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CORRESP
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Correspondence

 (717) 291-2473

July 26, 2010

 Mr. Michael R.
Clampitt

 Senior Attorney Advisor

Securities and Exchange Commission

 450 Fifth
Street, N.W.

 Washington, D.C. 20549

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. Clampitt:

 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 28, 2010 relating to the above-referenced
filings. In this letter, we have recited the comments from the staff in bold type and have followed each comment with the Company’s response.

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:

a)
The amount and /or percentage of loans that were considered collateral dependent;

Response – More than 99 percent of the $769.9 million of impaired loans at December 31, 2009 were considered to be
collateral dependent. Collateral could be in the form of real property in the case of residential mortgages, commercial mortgages and construction loans, or business assets, such as accounts receivable or inventory, in the case of commercial and
industrial loans. In many cases, commercial and industrial loans may also be secured by real property.

b)
The amount of loans measured using each of the methodologies described on pages 38 and 56 (i.e., present value of expected future 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);

 Response – Substantially all of the $769.9 million of impaired loans at
December 31, 2009 were measured based on the estimated fair value of the collateral.

c)
As it relates to collateral dependent loans, a comprehensive 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 validate the results of these valuation methodologies in the event they are not
based on current appraisal data;

 Response – Valuation methodologies are based upon
account-specific information for all impaired loans. We do not use automated or portfolio-aggregate methods for any of our impaired loans.

For loans secured by real estate, estimated fair value is determined primarily through certified third-party appraisals. A current
certified appraisal is required in the normal course of business when any significant change in the terms of the loan occurs, such as an extension, renewal, or change to underlying repayment terms. Updated appraisals may also be obtained for
nonperforming loans after consideration of various factors, including: the age of the most recent appraisal; the condition of the property; our experience and knowledge of the market; the purpose of the loan; environmental factors; payment status;
the strength of any guarantors; and the existence and age of other indications of value such as broker price opinions, among others.

Collateral values based on certified appraisals are discounted to arrive at the estimated selling price of the collateral, which is
considered to be the estimated fair value. The discounts also include estimated costs to sell the property.

 Where updated
certified appraisals are not obtained for nonperforming loans secured by real estate, fair values are estimated based on one or more of the following:

•

 Original appraisal – if the original appraisal indicated a significant loan to value position and, in the opinion of our internal loan evaluation
staff, there has not been a significant deterioration in the collateral value, the original appraisal may be used to support the value of the collateral. Appropriate discounts are applied to the appraised value to adjust for market changes since the
date the appraisal was completed, to arrive at estimated selling price for the collateral. Original appraisals are typically used only when the estimated collateral value, as adjusted, results in a current loan to value ratio that is lower than the
Company’s policy for new loans, generally 80%.

•

 Broker price opinions – in lieu of obtaining an updated certified appraisal, a less formal indication of value, such as a broker price opinion,
may be obtained. These opinions are generally used to validate internal estimates of collateral value and are not solely relied upon.

•

 Discounted cash flows – while substantially all of our impaired loans are measured based on the estimated fair value of collateral, discounted
cash flows analyses may be used to validate estimates of collateral value derived from other approaches.

 For
loans secured by non-real estate collateral, such as accounts receivable or inventory, estimated fair values are determined based on borrower financial statements, inventory listings, accounts receivable listings or agings, or borrowing base
certificates. Indications of value from these sources are generally discounted based on the age of the financial information or the quality

of the assets. Liquidation or collection discounts are applied to these assets based upon existing loan evaluation policies.

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

 Response –
Approximately 40% of impaired loans secured by real estate were measured using certified third party appraisals that had been updated within 12 months prior to December 31, 2009. Estimated fair values for the remaining 60% of impaired loans
were determined through the methods documented in response to comment 1.c.

e)
The typical timing surrounding the recognition of a collateral dependent loan as nonperforming, when you order and receive an appraisal, and the subsequent
recognition of any provision or related charge-off. In this regard, tell us if there have been any significant time lapses during this process;

Response – In general, a collateral dependent loan is placed on nonaccrual status once it becomes 90 days delinquent as to
principal or interest. In certain cases where a loan is not yet 90 days delinquent, but there is an indication that the borrower is having difficulty making payments, a loan may also be placed on nonaccrual status.

If the source of repayment for a nonperforming collateral dependent loan is determined to be the collateral itself, a decision is made
regarding whether an updated certified appraisal of the collateral is necessary. For loans secured by real property, this decision is based on various considerations, including: the age of the most recent appraisal; the condition of the property;
our experience and knowledge of the market; the purpose of the loan; environmental factors; payment status; the strength of any guarantors; and the existence and age of other indications of value such as broker price opinions, among others.

 If an updated appraisal is considered to be necessary, no charge-off is recorded until such appraisal has been completed and
reviewed. In the interim, a specific valuation allowance will be allocated to the loan, if necessary, based on the best information currently available for estimating the fair value of the collateral.

Upon review of the updated appraisal, the specific valuation allowance is revised, if necessary, and a determination is made about whether
a loss situation exists, which would warrant a charge-off of a portion or all of the loan balance.

 Once a loan is placed on
nonperforming status, the decision to obtain an updated appraisal is generally made in less than a month. The updated appraisal may take up to two months to complete and the final conclusion regarding estimated fair value and whether a charge-off is
necessary will be made less than a month after receiving the updated appraisal. In general, the total elapsed time is less than three months and there were no significant time lapses in this process during 2009.

f)
In more detail, the procedures you perform to monitor these loans between the receipt of an original appraisal and the updated appraisal;

 Response – Loans, including impaired loans, are monitored through various procedures, including
the following:

•

 Monthly loan review meetings to review and manage actions surrounding any account that exhibited potential signs of stress, which is generally
indicated by delinquency, a change in risk rating (see below) or other characteristics. The agendas for these meetings include updates on the status of these accounts, review of activities since the most recent meeting and development of action
plans for remediation of the accounts. These meetings are attended by lending staff, lending management, loan review management and corporate senior management.

•

 Monthly meetings with lenders to ensure proactive management of any stressed account, including dedication of additional personnel to managing the
loan, if necessary.

•

 Involvement either through consultation or direct management of loan workout personnel in stressed accounts to lead or assist in the negotiation,
remediation and/or exit of the account.

•

 Ongoing involvement of loan review staff in examining stressed portfolios and specific accounts to ensure that the above processes are effective in
identification and management of portfolios.

 The Company uses a risk rating system, which assigns a rating
to each loan on a scale of 1-9, with 1 representing an “excellent” credit, for borrowers of unquestionable financial strength, and 9 for credits where a “loss” is expected. The criteria for each risk rating category are specified
in the Company’s Risk Rating policy and include defined financial and business risks.

 Risk ratings are initially assigned
to loans by the loan officers and are reviewed on a regular basis by loan review staff in the normal course of their loan review procedures. Ratings can change as a result of the monitoring procedures documented above or as a result of specific loan
review activities. Risk rating allows management to identify riskier credits in a timely manner and to allocate resources to managing troubled accounts.

g)
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 amount of the difference and corresponding reasons for the difference, as applicable;

Response – The amount charged-off is generally higher than the amount calculated using the fair value of the collateral as
presented in the appraisal. The fair value of the collateral as presented in the appraisal will be the starting point for determining the amount, however, the appraised value will be discounted to arrive at the estimated selling price of the
collateral and to consider selling costs.

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

 Response – Updated certified appraisals prepared by independent third parties are reviewed to
ensure that the indicated fair value has been properly determined and is reasonable. If the estimated fair value based on the updated appraisal is lower than the estimated fair value used to determine the original charge-off amount, an additional
charge-off will be recorded.

 If the estimated fair value based on the updated appraisal is higher, no adjustment to the
amount charged-off is made. Recoveries of amounts previously charged-off are not recognized until realized.

 A partially
charged-off loan is generally not returned to performing status based on an improvement in collateral value. In rare circumstances where a partial charge-off is recorded and the remaining loan balance is part of a restructuring, the restructured
loan may be returned to performing status if the principal and interest payments, under the modified terms, are current for six consecutive months after modification.

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

Response – As noted in the response to comment 1.b. above, substantially all impaired loans were measured based on the
estimated fair value of the collateral as of December 31, 2009. All loans secured by real estate have a certified appraisal that was completed in connection with the original underwriting.

For those loans where an updated appraisal has not been obtained, the estimated fair value of the collateral may be determined through one
or more of the methods documented in the response to comment 1.c.

j)
For those loans where you determined that no specific valuation allowance was necessary, the substantive reasons to support this conclusion.

 Response – We consider all loans rated “substandard” or worse under the Company’s
Risk Rating policy to be impaired, based on the guidance provided in FASB ASC Section 310-10-35. Loans rated “substandard,” exhibit one or more of the following characteristics:

•

 inadequately protected by current net worth and paying capacity of the borrower.

•

 well-defined weakness or weaknesses that jeopardize the normal repayment of the debt.

•

 collection of principal may be collateral-intensive.

•

 a high probability of payment default.

•

 current or expected unprofitable operations, inadequate debt service coverage, inadequate liquidity, or marginal capitalization.

 Loans rated as substandard may have sufficient collateral value and, therefore, may not have a specific
valuation allowance.

 Approximately 40% of impaired loans with no specific valuation allowance at December 31, 2009 had
certified third-party appraisals of the underlying collateral that were completed within the previous 12 months. The estimated fair values of the collateral for these loans, as indicated by the appraisals as discounted to arrive at estimated selling
prices, exceeded the carrying amount of the loans and, accordingly, no specific valuation allowance was considered to be necessary.

The remaining 60% of these loans had no specific valuation allowance due to one or more of the following factors:

•

 Strong loan to value ratios based on original appraisal: See discussion of the use of original appraisals in the response to comment 1.c.

•

 Broker price opinions indicated an estimated fair value of the collateral in excess of the loan amount: See discussion of the use of broker price
opinions in the response to comment 1.c.

•

 Existence of a strong guarantor: While substantially all of our impaired loans are measur