SecProbe.io

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

 DIVISION OF
  CORPORATION FINANCE

June 21, 2011
  Via Email

Joseph M. Murphy President and Chief Executive Officer  Bar Harbor Bankshares   82 Main Street, P.O. Box 400   Bar Harbor, Maine 04609
Re: Bar Harbor Bankshares
 Form 10-K for the Fiscal Year Ended December 31, 2010   Filed March 16, 2011    Form 10-Q for the Quarter Ended March 31, 2011
Filed May 10, 2011  File No.  1-13349

Dear Mr. Murphy:

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 ten business days by amending your filing, by
providing the requested information, 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 ma y have additional comments
 Form 10-Q for Fiscal Quarter Ended March 31, 2011

Note 4: Securities Available for Sale

1. Please provide us your full detailed secu rities impairment analysis, as of both
December 31, 2010 and March 31, 2011, for the private label mortgage backed securities.  The analysis should address all availabl e evidence, explains the
relative significance of e ach piece of evidence, and identifies the primary

Joseph M. Murphy
Bar Harbor Bankshares   June 21, 2011   Page 2
 evidence on which you rely to support a real izable value equal to or greater than
the carrying value of the investment.
Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Nonperforming Loans
2. We note your response to comment one in our letter dated April 6, 2011.  In order
for us to more clearly unde rstand the nature, terms, collateral and any specific
allowance for loan loss recorded on this  specific loan, please address the
following:
 Tell us the original loan terms and indicate whether the terms have ever been
modified;
 Provide us with specific information deta iling the nature of the loan, sources of
repayment, repayment history (i.e. from housing units and affordability
covenants) to date as well as management ’s expectations regarding full repayment
of the loan upon maturity in August 2011;
 Regarding the repayment history, address the total number of housing units in the
project, how may units have been sold to  date and at what prices, the number of
affordability covenants sold as well as the related sales prices; and
 Provide us with details re garding the specific loss allo wances which have been
recorded and how these amounts have been determined at both December 31,
2011 and at March 31, 2011.
* * * *

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 Act
of 1933 and all applicable Securities Act rules require. 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.

 You may contact Marc Thomas, Staff Accountant, at (202)  551-3452 or me at
(202) 551-3492 if you have any questions regarding the above comments.

Sincerely,
        /s/ John P. Nolan         John P. Nolan         Sr Asst. Chief Accountant