reasonable period of time sufficient for a recovery of fair value, depending on the severity and
duration of the unrealized loss. Financial institution stocks began a declining trend in June
of 2007 that has continued through the current time. From June of 2007 through December of
2007, this sector declined approximately 20%, generally consistent with the decline we saw in
our portfolio. As of early January 2008, reports by financial institution analysts were mixed,
with some noting buying opportunities and others taking a “wait and see” approach. Some reports
compared the then current market to prior bank stock cycles. For example, a Citigroup Global
Markets report analyzed bank stock cycles from 1960 to 2008, indicating that the average decline
from peak was 37% with the subsequent 12-month return of 36%. With this view in mind, we
concluded that none of our holdings were other-than-temporarily impaired for the year ended
December 31, 2007, except for the aforementioned two items.

As of March 31, 2008, bank stock indices were down slightly compared to December 31, 2007.
Since we were not seeing signs of improvement, we concluded that certain of our holdings were
other-than-temporarily impaired and recorded a charge of $3.6 million. Those holdings
identified as other-than-temporarily impaired generally exhibited higher percentages of
depreciation from cost.

    2.

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

Response — We reviewed the disclosure requirements of paragraphs 19-22 of SFAS 115 and
based on the guidance in Regulation S-X 10-01 (a)(5), we concluded that the designated
disclosures were not required for our most recent interim filing on Form 10-Q as the details of
our investment securities have not changed significantly in amount or composition since the end
of the most recently completed year. In addition, we concluded that no material events related
to investment securities occurred subsequent to the most recent fiscal year that would have
resulted in our consolidated financial statements and notes not being presented fairly. There
have been no changes in our accounting principles and practices, or a change in accounting
estimates, in relation to our accounting for investment securities which would have warranted
any interim financial statement disclosures, in addition to those required by paragraphs 19-22
of SFAS 115.

During the quarter ended June 30, 2008, bank stock indices declined 24% with many analysts
becoming more negative. Because of the further declines, and in consultation with our
independent auditors, we concluded that an additional other-than-temporary impairment charge of
$24.7 million was appropriate, based upon the increasing severity and duration of the unrealized
losses and the financial condition and near-term prospects of the applicable issuers. Because
of this significance of this item, the above-referenced disclosures will be included in the Form
10-Q for the quarter ended June 30, 2008.

    3.

    We note your disclosure regarding your intent 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 investments from time to time based on when each customers’ liquidity need arises;

Response  — FFA has communicated to its clients that are holding ARCs in their
portfolios that FFA is willing to purchase those ARCs when the client has liquidity needs. The
offer is to purchase the ARCs at par, less an amount representing interest differential. The
interest differential is calculated as the difference between actual interest credited to the
ARC holdings and interest that would have been credited had the funds been invested in a 90-day
treasury bill. The purchase of ARCs has or would occur based upon notification from clients
that they have liquidity needs or otherwise desire to liquidate their holdings.

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    •

    Describe the methodology and tell us the specific assumptions used in determining the
$13 million liability related 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;

Response — We determined that our offer to purchase ARCs from clients constituted a
guarantee to be accounted for under FIN 45. We concluded that it was appropriate to value the
FIN 45 liability based on the estimated fair value of the ARCs underlying customer accounts. We
calculated this liability based on the difference between the estimated current fair value of
the ARCs held by customers and the estimated amount at which we would purchase the ARCs from
customer accounts.

A summary of this calculation follows —

    Total par value

    $
    332,715,000

    Estimated purchase discount

    (4,889,000
    )

    Estimated purchase price

    327,826,000

    Estimated fair value

    314,626,000

    Estimated loss accrual

    $
    13,200,000

The estimated purchase price was based on a spreadsheet model that calculated the difference
between the actual earnings on the ARCs compared to the earnings that would have been generated
at a T-bill rate. Note that the longer the period the ARCs are held, the greater the discount
will be.

To determine the estimated fair value, we hired a third-party valuation specialist to value a
representative sample of ARCs held by customers. Specifically, 41 different securities were
valued with a total par value of $160,885,000 (48% of the total). The estimated fair value of
these was $151,599,000, or 94.2% of par. In order to extrapolate these values to the entire
portfolio, we employed the following methodology — (1) For securities totaling $145,945,000,
where other securities of the issuers were valued, we based the value on the results of the
third party valuation. We noted that the values were very similar for securities of the same
issuer. (2) For securities of issuers where none of their issues were valued totaling
$16,475,000, we used the 94.2% average rate. (3) Non-student loan ARCs totaling $9,410,000 were
valued by our Investment Department based on similar securities in the market.

Exhibit IV attached represents the final valuation report.

    •

    Tell us the “other available information” 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.

Response — In addition to the valuation report, we considered publicly available
information concerning fair value estimates for auction rate securities secured by student loans
contained in current and quarterly reports filed by other filers with the Commission, as well as
anecdotal information from third party investment professionals. The estimated fair value of
the ARCs, and thus the amount of the estimated liability, was determined as described in the
preceding response. Our consideration of the “other available information” did not result in an
adjustment to the fair value determined in the valuation report. Rather, our consideration of
the “other available information” and the range of estimated valuations available from that
information were viewed as validating the valuation conclusions.

    •

    How you determined that the fair value of the ARCs held by FFA customers would be
approximately 95% of their par value;

Response — Please refer to the table and supporting explanation above as to how this
determination was made.

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    •

    Tell us how you considered the credit quality of the ARC issuer(s) in determining
whether to buyback these ARCs; and

Response — The credit quality of the ARCs was not a factor in the decision to purchase
ARCs from customer accounts. Management and the Board of Directors determined that it was in
the best interest of the Company to provide liquidity to customers. The majority of the ARCs
are student loan backed auction rate securities which are su