SecProbe.io

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

Mail Stop 4720         July 24, 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  File No. 001-12669

Dear Mr. Hill:

We have reviewed your response dated July 15, 2009 and have the following
comments.  Where indicated, we think you should revise your disclosure 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 provide us with information so we may better understand your disclosure.  Af ter reviewing this
information, we may raise additional comments.  Form 10-K for Fiscal Year Ended December 31, 2008

Financial Statements

Note 4 – Investment Securities, page F-21

1. We note your response to comment 6 of our  letter dated June 26, 2009.  We have
the following additional comments:

• We reiterate our request from our prev ious comment letter for you to provide
us with the following information:

a) The relative significance you place on each piece of evidence used in
your impairment analysis;

Robert R. Hill, Jr.
SCBT Financial Corporation
July 24, 2009 Page 2
b) The primary evidence you relied on to support a realizable value equal to or greater than the car rying value of the investment;

c) The class of each security that you hold (mezzanine, senior …)

• Please tell us and revise future filings to disclose if principal and interest
payments are still being made on a timely basis for each security.
 • Please provide us with the cash flow analyses you used to support a realizable
value equal to or greater than the ca rrying value of the PreTSL IX B-3 and
PreTSL X B-1 securities.  Please confirm that you use the same methodology
for all of your trust preferred securiti es.  Please identify all of the key
assumptions and explain how you determined the assumptions were appropriate and consistent with FSP FAS 115-1 and FAS 124-1 and related
guidance.  Specifically address the follo wing related to the assumptions used
in your cash flow analysis:

a) Discount rate: tell us the discount rate used and how you determined
it;
 b) Deferrals and defaults:

1) Please tell us in detail how you developed your estimate of
future deferrals and defaults.  Specifically tell us if and how you considered the specific collateral underlying each individual security;
 2) Please tell us the dollar amount  of deferrals and defaults
experienced by the trust by quarter;

3) Please tell us your estimate of fu ture deferrals and defaults and
compare your estimate to actual amounts experienced to date;

4) Tell us how you treat deferrals (e.g. – do you treat deferrals the same as defaults); and

5) Tell us about your recovery rate.

• Please tell us how you considered in formation received after the balance
sheet date but before you issued your fi nancial statements in your other-than-
temporary impairment analysis at December 31, 2008 and March 31, 2009.  Specifically tell us if you received info rmation regarding inte rest deferrals or
defaults or credit rating downgrades a nd how this information affected your
analysis at each period end.

Robert R. Hill, Jr.
SCBT Financial Corporation July 24, 2009 Page 3
• Please revise future filings to clearly disclose how you calculate excess
subordination and explain how the subordi nation percentage relates to other
column descriptions in order for an invest or to understand why this information is
relevant and meaningful.

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

 Management’s Discussion and Analysis, page 16

 Problem Loans, page 26

 2. We note your response to comment 8 of our letter dated June 26, 2009.  Please
revise future filings to in clude a discussion of the performance and progression of
your four loan participations from Silverton Bank.
   *  *  *  *  *
Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a cover letter that keys your responses to
our comments and provides any requested in formation.  Detailed cover letters greatly
facilitate our review.  Please understand th at 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.

 Please contact Babette Cooper, Staff A ccountant, at (202) 551-3396 or me at
(202) 551-3492 if you have any questions.
Sincerely,    John P. Nolan  Senior Assistant Chief Accountant