SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

                June 15, 2010
By U.S. Mail and facsimile to (772) 288-6012

William R. Hahl Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue Stuart, FL  34994
Re:  Seacoast Banking Corporation of Florida
 Form 10-K for the Fiscal Year Ended December 31, 2009  Form 10-Q for the Fiscal  Quarter Ended March 31, 2010
 File No. 000-13660
 Dear Mr. Hahl:
We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings,
or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circumst ances or do not believe future revisions are
appropriate, please tell us why in your response.
 After reviewing the information you provi de in response to these comments,
including the draft of your pr oposed disclosures, we may ha ve additional comments.

* *  *  *  *

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida June 15, 2010 Page 2 of 5  Form 10-K for the Fiscal Year Ended December 31, 2009

 Management’s Discussion and Analysis

 Nonperforming Assets, page 9

 1. Please revise your future filings to quantif y the types of concessions made (e.g. rate
reductions, payment extensions, forgivene ss of principal, forbearance or other
actions) concerning troubled de bt restructurings and discus sion of your success with
the different types of concessions.  Show us what your disclosure will look like in
your response.

2. We note your disclosure on page 55 that you modify certain loans that are not
considered TDRs.  Please desc ribe the types of modifica tions performed and explain
your rationale for not classifying them as TD Rs.  In this regard, specifically tell us
whether you have performed any loan modifi cations that you consider to be short
term in nature (and provide your definition of short term) and therefore concluded
that TDR classificati on was not required.

3. Please tell us and revise your future filings to disclose whether you have performed
any CRE workouts whereby an existing loan was restructured into multiple new loans
(i.e., A Note/B Note structure).  To the ex tent that you have performed these types of
CRE workouts, please provide us with and re vise your future filings to disclose the
following:

• Quantify the amount of loans that have been restructured using this type of
workout strategy in each period presented;
• Discuss the benefits of this workout strategy, including the impact on interest
income and credit classification;
• Discuss the general term s of the new loans and how the A note and B note
differ, particularly  whether the A no te is underwritten in accordance with
your customary underwriting standards and at current market rates;
• Clarify whether the B note is immediat ely charged-off upon restructuring.  If
not, clarify whether you combine the rest ructured notes in your evaluation of
whether the notes should be returned to accrual status;
• Confirm that the A note is classified as a TDR and explain your policy for
removing such loans from TDR classification; and
• Clarify your policy for returning the A note to accrual status, including how
you consider the borrower’s payment perfor mance prior to the restructuring.

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida June 15, 2010 Page 3 of 5  4. Please tell us and consider revising your future filings to disclose, whether you have
noticed an increase in any loan categories such as co mmercial real estate or
construction loans that have been exte nded at maturity for which you have not
considered the loans to be impaired due to the existence of guaran tees.  If so, provide
us with the following information and consid er enhancing your disclosure in future
filings accordingly:

• The types of extensions being made, wh ether loan terms are being adjusted
from the original terms, and whether you consider these types of loans as
collateral-dependent;
• To the extent you extend commercial loans at or near maturity at the existing
loan rate due to the exis tence of a guarantee, tell us  how you consider whether
it is a troubled debt restructuring;
• In detail, how you evaluate the financ ial wherewithal of the guarantor,
addressing the type of financial in formation reviewed, how current and
objective the information reviewed is, a nd how often the review is performed;
• How many times you have sought performa nce under the guarantee discussing
the extent of the successes.  As part  of your response, discuss the decision
making process you go through in deciding whether to pursue the guarantor and whether there are circumstances you would not seek to enforce the
guarantee; and
• Quantify the dollar amount of commercial loans in which your carrying value is in excess of the appraised value bu t not considered impaired due to the
existence of guarantees.
 Notes to Consolidated Financial Statements

 Note R - Fair Value, page 81

 5. Please address and disclose the following as  it relates to your appraisal policies:

• When the Company does not have a new appraisal on file, describe in more
detail the procedures performed by your Credit Officers and Special Assets Officers in determining whether the assu mptions reflected in these original
appraisals are reflective of current ma rket conditions, particularly for those
appraisals that are more than a year old;
• Describe the procedures performed at each  balance sheet date to determine the
fair value of collateral-dependent impa ired loans and OREO.  Tell us how you
define collateral dependent loans.  In determining the fair value address
whether you make adjustments to original appraisals to take into consideration
current market conditions.  If so, desc ribe the types of adjustments made.
Alternatively, if you perform an internal  valuation to  estimate fair value,
please describe the valuation approaches used, the significant assumptions

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida June 15, 2010 Page 4 of 5
used in each model, and if multiple va luation approaches are used, the relative
weighting of each model. Clarify whether you make any adjustments to current appraisals and if so, describe the types of adjustments made and the
reasons for such adjustments.
• When you receive new appraisals, describe  the type of appraisals received,
such as “retail valu e” or “as is value”;
• Address how partially charged-off loans measured for impairment based on
the collateral value are classified and accounted for subsequent to receiving an
updated appraisal.  For example, disclo se whether the loan s are returned to
performing status or whether they remain as nonperforming;
• Address the typical timing surrounding th e recognition of a loan as nonaccrual
and recording of any provision or charge-off;
• Address the procedures performed betw een receipt of updated appraisals to
ensure impairment of loans measured for impairment based on collateral value
are measured appropriately; and
• Address how you determine the amount to charge-off.
 Show us what your disclosure wi ll look like in yo ur response.

* *  *  *  *
  We urge all persons who are responsible for the accuracy and adequacy  of the disclosure
in the filing to be certain that the filing in cludes the information the Securities Exchange
Act of 1934 and all applicable Exchange Act rules require.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
             In responding to our commen ts, 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
• 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.

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida
June 15, 2010 Page 5 of 5   You may contact David Irving, Staff A ccountant, at (202) 551-3321, or me at
(202) 551-3872 if you have any questions regarding our comments.
Sincerely,

        Hugh West         B r a n c h  C h i e f