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Dean K. Hirata Chief Financial Officer Central Pacific Financial Corp. 220 South King Street Honolulu, Hawaii 96813
Re: Central Pacific Financial Corp.
Form 10-K for Fiscal Year Ended December 31, 2007 Form 10-Q for the period Ended March 31, 2008
 File No. 001-31567
 Dear Mr. Hirata:
 We have reviewed your filings and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to  other portions of your docum ents.  Where indicated, we
think you should revise your documents in response to these comments in future filings.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In your response, please indicate your  intent to include the requested revision in future
filings and provide a draft of your proposed di sclosures.  In some of our comments, we
may ask you to provide us with information so we may better understand your disclosure.
After reviewing this information, we may 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 filings.  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.

Dean K. Hirata
Central Pacific Financial Corp.
August 7, 2008 Page 2  Form 10-K for the Year Ended December 31, 2007

 Our Services, page 4

 1. We note the references in this section to  the maintenance of appropriate reserves
that are required for certain loan products.  Please address the following regarding
this disclosure:

• Please tell us the specific nature of these reserves.  Tell us if you require
interest reserves on any of your loan products.

• If you do require interest reserves, pleas e tell us the amount of such loans and
accompanying reserves as of June 30, 2008 and the three previous quarter ends.

• Tell us how you monitor such projects th roughout their lives to make sure the
properties are moving along as planned such  that it is appropriate to continue
to capitalize the interest to the loan.

• Tell us whether you have ever extended, renewed or restructured terms of the
related loans, and the reasons for the changes.
 Nonperforming Assets, Accruing Loans Delinqu ent for 90 Days or More, Restructured
Loans Still Accruing Interest, page 39
 2. We note your disclosure that non-accrui ng loans increased approximately 57% in
2008 just prior to the filing of this Form  10-K.  Please tell us the basis for your
assertion that your loss exposure to non accrual loans was adequately provided for
at December 31, 2007 considering the appare nt significant increase in nonaccrual
loans.

Financial Statements, beginning on page 48

Principles of Consolidation, page 56

3. Please tell us in detail and more clearl y disclose in your future filings how you
determined that it is appropriate not to consolidate the 50% owned mortgage
brokerage companies.  Also, please tell us the specific na ture of the contributions
to unconsolidated subsidiaries reflected in  the statements of cash flows, including
a discussion of any contract ual requirement to provide  contributions to these
subsidiaries.

Dean K. Hirata
Central Pacific Financial Corp.
August 7, 2008 Page 3  4. Please tell us and revise future filings as appropriate to disclose your total investment in unconsolidated subsidiaries  accounted for under the equity and cost
methods and your policy for determin ing impairment of these assets.
 Reclassifications and Corrections, page 56

 5. We note $2 million tax benefit recognized in 2007 as a result of your detailed
analysis of your tax positions.  Please tell  us how this analysis coincided with
your implementation of FIN 48 such that current period recognition was appropriate.  Also, please e xplain to us why you think th is amount was immaterial
considering its apparent signi ficance to reported net income.
 Goodwill and Other Intangible Assets, page 59

 6. Considering the goodwill impairment r ecognized in 2007 and your disclosed
policy for evaluating other intangible assets  for impairment, please tell us how
your impairment analysis of goodwill consid ered the carrying value of the other
intangible assets in determining the goodwill impairment.  Also, tell us whether you separately considered the other intangi ble assets for impairment based on the
same changes in market circumstances th at triggered your analysis of goodwill.

Form 10-Q for the Period Ended March 31, 2008

7. Please refer to the transfer of loans held for investment to loans held for sale and
tell us where you included the cash flows rela ted to the sale of these loans in the
statements of cash flows, clarifying how you considered the requirements of paragraph 9 of SFAS 102.
 8. We note the significant decrease of the a llowance for loan and lease losses as a
percentage of your total loan portfolio a nd that you attribute it to approximately
$54 million in charge-offs in the first quart er of 2008.  In order to bridge the gap
in your disclosure, please revise Manage ment’s Discussion and Analysis in your
future interim and annual to address the following:

• Please disclose in detail how your al lowance at March 31, 2008 specifically
considered the approximately 95% percentage increase non-performing loans from December 31, 2007.

• Please quantify the decline in collateral  values to which you ascribe the $34.4
million provision.  Please disclose how you determine collateral values for this purpose and discuss the extent  to which you obtain updates to your
appraisals.

Dean K. Hirata
Central Pacific Financial Corp.
August 7, 2008 Page 4
• Please disclose your accounting policy fo r transferring loans from held for
investment to loans held for sale, in cluding how you record the loans when the
transferred and how you recognize subsequent impairments.  To the extent you have recognized material impairments subsequent to tran sferring loans to
held for sale, please quantify them for us.

• Please provide us with your proposed disclosures.
 9. Please tell us and in future filings revise to disclose more clearly the facts and circumstances resulting in the disproportionate recogniti on of federal and state tax
credits and the generation of tax-exempt  income compared to taxable income.

* * * * *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Your re sponse letter should key your responses to our
comments, indicate your intent to include th e requested revisions in future filings,
provide a draft of your proposed disclosure s and provide any requested information.
Please file your letter on EDGAR as corre spondence.  Please understand that we may
have additional comments after review ing your responses to our 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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed decision.  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.     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.

Dean K. Hirata
Central Pacific Financial Corp. August 7, 2008 Page 5
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 comments on your filing.

You may contact Paul Cline at (202 ) 551-3851 or me at (202) 551-3494 if you
have questions.

Sincerely,
   Kevin W. Vaughn Branch Chief