SecProbe.io

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Correspondence

July 23, 2009

Ms. Kathryn McHale and Mr. Justin Dobbie

Division of Corporate Finance

U.S. Securities and Exchange Commission

Mail Stop 4720

100 F Street, N.E.

Washington, DC 20549

    Re:

     Seacoast Banking Corporation of Florida

Form 10-K for Fiscal Year Ended December 31, 2008

Form 10-K/A for Fiscal Year Ended December 31, 2008

Form 10-Q/A for Fiscal Quarter Ended March 31, 2009

Form 8-K filed on March 11, 2009

Form 8-K filed on April 29, 2009

Form 8-K filed on May 22, 2009

File Number: 000-13660

Dear Ms. McHale and Mr. Dobbie:

We have reviewed your comments dated July 17, 2009 on the above filings and provide our responses to your comments
below.

Form 10-K for the Fiscal Year Ended December 31, 2008

Exhibit 13

Management’s Discussion and Analysis

Allowance and Provision for Loan Losses, page 13

    1.

    Please revise the presentation of loan categories in Tables 12 and 13 (pages 48 and 49) in future filings to be
consistent with the loan categories in Table 9 (page 47).

RESPONSE: We recently expanded the detail about our loan portfolio that is included in table 9 and other tables
to allow investors to make their own assessment about the risk associated with the loan portfolio. We will revise the
loan categories in Table 9, 12 and 13 to be consistent in compliance with Industry Guides in our future filings.

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Ms. McHale and Mr. Dobbie

July 23, 2009

Page 2

Fair Value of Securities, pages 17-18

    2.

    We note your use of pricing models (independent and third party) to value financial instruments. Please tell us
and revise your future filings to disclose the following:

    •

    the number of prices you generally obtain per instrument, and if you obtained multiple prices, how you
determine the ultimate fair value used in your financial statements;

RESPONSE: Generally we obtain one price for each security. Prices obtained from pricing services are usually not
adjusted; however, for two securities (both super-senior AAA private label securities) we noted that the pricing
provided by the pricing services was not consistent with other observed prices in the market during the fourth quarter
of 2008 for similar securities. Using observable market inputs, which included interest rate and yield curves,
volatilities, prepay speeds, loss severities and default rates at year end, we validated the observed prices using a
discounted cash flow model and used the observed prices for similar securities to determine the fair value of these two
securities.

    •

    whether, and if so, why, you adjust prices obtained from the pricing service; and

RESPONSE: Please see response above.

    •

    if true, please include an affirmative statement that based on your internal review procedures, the
fair values provided by the pricing services are consistent with the principles of SFAS 157.

RESPONSE: We confirm our belief that, based on our internal review procedures, the fair values provided by the
pricing services allowed us to conclude that the fair values provided by the pricing services are consistent with the
principles of SFAS 157. We will include such a statement in our future filings.

Goodwill Impairment, page 19

    3.

    In the interest of providing readers with a better insight into management judgments in accounting for goodwill,
please tell us and disclose the following in future filings:

    •

    the reporting unit at which you test goodwill for impairment and your basis for that determination;

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Ms. McHale and Mr. Dobbie

July 23, 2009

Page 3

RESPONSE: As disclosed in Note A to our audited consolidated financial statements, we are a single segment bank
holding company with one operating subsidiary bank. With the assistance of an independent third party, our management
reviews the results and assumptions utilized in the third party’s analysis which use discounted cash flows and change
in control valuation methods. Determining the fair value using discounted cash flow analysis requires assumptions
regarding short- and long-term net cash flow growth rates, as well as discount rates. As part of the analysis, the
independent third party considers the makeup of assets and liabilities (including both loan and deposit compositions),
scarcity value, capital ratios, market share, credit quality (asset quality), control premiums, the type of financial
institution, the overall size, the various markets we serve as well as profitability ratios.

Growth Assumptions

Multi-year financial forecasts were developed considering key business drivers such as new business initiatives,
market share, anticipated loan and deposit growth, interest rates, historical performance, and industry and economic
trends, among other considerations. Average assets were grown 0.0% in 2009, 5.0% in 2010 and 8.0% thereafter.
Earnings per share of $0.00 in 2009 and $0.71 for 2010 were used with ROAA of 0.75% in 2011 and 1.00% thereafter.

Discount Rate Assumptions

Discount rates are estimated based on the Capital Asset Pricing Model, which considers the risk-free interest
rate, market risk premium, and beta. For the 2008 annual goodwill impairment evaluation, the discount rate used to
develop the estimated fair value was 16%.

Change in Control Assumptions

A total of 14 bank acquisition transactions since December 2004 were used, excluding mergers of equals.
Comparable target financial performance measures were considered in selecting the deals to be examined. The
transactions’ multiples were examined as announced and then adjusted using the price performance of the Keefe Regional
Bank Index since announcement of the transaction.

Market Capitalization

The market capitalization is analyzed in relation to numerous market and historical factors, including current
economic and market conditions, recent, historical, and implied stock price volatility, marketplace dynamics such as
the level of short selling, company-specific growth opportunities, and an implied control premium. In the current
unprecedented market environment, the size of the implied control premium can vary significantly based on the economic
and market conditions which may cause increased volatility in a company’s stock price, resulting in a temporary decline
in market capitalization; therefore, current market capitalization may not be an accurate indication of a market
participant’s estimate of entity-specific value measured over a more reasonable period of time.

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Ms. McHale and Mr. Dobbie

July 23, 2009

Page 4

Fair Value Results (per share)

    Discounted Cash Flow:

    $
    10.61

    Comparable Transactions Analysis:

    $
    12.17

    Market Capitalization:

    $
    6.60

    •

    a list in tabular form for each reporting unit identifying the reporting unit’s fair value, carrying
amount and goodwill;

RESPONSE: We have only one reporting unit. The Company’s shareholder equity represents carrying value. Goodwill
is disclosed in the balance sheet filed with the SEC. Please see response above for fair value of the Company.

    •

    the reporting units that required the second step of impairment testing;

RESPONSE: The second step of impairment testing was not required.

    •

    specific techniques and their assumptions used to determine fair value of the reporting unit;

RESPONSE: Not applicable as we were not required to perform a second step evaluation.

    •

    the type of report issued by the valuation firm and how management used this information to arrive at
the fair values ultimately used, including discussions of any adjustments made to the fair values
discussed in the report obtained; and

RESPONSE: Please see the response above. No formal report was issued. Management utilized discounted cash flow
and change in control valuations obtained from an independent third party in its assessment of impairment. There were
no adjustments made to the fair values.

    •

    whether management performed any ‘reasonableness’ test or valuation procedures on the fair values
assumed for the reporting units. For example, tell us whether management reconciled the fair values of
the reporting units to the market capitalization of the company, and if so, the results of such testing.

RESPONSE: As a “reasonableness” test, management reviewed its change in market capitalization compared to the KBW
Bank ETF index and determined that the decline in our market capitalization was consistent with the decline in the
index. This “reasonableness” test was performed each quarter beginning June 30, 2008 and for the year ended December
31, 2008.

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Ms. McHale and Mr. Dobbie

July 23, 2009

Page 5

We will include the above-described disclosure relating to our methodology for and our results of testing goodwill
for impairment in our future filings.

Capital Resources, page 34

    4.

    We note your presentation of the tangible common equity ratio. This financial measure appears to be non-GAAP as
defined by Item 10(e) of Regulation S-K as it is not required by GAAP, Commission Rules, or banking regulatory
requirements. To the extent you plan to provide this non-GAAP measure in the future, please:

    •

    Clearly label the financial measure as non-GAAP each time it is presented;

RESPONSE: We will include the following disclosure in future filings:

This document contains financial information determined by methods other than those prescribed
by accounting principles generally accepted in the United States of America (“GAAP”). Seacoast’s
management uses these “non-GAAP” financial measures in its analysis of the Corporation’s performance.
Seacoast’s management believes that these non-GAAP financial measures provide a greater
understanding of ongoing operations and enhance comparability. These non-GAAP financial measures
include the tangible common equity ratio. Seacoast’s management uses this measure to assess the
quality of capital and believes that investors may find it useful in their analysis of the
Corporation. This capital measure is not necessarily comparable to similar capital measures that may
be presented by other companies.

    •

    State that in light of diversity in presentation in the marketplace, the methodology for determining
this measure may differ among companies; and

RESPONSE: Please see the response above.

    •

    Provide the required disclosures of Item 10(e) and ensure to disclose, in sufficient detail, the
reasons why you believe this presentation provides useful information to investors and specify how
management uses this measure.

RESPONSE: Please see the response above.

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Ms. McHale and Mr. Dobbie

July 23, 2009

Page 6

Table 9 — Loans Outstanding, page 47

    5.

    Please expand your table in future filings to include information for the last five years pursuant to General
Instruction 3(b) of Guide III.

RESPONSE: We will revise our future filings to include the information for the last five years pursuant to General
Instructions 3(b) of Guide III.

Reports of Independent Public Accountants, pages 57 and 58

    6.

    Please file the signed report of the independent public accountants. In addition, please file the signed
attestation report on the company’s internal control over financial reporting.

RESPONSE: The conformed signature of KPMG LLP was inadvertently dropped in the EDGAR version of our Annual Report
on Form 10-K. At the time of the filing of the Form 10-K, we were in possession of a signed copy of the Reports of
Independent Registered Public Accounting Firm of KPMG LLP. We are attaching the signed reports to this letter. We
respectfully advise the staff that we will include in all relevant future filings the conformed signature of our
independent registered public accounting firm on the reports and consents of such firm.

Financial Statements

Note D — Securities, pages 70-72

    7.

    We note the significant unrealized losses related to your private collateralized mortgage obligations. Please
provide us a detailed analysis of the securities’ impairment as of December 31, 2008 and March 31, 2009 that
identifies all available evidence, explains the relative significance of each piece of evidence, and identifies
the primary evidence on which you rely to support a realizable value equal to or greater than the carrying value
of the investment. Specifically tell us if you considered all available evidence, including information received
after year end, affecting the projected cash flows as of the period end. In addition, disclose the current and
initial (upon initial investment) credit ratings of the private collateralized mortgage obligations and correlate
any deterioration to your analysis above.

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Ms. McHale and Mr. Dobbie

July 23, 2009

Page 7

RESPONSE: The private label securities consist entirely of super senior AAA investments (these securities have not
been subject to deterioration and are still rated AAA) with collateral that consists of prime residential mortgages
originated between the years of 2003 and 2005. These investments are reviewed quarterly for other than temporary
impairment by considering the following primary factors: percent decline in fair value, rating downgrades,
subordination, duration, amortized loan-to-value, and the ability of the issuers to pay all amounts due in accordance
with the contractual terms. All private label bonds were analyzed and all were determined not to be
other-than-temporarily impaired. Information considered after year-end did not affect the projected cash flow as of
year-end. These bonds are all super senior Tranche SMMEA qualified
and are collateralized by one to
four family fixed and adjustable rate mortgage loans. The bonds’ collateral had no cumulative losses, and delinquency,
foreclosure and bankruptcy rates are low.

    8.

    We note that the company is a member of the Federal Home Loan Bank of Atlanta and at December 31, 2008 holds
approximately $12.8m in FHLB stock. Refer to the guidance of paragraph 12.21-12.25 of the AICPA Guide for
Depository and Lending Institutions and paragraph 8(i) of SOP 01-06. Please tell us and revise future filings to
more clearly discuss your accounting for these securities, including your impairment policy. In addition, present
a balanced discussion to state why, if true, that the company believes that its investment in FHLB Atlanta stock
is not other than temporarily impaired. For example, please discuss how you considered the fact that the FHLB
Atlanta will not pay a dividend for the fourth quarter of 2008 and will only repurchase 50% of each members excess
activity based stock outstanding as of March 16, 2009, but not to exceed the amount of such member’s excess
activity based stock on the date of repurchase.

RESPONSE: We hold stock in the FHLB of Atlanta totaling $7.3 million as of December 31, 2008. We account for the
stock based on the industry guidance in SOP 01-6, “Accounting by Certain Entities (Including Entities With Trade
Receivables) That Lend to or Finance the Activities of Others,” which requires the investment to be carried at cost and
evaluated for impairment based on the ultimate recoverability of the par value. We evaluated our holdings in FHLB
stock at December 31, 2008 and believed our holdings in the stock were ultimately recoverable at par. We do not have
operational or liquidity needs that would require a redemption of the stock in the foreseeable future and, therefore,
determined that the stock was not other-than-temporarily impaired. We will include this discussion in future filings.

Note R — Fair Value

Fair Value Instruments Measured at Fair Value, pages 89-91

    9.

    For fair value measurements using significant unobservable inputs (Level 3), expand the disclosure in future
filings to provide a reconciliation of the beginning and ending balances as required by paragraph 32(c) and (d) of
SFAS 157.

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Ms. McHale and Mr. Dobbie

July 23, 2009

Page 8

RESPONSE: All of our level 3 fair val