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CORRESP
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August 14, 2009

Mr. John P. Nolan

Senior Assistant Chief Accountant

Securities and Exchange
Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C.  20549

  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. Nolan:

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 July 24, 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, 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 (in italics)
prior to our responses.

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 previous 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;

RESPONSE:

The following lists each
piece of evidence and the rating of significance of each piece of evidence
(based upon a high significance, medium significance or low significance) used
in our impairment analysis:

·                  Discounted cash
flow analysis (EITF 99-20, as amended) — High / Primary evidence

·                  The Company’s
ability and intent to hold securities until recovery in value — High

·                  Excess
subordination amount and as a percentage of performing collateral, as
determined through a Stress / Break in yield analysis - High (the higher this
ratio the stronger probability that the security will continue to perform as to
principal and interest)

·                  Deferral/Default
Summary — High

·                  Texas ratios*
of underlying issuers in each pool — High

·                  Inactivity in
the TRUPs origination market and secondary market, leading to our use of Level
3 pricing for GAAP fair valuations — Medium

·                  Credit ratings —
Medium

·                  TARP recipients
/ pending recipients — Medium

·                  Risk Weighting
analysis — Medium

·                  Length of time
in unrealized loss position — Low

*The Texas ratio is defined to mean the amount of
non-performing assets divided by the tangible capital plus the allowance for
loan losses of a financial institution.

b)            The
primary evidence you relied on to support a realizable value equal to or
greater than the carrying value of the investment;

RESPONSE:

The Company primarily relies
upon the discounted cash flow analysis generated under EITF 99-20, as amended,
and the determination that this analysis provides

that we would receive our
contractual principal and interest by maturity for each trust preferred
collateralized debt obligation (“TRUPs”) security.  The amount of excess subordination or cushion
available (i.e., the additional defaults / deferrals it would take) before
there is a break in yield or cash flow shortfall is another indicator of
realizable value.

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

RESPONSE:

Included in the attached
table 1 and 2 — similar to what was included in Note 3 — Investment securities
of Form 10-Q for the period ended June 30, 2009.

·                  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.

RESPONSE:

Included in the attached
table 1 and 2 — similar to what was included in Note 3 — Investment securities
of Form 10-Q for the period ended June 30, 2009.

·                  Please
provide us with the cash flow analyses you used to support a realizable value
equal to or greater than the carrying value of the PreTSL IX B-3 and PreTSL X
B-1 securities.

RESPONSE:

Please see the attachments
for these cash flow analyses for PreTSL IX B-3 (attachment 3 & 5) and
PreTSL X B-1 (attachment 4 & 6).

·                  Please
confirm that you use the same methodology for all of your trust preferred
securities.

RESPONSE:

We employed EITF 99-20, as
amended, discounted cash flow analysis for all TRUPs holdings.

·                  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.

RESPONSE:

We primarily use discounted
cash flow analysis to evaluate and support the realizable value equal to or
greater than the carrying value of our TRUPs holdings.  Paragraph 13 of FSP FAS 115-1 and FAS 124-1
refers to EITF 99-20, and accordingly, we use an EITF 99-20 discounted cash
flow analysis as the cornerstone for this evaluation.

·                  Specifically
address the following related to the assumptions used in your cash flow
analysis:

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

RESPONSE:

PreTSL IX B-3 discount rate
used in the cash flow analysis was 5.32% for December 31, 2008 and 3.30%
for March 31, 2009.

PreTSL X B-1 discount rate
used in the cash flow analysis was 5.18% for December 31, 2008 and 3.17%
for March 31, 2009.

These discount rates were
determined by the current yield used to accrete the beneficial interest of each
security as prescribed by EITF 99-20a, paragraph 12(b).  This current yield can and will change from
quarter to quarter since these securities are variable rate instruments.

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;

RESPONSE:

For
the periods ended December 31, 2008 and March 31, 2009, we used the
following estimates of future deferrals / defaults:

75
basis points applied annually, with a 15% recovery rate after a two year lag,
applied each year until maturity.  This
scenario was developed from the following data:

·                  The FDIC lists
the number of bank failures each year from 1934-2008.  Comparing bank failures to the number of FDIC
institutions produces an annual average default rate of 36 basis points.

·                  AM Best
published “Best’s Impairment Rate and Rating Transitions Study 1977-2006” in
2007 that states the average annual impairment rate for all insurers is 72
basis points.

·                  On November 21,
2008, Standard & Poor’s published “Global Methodology for Rating Trust
Preferred / Hybrid Securities Revised”.
This analysis uses a recovery assumption of 15%.

In
computing a long-term default rate to be included in the PreTSL cash flow
analysis, we used approximately two times the historical long-term

bank
default rate and approximately one times the historical long-term insurer
impairment rate.

We
also compared this set of analyses against other considerations, including
specific consideration of the specific collateral underlying each individual
security.  We looked at numerous metrics,
including the Texas Ratio, for each issuer in the pools.  We considered the likelihood of defaults and
compared these to the amount of additional deferrals /defaults necessary to
incur a Break in Yield (i.e., the point at which we would not ultimately
collect all contractual principal and interest, the contractual cash flows, by
the maturity date of the security).

2)            Please
tell us the dollar amount of deferrals and defaults experienced by the trust by
quarter;

RESPONSE:

The
amounts below represent both deferrals and defaults for the respective time
periods.  The total current collateral
for each deal is listed to the right.

  Total

  Current

  (in thousands)

  4Q 2008

  1Q 2009

  Collateral

  PreTSL IX B-3

  $

  0

  $

  17,640

  $

  450,030

  PreTSL X B-1

  $

  19,500

  $

  37,500

  $

  512,145

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

RESPONSE:

At
December 31, 2008 and March 31, 2009, we estimated future deferrals /
defaults at 75 basis points on the remaining performing collateral annually
until maturity.  This assumption is in
addition to the historical defaults.
These estimates used at December 31, 2008 and March 31, 2009
would provide for future additional defaults totaling approximately 19% (which
is in addition to the defaults already experienced) that would be incurred over
the remaining life of the securities.
This compares to actual cumulative amounts experienced to date in PreTSL
IX of 11.7% and in PreTSL X of 17.9%.

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

RESPONSE:

We
treat deferrals the same as defaults (assume all deferrals will default) for
the two securities above and for all other TRUPs.

5)            Tell us
about your recovery rate.

RESPONSE:

We
assume a 15% recovery rate with a 2-year lag for all future deferrals/defaults
on our TRUPs.  This rate is conceptually
equal to about an eventual full recovery of principal on one out of every seven
defaults.

·                  Please
tell us how you considered information received after the balance sheet date
but before you issued your financial statements in your other-than-temporary
impairment analysis at December 31, 2008 and March 31, 2009.  Specifically tell us if you received
information regarding interest deferrals or defaults or credit rating
downgrades and how this information affected your analysis at each period end.

RESPONSE:

We
monitor information regarding our TRUPs investments typically on a daily basis,
but in terms of the financial reporting process this is done monthly.  We did consider information received after December 31,
2008 and March 31, 2009 balance sheet dates in our OTTI analysis.  It is not unusual for some issuers, if they
are going to defer interest payments, to make such announcements at or very
near a quarter-end.  However, we
typically have advance knowledge (before quarter-end) that an amount of
deferrals on collateral within a narrowly-specified range are forthcoming; but
we do not know which specific issuer(s) will make the announcement(s).

In
terms of total dollars of collateral on which dividends are deferred, there
were no unanticipated amounts that were announced (by specific issuer
name) subsequent to either the December 31, 2008 period end or the March 31,
2009 period end.

Subsequent
to December 31, 2008, there were no credit rating changes to
consider.  Subsequent to March 31,
2009, Fitch decreased its ratings from “A” to “CC” on all of our PreTSLs.  We considered this information but, since
Moody’s about two weeks prior to that time had decreased its ratings from “A2”
to “Ca” on all our PreTSLs, the Fitch action did not change our analysis or
conclusions.

·                  Please
revise future filings to clearly disclose how you calculate excess
subordination and explain how the subordination percentage relates to other
column descriptions in order for an investor to understand why this information
is relevant and meaningful.

RESPONSE:

See attached table — similar
to what was included in Note 3 — Investment securities and the related Notes to
the table of Form 10-Q for the period ended June 30, 2009.  We have defined what the percentages in the
table represent relative to excess subordination and deferrals / defaults and
how that information is relevant and meaningful in relation to the securities
we own.

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 include a
discussion of the performance and progression of your four loan participations
from Silverton Bank.

RESPONSE:

As noted, we will revise
future filings to include a discussion of the performance and progression of
these assets (Other Real Estate Owned or Loans) which resulted from the four
loan participations from Silverton Bank — see Form 10-Q for the period
ended June 30, 2009 within MD&A, subsection titled “Silverton Bank
Loan Participations.”

Please contact the undersigned at (803)
765-4630 with any questions regarding this letter.  Thank you.

Sincerely,

  /s/ John C. Pollok

  John C. Pollok

  Senior Executive Vice President
  and

  Chief Financial Officer

  cc:

  Matt Snow, CPA, Member,
  Dixon Hughes PLLC

  John Jennings, Nelson
  Mullins Riley & Scarborough LLP

  SCBT
  Financial Corporation

  TABLE
  1

  Pooled
  Trust Preferred Securities

  (dollars in thousands)

  Excess

  Deferral /

  Subordination

  Receiving

  Defaults

  as a % of

  #

  12/31/2008

  Principal /

  % of

  Current

  of

  12/31/2008

  12/31/2008

  Unrealized

  Credit

  Interest

  Current

  Performing

  Deal Name

  Class

  Issuers

  Book Value

  Fair Value

  Gain (Loss)

  Ratings (1)

  Contractually (2)

  Collateral (3)

  Collateral (4)

  PreTSL
  IX B-3

  Mezzanine

  51

  $

  2,982

  $

  1,945

  $

  (1,037

  )

  Ba3 / A

  Yes / Yes

  6.1

  %

  22.3

  %

  PreTSL
  X B-1

  Mezzanine

  58

  3,500

  1,576

  (1,924

  )

  B3 / A

  Yes / Yes

  12.1

  %

  16.7

  %

  PreTSL
  XVI C

  Mezzanine

  58

  988

  428

  (560

  )

  A2

  Yes / Yes

  6.9

  %

  23.2

  %

  Trust
  Preferred Securities - unrealized loss > 12 months

  7,470

  3,949

  (3,521

  )

  PreTSL
  X B-3

  Mezzanine

  58

  979

  450

  (529

  )

  B3 / A

  Yes / Yes

  12.1

  %

  16.7

  %

  PreTSL
  XI B-1

  Mezzanine

  67

  3,000

  1,605

  (1,395

  )

  B2 / A

  Yes / Yes

  9.4

  %

  19.8

  %

  PreTSL
  XIII B-2

  Mezzanine

  68

  1,000

  469

  (531

  )

  B3 / A

  Yes / Yes

  8.2

  %

  24.5

  %

  PreTSL
  XIV B-2

  Mezzanine

  63

  1,800

  1,032

  (768

  )

  Ba3 / A

  Yes / Yes

  4.2

  %

  22.4

  %

  MMCaps
  I A

  Senior

  29

  2,762

  2,578

  (184

  )

  Aa1 / AAA

  Yes / Yes

  9.2

  %

  31.8

  %

  Trust
  Preferred Securities - unrealized loss < 12 months

  9,541

  6,134

  (3,407

  )

  Total Trust Preferred Securities

  $

  17,011

  $

  10,083

  $

  (6,928

  )

(1)  Credit
Ratings represent Moody’s and Fitch ( S&P does not rate these securities).

(2)  Interest
on this secuirty is currently not being paid in cash, but is being added
(capitalized) to the bond balance, a process known as a payment in kind
(“PIK”).  This is the result of a
current, temporary interest shortfall being experienced due to the amount of
deferrals / defaults within the given deal, and therefore, there is not enough
interest available to pay the current interest on the given class of notes or
breaching the principal coverage test of the class of notes immediately senior
to the given class.  All securities were
paying and current at 12/31/2008.

(3)  The
ratio represents the amount of