SecProbe.io

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

Mail Stop 4720         September 18, 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 June 30, 2009  File No. 001-12669

Dear Mr. Hill:

We have reviewed your response dated August 14, 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 have reviewed your response to comm ent 1 of our letter dated July 24, 2009.
We have the following comments:

a. You state you used an estimate of  75 basis points for your future
deferrals/defaults annually on your TRUPs.   Please clarify to us if you are
assuming a deferral/default rate of 75 basis points for each year in the
future.

Robert R. Hill, Jr.
SCBT Financial Corporation
September 18, 2009 Page 2
b. We note that your TRUPs have significan tly different actual  deferral rates,
credit ratings, and fair values.  Presumab ly, this is because each security has
different and distinct credit characterist ics represented by th e individual banks
in each trust and based on the specific  tranche in which you have invested.
We believe you must look at the specific  collateral underlying each individual
security to develop the credit deferra l/default assumptions for your estimated
cash flows and that simply using the same credit default assumption based on
the average long term performance of  FDIC regulated banks, AM Best’s
study, and Standard & Poor’s methodology for all of your se curities is not a
reasonable methodology consistent with the guidance.  Therefore, please
revise your TRUP OTTI me thodology to use the speci fic collateral underlying
each security as the basis for your credit deferral/default assumptions.

c. As a related matter, please tell us how  you were able to conclude that the
analysis you performed that considered the specific collateral underlying each
individual security was si milar enough to the analysis that based its default
assumptions on the performance of numerous banks, as discussed above.
 Form 10-Q for Fiscal Quarter Ended June 30, 2009

 Note 3 – Investments, page 7

 2. On page 9 you state the company evalua tes its “intent and ability” to hold
investments for a period of time sufficient  to allow for any anticipated market
recovery.  Please revise your  disclosure in future f ilings to discuss whether you
may be required to sell the security before recovery of its amortized cost basis and refer to paragraph 21 of SFAS FSP 115-2.
 3. We note the impairment recorded on PreT SL X B-1 and PreTSL X B-3 during the
three months ending June 30, 2009.  Please te ll us the events that transpired
during the three month period that caused these securities to become other than
temporarily impaired.  Please be as specific as possible in your response.
 4. On page 10 you state you will have “11.5% in  defaults over the next five years on
top of deferrals previously encountered in  prior periods ….”  Please tell us and
revise future filings to stat e the percentage of defaults that you expect will occur
in each of the next five years.
  *  *  *  *  *
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

Robert R. Hill, Jr.
SCBT Financial Corporation September 18, 2009 Page 3  reviewing your responses to our comments.

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