SecProbe.io

June 19, 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
Response filed May 22, 2014
  File No.  001-31567

Dear Mr. Isono :

We have reviewed your response to our May 8, 2014 letter 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 ten business days by amending your filing, by
providing the requested i nformation, or by advising us when you will provide the requested
response.   If you 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

Critical Accounting Policies and Use of Estimates

Allowance for Loan and Lease Losses, page 34

1. Please refer  to the response to comment 1 of our May 8, 2014 letter.  The comment was
intended to elicit more transparency surrounding how you segment your loan portfolio
and the categories therein for purposes of measuring impairment, particularly as that
segmentatio n applies to the general allowance component of the allowance for loan and
lease losses.  The response appears to be consistent with what you have disclosed and;
considering the significance of these estimates to your financial condition, results of

Denis K. Isono
Central Pacific Financial Corp.
June 19,  2014
Page 2

 operat ions, it appears overly abbreviated.  Please tell us and revise future filings to
address the following:

 Please provide a more detailed discussion of how you segment the categories of the
portfolio for purposes of determining the general allowance compone nt of the allowance
for loan losses.  Your revisions should qualitatively and quantitatively clarify how you
segmented the loan categories into homogeneous groups and how you identify and
measure underlying losses of each segment.

 Please provide the loss experience used to measure the losses in each of the segments of
your loan portfolio for each period presented and discuss changes between periods.
Discuss, to the extent applicable, how the loss experience is weighted.

 Please provide quantification of  the environmental or qualitative loss factors recorded in
each segment of each loan category from the methodology used to develop the general
component of the allowance for loan losses.

 Please discuss the specific nature of the loss factors considered in  developing the
“unallocated ” component of the reserve and quantify the amount allocated to each of the
factors.  Discuss why the environmental or qualitative factors used to determine the
general component of the allowance for loan and leases do not capture these loss facto rs.

Provision and Allowance for Loan and Lease Losses, page 50

2. Please refer to the response to comment 10 of our May 8, 2014 letter.  Tell us and revise
future filing to address the following:

 Please explain why you believe a rolling four or eight quarter period is an appropriate
time period to use in determining the related losses.  Provide a discussion that enables a
reader to understand why shorter loss experience periods do not appear to have captured
the improvement in your credit quality  factors over the periods presented such that you
have continually reversed portions of the allowance into income over the last three fiscal
years rather than recognizing a provision for loan losses.

 Please provide a discussion of the external proxies tha t were used prior to the first quarter
of 2014, including the source from which you obtained them, how you determined that
they were reasonable and applicable to your portfolio and the segments of the loan
categories to which they were applied.

 Please pro vide a discussion of why actual historical loss factors were not used prior to the
first quarter of 2014.

Denis K. Isono
Central Pacific Financial Corp.
June 19,  2014
Page 3

 3. Please refer to the response to comment 11 of our May 8, 2014 letter.  The response
appears to repeat information that is disclosed in your F orm 10 -K and related documents.
The purpose of the comment was to obtain disclosures that explains to a reader why the
improvements noted in your disclosures and the response do not appear to have been
captured in the methodology you use to determine the appropriateness of the allowance
for loan and lease losses such that you continually reverse portions of the allowance into
income.  These reversals contributed approximately 19%, 40% and 111% to pre -tax
income in 2013, 2012 and 2011, respectively.  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 credit
quality in your loan portfolio, resulting in  a net credit to the loan loss provision in each
period presented for the last three fiscal years and an increase in the allowance for loan
and lease losses as a percentage of non -accrual loans and nonperforming assets.  Please
also 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
loan losses were appropriate for these periods.

4. See our comments above on providing the loss factors used in e ach loan segment in each
loan category for each period presented and provide us a schedule that compares each of
those factors to the actual losses in each of the segments.

5. You stated in your response to our comments that a rolling four or eight quarter period is
an appropriate time period to use in determining the related losses.  Since y our average
charge -offs for real estate mortgage residential have  been $1.37 million over the last two
years please tell us why an A LLL of $28.4 million or almost 21 times the average charge -
offs over the last two years is appropriate for your residential real estate loans at
December 31, 2013.  In your response, please also address why an ALLL of almost 21
times the average charge -offs is appropriate for your residential real estate loans in light
of your disclosure on page 32 that market conditions improved in Hawaii in 2013.

Financial Statements and Supplementary Data, page 66

6. Please refer to the response to comment 13  of our May 8, 2014 letter.  Please tell us and
revise future filings to address the following:

 Please discuss why third -party market data was determined to be more indicative of the
appropriate loss factors to use in many segments of the loan portfolio, identifying those
segments, than your actual loss experience, particularly given that using the data resulted
in a credit to the provision for loan and lease losses in the fourth quarter of 2013.

 Please explain in greater detail why using a look back pe riod of six years is appropriate
given that you state elsewhere in the response letter that current date is more relevant in
predicting probable loss.

Denis K. Isono
Central Pacific Financial Corp.
June 19,  2014
Page 4

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
        Account ing Branch Chief