SecProbe.io

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

 DIVISION OF
  CORPORATION FINANCE

November 2, 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  Form 10-Q filed for the Quarter Ended June 30, 2011 Filed August 8, 2011 File No.  1-13349

Dear Mr. Murphy:

   We have reviewed your supplem ental response 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 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 may have additional comments.
 Form 10-Q for the Quarter Ended June 30, 2011

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Nonperforming Loans

Joseph M. Murphy
Bar Harbor Bankshares   November 2, 2011 Page 2
 1. The staff notes your response to prior co mment two in our letter dated June 21,
2010. Please address the following as it relates to the loan to th e local, non-profit
housing authority:
 Tell us whether the loans were repaid  in August of 2011 or were extended
addressing the nature and terms of the extensions;
 If loan extensions were made, tell us how management determined there was
sufficient collateral to support repa yment of the loans taking into
consideration the amount and timing of previous housing unit sales and the net
proceeds received as well as economic and other conditions affecting sales.
Further, address whether the compa ny expects to be repaid during the
extension period or whether the comp any would continue to enter into
additional loan extensions until repayment has occurred;
 The collateral analysis should also address the number and amount of
affordability covenants (i.e. as well as define) the borrower has for sale as well other real estate available for sale for which the company has the
guaranteed right to receive the pr oceeds from these sales;
 Provide us with details of your specifi c loan loss allowance for the nine
months ended September 30, 2011.  It may be  appropriate to provide a table or
reconciliation, along with an accompanying textual discussion which highlights any significant triggering ev ents or other useful information to
understand how changes in the asset qua lity/performance of this loan was
considered during this time period;
 Tell us whether the company is continui ng to accrue interest income on these
loans; and
 Tell us why the current remaining outst anding aggregate loan balance does
not seem to be reflective of the principal payments received during the timeframe in which these loans have been outstanding.

* * * *

 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         Senior Assistant Chief Accountant