SecProbe.io

UNITED STATES
SECURITIES  AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE

Mail Stop 4720         June 26, 2009   Robert R. Hill, Jr. President and Chief Executive Officer SCBT Financial Corporation 520 Gervais Street Columbia, SC 29201

Re: SCBT Financial Corporation
 Form 10-K for Fiscal Year Ended December 31, 2008  Form 10-Q for Fiscal Quarter Ended March 31, 2009  Form 8-K filed April 28, 2009  File No. 001-12669

Dear Mr. Hill:

We have reviewed your filings and have the following comments.  Where
indicated, we think you should re vise your documents in response to these comments.  If
you disagree, we will consider your explanation as to why our comments are inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Form 10-K for Fiscal Year Ended December 31, 2008

 Management’s Discussion and Analysis, page 33

 Loan Portfolio, page 48

 1. We note Table 9 on page 50 showing the maturity distribution of your loans.  We
also note you have not stipulated which lo ans have floating or adjustable interest
rates in accordance with Section III.B of  Guide 3.  In addition, we note Table 11

Robert R. Hill, Jr.
SCBT Financial Corporation
June 26, 2009 Page 2
on page 53 does not delineate the charge-o ffs and recoveries by loan category in
accordance with Section IV.A of Guid e 3.  Lastly, we could not find the
information required by Section IV.B of Guide 3.  Please provide us with this
information for the required periods and confirm you will provide all of this data
in future filings.
 Nonaccrual Loans and Total Nonperforming Assets, page 50

 2. We note that non-performing loans have  increased from $6.3 million as of
December 31, 2007 to $14.9 million as of December 31, 2008 and then to $21.3M as of March 31, 2009. We also note your discussion of the seven loans which drove the increase in nonaccrual loan s as of December 31, 2008 and the two
commercial land loans which drove the in crease as of March 31, 2009.  Please tell
us and expand your discussion of these lo ans in future filings to include the
following information:

• When the loans were originated;
• When the loans became non-performing;
• The underlying collateral  supporting the loans;
• The last appraisals obtained for the loans, as applicable; and
• Any other pertinent information deemed necessary to understand your review
of the loans and related accounting for the loans as of December 31, 2008,
March 31, 2009 and through the date of your response.
 3. We note you recorded approximately $10.7 million in additional loss provision
due to higher net charge-offs as well as  loan growth during the year ending
December 31, 2008.  Please tell us and revise future filings to more fully discuss
the reasons for the provision in the period.  Additionally, te ll us to what extent, if
any, these conditions have changed from  December 31, 2008 to the current date
and discuss how your interim 2009 pr ovisions have been impacted.
 Item 13. Certain Relationships and Related Transactions, and Di rector Independence

 Certain Relationships and Related Tran sactions, page 41 of Definitive Proxy
Statement on Schedule 14A
 4. We note the disclosure that loans to re lated persons were made on substantially
the same terms as those prevailing at the time for comparable transactions with other persons.  Please confirm, and revise future filings to disclose, if accurate,
that the loans were made on substantially the same terms, including interest rates and collateral, as those prev ailing at the time for comparable loans with persons
not related to the lender
.  Refer to Instruction 4.c. to Item 404(a) of
Regulation S-K.

Robert R. Hill, Jr.
SCBT Financial Corporation
June 26, 2009 Page 3   Financial Statements

 Note 1 - Summary of Significant Accounting Policies

 Allowance for Loan Losses, page F-13

 5. We note your disclosure of your accounting policies with respect to impaired
loans that states “[l]arge groups of  smaller balance homogeneous loans are
collectively evaluated fo r impairment.”  As paragraph 6.a of SFAS 114
specifically scopes out large groups of smaller-balance homogeneous loans that
are collectively evaluated for impairment, pl ease tell us and clarify this policy in
future filings.
 Note 4 – Investment Securities, page F-21

 6. We note the significant unrealized losses related to your trust preferred securities
at December 31, 2008 and March 31, 2009.  We have the following comments:

• Please provide us a full detailed analysis  of these securities’ impairment as of
December 31, 2008 and March 31, 2009, that identifies all available evidence, explains the relative signif icance of each piece of evidence, and identifies the
primary evidence on which you rely to s upport a realizable va lue equal to or
greater than the carrying value of the investment.

• Please provide us and consider disclosing in future filings a table detailing the
following information for your trust preferre d securities: deal name, single-issuer
or pooled, class, book value, fair value,  unrealized gain/loss, credit ratings,
number of banks in issuance, deferrals and defaults as a percentage of collateral,
and excess subordination after taking into account your best estimates of future
interest deferrals and defaults.

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

 Balance Sheet, page 1

 7. We note your investment in FHLB Atlant a stock.  We also note that you did not
consider this investment other than temporarily impaired as of March 31, 2009.
In order to provide more transparent disc losure, please tell us, and revise your
future filings to disclose, how you cons idered any positive and negative factors
in reaching this conclusion.  Please discu ss how you considered the fact that the
FHLB did not make any dividend payments  in the fourth quarter of 2008 and will
not make any dividend determination until after the end of each quarter and after
quarterly results are known.  You may refer to the guidance of paragraphs 12.21

Robert R. Hill, Jr.
SCBT Financial Corporation
June 26, 2009 Page 4
to 12.25 of the AICPA Audit Guide for De pository and Lending Institutions and
paragraph 8(i) of SOP 01-06.
 Management’s Discussion and Analysis

 Problem Loans, page 26

 8. We note your disclosure regarding th e Office of the Comptroller of the
Currency’s closure of Silverton Bank on May 1, 2009.  Further, we note that you
had three loan participations with S ilverton with an a ggregate outstanding
participation loan balance of approxima tely $4.0 million and one piece of OREO
that resulted in a charge off of $1.7 million.  Please tell us and revise future filings to state your original loan balances, number of loans, non-accrual and nonperforming loan amounts, and the timing and amounts charged-off for your Silverton loan partic ipations.  In additi on, please provide us with your basis for
any remaining loan balances on your balance sheet as of March 31, 2009 and June 30, 2009, when available.
 Form 8-K filed April 28, 2009

 General

 9. We note your presentations of  average tangible equity, ta ngible equity to tangible
assets, tangible book value and other varia tions of these measures within this
filing and the Form 10-K as of December 31, 2008.  These measures appear to be non-GAAP measures as defined by Regulation G and Item 10(e) of Regulation  S-K as they are not requi red by GAAP, Commission Rule s, or banking regulatory
requirements.  To the extent you plan  to provide these non-GAAP financial
measures in the future, please address the following:  a. To the extent these measures are disclosed in future filings with the Commission, you should comply with all of  the requirements in Item 10(e) of
Regulation S-K, including clearly labe ling the ratio as a non-GAAP measure
and complying with all of the disclosure requirements.
 b. To the extent that you plan to disclose these measures in future Item 2.02 Forms 8-K, you should provide all of th e disclosures required by Regulation
G and Item 10(e)(1)(i) of Regulation S-K as required by Instruction 2 to Item 2.02 of Form 8-K.

c. To the extent you disclose or release publicly any material information that
includes a non-GAAP measure, such as these meas ures in your Item 8.01
Form 8-K, you should be cognizant of the requirements in Regulation G to label the measure as non-GAAP and pr ovide a reconciliation to the most
closely comparable GAAP measure.

Robert R. Hill, Jr.
SCBT Financial Corporation June 26, 2009 Page 5     *  *  *  *  *
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Pl ease furnish a cover letter that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your responses to our comments.
  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 all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  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 connection with responding to our comments, please provide, in writing, a 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 comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     You may contact Babette Cooper, St aff Accountant, at  (202) 551-3396 or
John Nolan, Senior Assistant Chief Accountan t, at (202) 551-3492 if you have questions
regarding comments on the financ ial statements and related matters.  Please contact
Matt McNair, Attorney-Adviser, at (202) 551-3583 or me at (202) 551-3419 with any
other questions.
Sincerely,

Christian Windsor  Special Counsel