SecProbe.io

May 8, 2014

Via E -mail
Denis K. Isono
Executive Vice President and Chief Financial Officer
Central Pacific Financial Corp.
220 South King Street
Honolulu, HI 96813

Re: Central Pacific  Financial Corp.
Form 10-K for Fiscal Period Ended  December 31, 2013
Filed February 28, 2014
  File No.  001-31567

Dear Mr. Isono :

We have reviewed your filing an d 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 ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If yo u do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2013

Critical Accounting Policies and Use of Estimates

Allowance for Loan and Lease Losses, page 34

1. Please tell us and revise future filings to provide a detailed discussion of which loans you
evaluate for impairment on an individual basis under ASC 310 -10 and which loans you
evaluate for impairment on a pool  or homogeneous basis under ASC 450-20.  Please be
specific, addressing each major loan category. In clude applicable quantitative thresholds,
methodologies used (e.g., discounted cash flows, collateral values) and other criteria that
you apply as well as a discussion of the surrounding uncertainties of each methodology.

Denis K. Isono
Central Pacific Financial Corp.
May 8, 2014
Page 2

 Goodwill and other Intangibles Assets, page 36

2. Please tell us and revise future filings to disclose how you validate the values assigned to
loan servicing assets determined by a third party and clarify the sources of the market
value assumptions used to value them at each reporting per iod (i.e., third party or
internally obtained).

Net Interest Margin, page 41

3. Please tell us and revise future filings to discuss the factors contributing to the slowing of
premium amortization on your mortgage backed securities, including quantificatio n of it
on your net interest margin in the periods presented.

Loan Portfolio, page 45

4. Please tell us and revise in future filings to provide expanded discussions of your loan
underwriting policies and procedures.  For instance, discuss criteria in additi on to loan to
value ratios applied to your loans, such as FICO scores, etc.

5. Please tell us and revise future filings to discuss the nature of your loan products by loan
category, to include fixed rate loans and variable rate loans.  For variable rate loans,
disclose whether borrowers are qualified at the fully indexed interest rate and, if not, how
you evaluate the risks associated with these loans in the underwriting process.

6. Please tell us and revise future filings to clarify whether or not your loa n portfolio
includes any non -conforming loans such as hybrid loans, interest only loans, etc. and, if
applicable, how they are underwritten.

7. Given the different credit characteristics of home equity lines of credit (HELOC) and
home equity loans from first  lien mortgages, please tell us and revise future filings to
provide a separate discussion of the underwriting policies and procedures for them,
including whether they are amortizing or balloon, the percentage of them for which you
own the first lien and h ow you monitor credit risk on those for which the first lien is
owned by others.

8. Please tell us and revise future filings to provide disaggregated disclose of your
HELCO’s and home equity loans from your residential real estate loans in the table
presente d on page 45 and elsewhere, as applicable.  The current disclosure that these
loans are approximately 14% of your residential real estate does not appear to enable
reader to understand the changes in this loan segment between periods.

Denis K. Isono
Central Pacific Financial Corp.
May 8, 2014
Page 3

 Maturities and Sen sitivities of Loans to Changes in Interest Rates, page 49

9. Please tell us and revise the tabular presentation in this section in future filings to
incorporate your entire loan portfolio.

Provision and Allowance for Loan and Lease Losses, page 50

10. You d isclose on page 52 that you made certain enhancements to your methodologies in
2010 and that you did not make any material enhancements in 2011 through 2013.  Please
tell us  and revise future filings to provide a detailed discussion of how you develop the
historical loss experience used to determine the allowance for loan losses.  In your
response, please fully explain how the 2010 enhancements and the lack of subsequent
enhancements contributed to your determination that your allowance for loan losses were
appropriate f or the periods presented.

11. Please  tell us and  revise future filings to provide a more detailed discussion of the
changes in your credit quality between periods since your methodology does not appear
to capture the apparent improvement in c redit quality in your loan portfolio, resulting in a
net credit to the loan loss provision in each period presented fo r the last three fiscal years
and an increase in the allowance for loan and lease losses as a percentage of non -accrual
loans and nonperfo rming assets including loans held for sale which ranged from 79% at
December 31, 2010 to 201.55% at December 31, 2013.  Please also tell us and revise
future filings to discuss the basis for including loan s held for sale in your presentations of
the allowance for loan losses. Finally, p lease tell us why you believe your allowance for
loan losses was directionally consistent considering noted asset quality improvements and
why you believe your allowance for l oan losses were appropri ate for these periods.

12. Noting your reference to the segmentation guidance in ASC 310 -10, please tell us and
revise future filings to provide qualitative and quantitative disclosures of how you apply
that guidance.

Financial Stat ements and Supplementary Data, beginning on page 66

13. You disclose a material weakness in your internal controls over financial reporting in the
report issued by your independent accountant and the related disclosures in
management’s report on internal cont rol over financial control.   Please tell us and revise
future filings to disclose specifically when and how the material weakness was identified
and to more specifically describe its effect on the determination of the allowance for loan
and lease losses, both qualitatively and quantitatively.   Discuss whether the related input
data was tested for effectiveness in periods prior to the identification of the material
weakness; and, if so, what changed in the period the material weakness was identified.
Your  discussion should clarify how you determined earlier periods were not affected by
the material internal control weakness.

Denis K. Isono
Central Pacific Financial Corp.
May 8, 2014
Page 4

Note 5.  Loans and Leases, page 83

14. Please tell us and revise future filings to include the discussion of risk characteristics
relevant to each portfolio segment required by ASC 310 -10-50-11(B).

Note 26. Parent Company and Regulatory Restrictions
Condensed Statements of Cash Flows, page 121

15. You commenced paying cash dividends to common shareholders this past year.
However, the sources of cash flows used to pay these dividends is not clear since the line
item Other, net accounts for a significant percentage of your net cash provided by (used
in) operating activities over the last three years.  Please tell us and consider disclosi ng,
the nature and amount of the transactions included in the Other, net line item.

Please also tell us and revise the liquidity disclosures of the holding company in the
liquidity section of Management’s Discussion and Analysis to describe the signific ant
drivers of operating, investing and financing cash flows and the reasons for the material
variations in these cash flows over the last three years.

Definitive Proxy Statement on Schedule 14A

Summary Compensation, page 46

16. We note that the total comp ensation earned by each of the named executive officers in
2013 was significantly less than the compensation earned in 2012. The Compensation
Discussion and Analysis does not appear to address this material difference. Please
advise.

             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 Exchange Act rules require.   Since the company and i ts 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 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

Denis K. Isono
Central Pacific Financial Corp.
May 8, 2014
Page 5

  the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Paul Cline  at (202)551 -3851  or me at (202)551 -3752  if you have
questions regarding comments on the financial statements and related matters.  Please contact
Erin Purnell  at (202)551 -3454  or Mark Webb at (202)551 -3698  with any other questions.

Sincerely,

 /s/ Gus Rodriguez

 Gus Rodriguez
        Accounting Branch Chief