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Securities and Exchange Commission Division of Corporation Finance 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

Re:

Dear Mr. Windsor:

The letter is provided on behalf of SCBT Financial Corporation (the “Company,” “SCBT,” “we,” or “our”) in response to the letter from the Securities and Exchange Commission (“SEC”) dated June 26, 2009 (the “Request Letter”) related to its review of the Company’s Form 10-K for the fiscal year ended December 31, 2008, Form 10-Q for the fiscal quarter ended March 31, 2009, Form 8-K filed April 28, 2009, and request for certain information.

The Company acknowledges that:

· The Company is responsible for the adequacy and accuracy of the disclosure in the referenced filings;

· Staff comments or changes to disclosures in response to staff comments do not foreclose the Commission from taking any action with respect to the referenced filings; and

· The Company may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.

Below we have outlined our response to the Request Letter. For your convenience, we have restated the SEC’s comment prior to our response.

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 loans have floating or adjustable interest rates in accordance with Section III.B of Guide 3. In addition, we note Table 11 on page 53 does not delineate the charge-offs and recoveries by loan category in accordance with Section IV.A of Guide 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.

RESPONSE:

The following disclosure is provided in accordance with Guide 3, Section III. B:

At December 31, 2008, the Company had a balance for loans due after one year of $407.3 million with fixed interest rates and $141.6 million with adjustable interest rates in the commercial real estate loan category. At December 31, 2008, the Company had a balance for loans due after one year of $92.1 million with fixed interest rates and $47.6 million with adjustable interest rates in the commercial and industrial loan category.

Additionally, please find attached the information required for the periods indicated in accordance with Guide 3, Section IV. A. (Revised Table 11) and Section IV. B (Table 11a).

SCBT Financial Corporation

Revised Table 11 - Summary of Loan Loss Experience

(dollars in thousands)

Allowance for loan losses at January 1

$

26,570

$

22,668

$

20,025

$

14,470

$

11,700

Charge-offs:

Real estate:

Commercial

(1,532

)

(446

)

(798

)

(459

)

(283

)

Consumer

(1,263

)

(374

)

(170

)

(124

)

(216

)

Commercial owner occupied

(61

)

—

(43

)

(143

)

—

Commercial & industrial

(1,449

)

(682

)

(454

)

(550

)

(316

)

Other income producing property

(185

)

(84

)

(418

)

(123

)

—

Consumer

(1,092

)

(491

)

(505

)

(451

)

(995

)

Other loans

(1,172

)

(1,248

)

(1,050

)

—

(198

)

Total loan charge-offs

(6,754

)

(3,325

)

(3,438

)

(1,850

)

(2,008

)

Recoveries:

Real estate:

Commercial

Consumer

Commercial owner occupied

—

—

—

Commercial & industrial

Other income producing property

—

—

Consumer

Other loans

—

Total recoveries

1,008

Net charge-offs

(5,781

)

(2,317

)

(2,625

)

(1,467

)

(1,562

)

Provision for loan losses

10,736

4,384

5,268

4,907

4,332

Allowance from acquisitions

—

1,835

—

2,115

—

Allowance for loan losses at December 31

$

31,525

$

26,570

$

22,668

$

20,025

$

14,470

Average loans, net of unearned income

$

2,220,448

$

1,823,196

$

1,646,906

$

1,313,796

$

1,043,471

Ratio of net charge-offs to average loans, net of unearned income

0.26

%

0.13

%

0.16

%

0.16

%

0.21

%

Allowance for loan losses as a percentage of total loans

1.36

%

1.28

%

1.29

%

1.30

%

1.25

%

SCBT Financial Corporation

Table 11(a) - Allocation of the Allowance for Loan Losses

As of December 31,

(in thousands)

Amount

%*

Amount

%*

Amount

%*

Amount

%*

Amount

%*

Real estate:

Commercial

$

11,960

37.4

%

$

10,442

38.7

%

$

8,886

38.7

%

$

7,289

35.5

%

$

6,077

41.4

%

Consumer

6,909

22.3

%

5,527

21.0

%

5,010

22.3

%

4,886

24.5

%

4,153

29.0

%

Commercial owner occupied

4,865

18.3

%

3,268

14.8

%

2,267

12.5

%

1,982

12.3

%

6.1

%

Commercial & industrial

3,936

10.9

%

3,587

12.3

%

2,811

11.2

%

2,163

11.9

%

1,650

12.5

%

Other income producing property

1,890

6.1

%

1,568

5.9

%

1,428

6.5

%

1,302

6.0

%

0.3

%

Consumer

1,511

4.1

%

1,594

5.7

%

1,768

7.5

%

1,762

8.4

%

1,230

9.1

%

Other loans

1.0

%

1.6

%

1.3

%

1.3

%

1.6

%

Total allowance for loan losses

$

31,525

100.0

%

$

26,570

100.0

%

$

22,668

100.0

%

$

20,025

100.0

%

$

14,470

100.0

%

* Loan balance in each category, expressed as a percentage of total loans

All of the information from the comment above will be provided as required in future filings (Form 10-K).

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 loans as of December 31, 2008 and the two commercial land loans which drove the increase as of March 31, 2009. Please tell us and expand your discussion of these loans 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.

RESPONSE:

The seven loans which drove the increase from 2007 to 2008 were originated in 2005 (1), 2006 (4) and 2007 (2). All of these loans became non-performing loans in the last half of 2008, except for one which became non-performing in May 2008. The underlying collateral for all of these loans is real estate (4 residential land development loans, 1 multi-family development loan, 1 commercial non-owner occupied loan, and 1 completed residential spec loan), and the appraisals for four of the loans were done in 2008; one was done in 2007; and two were done in 2006. For the loans with appraisals earlier than 2008, new appraisals were done in the first quarter of 2009. Three of these loans are not in the depository footprint of the Company and are loan participations (Silverton related) which were acquired in prior bank mergers. Three of the other four loans are located on the coast of South Carolina.

The two loans which drove the increase from the end of 2008 to March 31, 2009 were originated in October of 2007. These loans became non-performing in January and March 2009, respectively. The underlying collateral for one of these loans is seven lots of commercial real estate located in North Carolina, and the other loan is supported by 31 residential lots on the coast of South Carolina. The appraisals for these two loans were recently updated with one being done in October of 2008 and one in March of 2009.

Through June 30, 2009, these “loans” (assets) are at different stages of resolution. Two loans remain on non-accrual status with specific reserves totaling $987,000, and with a total loan balance of approximately $4.8 million. Two “loans” were moved to OREO, and subsequently sold during the 2nd quarter of 2009, with original loan balances of approximately $1.4 million. The charge-offs related to these two “loans” totaled approximately $376,000. Four “loans” are now in OREO, and have been partially charged off by approximately $3.1 million. The original loan balances on these four loans totaled approximately $6.9 million. The last loan of this group is currently in the process of foreclosure, and the related collateral value is sufficient to cover the outstanding loan balance of approximately $394,000.

We will expand this discussion of these loans and similar loans in future filings to include the requested information.

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, tell us to what extent, if any, these conditions have changed from December 31, 2008 to the current date and discuss how your interim 2009 provisions have been impacted.

RESPONSE:

During 2008, the Company increased the allowance for loan losses (ALLL) compared to the prior year due to the increase in risk within the overall loan portfolio both on a general basis

and a specific basis. On a general basis, the company considers three-year historical loss rates, economic risk, model risk and operational risk when determining the ALLL. All of these factors are reviewed and/or adjusted each reporting period to account for management’s assessment of loss within the loan portfolio.

The three-year historical loss rate on an overall basis increased from 2007 due to the increase in loan losses the Company experienced in 2008, and especially the last half of 2008. This resulted in the need for a higher allowance for loan losses, given the rise in losses throughout the portfolio. The loan losses experienced in the first half of 2009 remain at elevated levels which increases these factors in determining the general allowance for loan losses.

Economic risk increased in 2008 versus 2007 due to rise in unemployment, rise in foreclosures, and the decline in home sales within the Company’s markets. These trends have continued into 2009, both in the first and second quarter of 2009.

Model risk has remained constant during 2008 and thus far into 2009. This risk comes from the fact that our allowance for loan losses model (or, for that matter, any model) is not all inclusive. Risk inherent with new products, new markets, and timeliness of information are examples of this type of exposure. Management has not yet had any significant changes or evidence from independent credit review which would warrant a change in this risk factor, therefore, this component of our model did not significantly impact the provision for loan losses in 2008 and thus far in 2009.

Operational risk consists of the underwriting, documentation, closing and servicing associated with any loan. This risk is managed through policies and procedures, portfolio management reports, best practices and the approval process. The risk factors evaluated include the following: exposure outside the Company’s deposit footprint, changes in underwriting standards, levels of past due loans, loan growth, supervisory loan to value exceptions, results of external loan reviews, the Company’s centralized loan documentation process and significant loan concentrations. The overall operational risk has remained slightly increased during 2008, due primarily to the increase in the level of past due loans, levels of classified assets and loan growth, which occurred primarily during the first half of 2008. This increase has been offset by a reduction in supervisory loan to value exceptions and a reduction in loan concentrations as the bank continues to reduce its portfolio of construction & land development loans. During the first quarter of 2009, operational risk was reduced slightly due primarily to the decline in net loan growth.

On a specific basis, the allowance for loan losses increased by $2.1 million during 2008. See page F-25, Note 5 and the analysis of changes in the allowance for loan losses. Specific reserves have increased by approximately $243,000 since December 31, 2008.

In terms of the conditions and how they have changed since December 31, 2008 through the first half of 2009, the allowance remains elevated due to the continued higher level of net charge offs, rising unemployment, and weak real estate markets. Offsetting this partially, is the fact that the Company has experienced no net loan growth since the beginning of the year (2009), reduced the exposure outside of our depository footprint, and reduced the Company’s

loan concentrations. Past due loans have leveled off at this point and are slightly lower than March 31, 2009; however, the level of classified loans continues to increase.

For future filings, the Company will more fully discuss the reasons the provision for loan losses in the reporting period in management’s discussion and analysis as requested above.

Item 13. Certain Relationships and Related Transactions, and Director Independence

Certain Relationships and Related Transactions, page 41 of Definitive Proxy Statement on Schedule 14A

4) We note the disclosure that loans to related 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 prevailing 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.

RESPONSE:

We confirm and will revise future filings of our Definitive Proxy Statement on Schedule 14A to disclose that loans to related persons were made on substantially the same terms, including interest rates, collateral and fee pricing as those prevailing at the time for comparable transactions with other persons not related to the lender, and did not, at the time they were made, involve more than the normal risk of collectability or present other unfavorable features.

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 homogenous loans are co