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CORRESP
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      SCBT Financial Corporation

    April
      4,
      2007

    Mr.
      John
      P. Nolan

    Accounting
      Branch Chief

    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 the Fiscal Year Ended December 31, 2006
      filed March 15, 2007 (file no. 001-12669)

    Dear
      Mr.
      Nolan:

    We
      are
      hereby responding to the letter from the Securities and Exchange Commission
      (“SEC”) dated March 23, 2007 (the “Request Letter”) related to its review of the
      Company's Form 10-K for the fiscal year ended December 31, 2006, filed March
      15,
      2007, and request for certain information.

    Below
      we
      have outlined our responses to the Request Letter. For your convenience, we
      have
      restated the SEC's questions prior to each of our responses.

    1)
      We note
      your disclosure on page 27 that the increase in your net charge-off ratio in
      2006 is partially attributable to a 0.04% increase resulting from adding
      automated overdraft protection (“AOP”) net charge-offs to the allowance for loan
      losses. Please describe for us your basis, including the specific guidance
      upon
      which you relied, for your previous presentation of AOP charge-offs outside
      of
      the provision and allowance for loan loss. Quantify the amount of AOP net
      charge-offs for each of the periods presented. Refer to the February 18, 2005
      Joint Guidance on Overdraft Protection Programs available at
      http://www.fdic.gov/news/news/financials/205/fil1105.html.

    RESPONSE:

    We
      have
      followed the February 18, 2005 Joint Guidance on Overdraft Protection Programs
      for the year ended December 31, 2006. The guidance states that “with respect to
      the reporting of income and loss recognized on overdraft protection programs,
      institutions should follow generally accepted accounting principles (GAAP)
      and
      the instructions for the Reports of Condition and Income (Call Report), and
      NCUA
      5300 Call Report. Overdraft balances should be reported on regulatory reports
      as
      loans. Accordingly, overdraft losses should be charged off against the allowance
      for loan and lease losses.” For the years ended December 31, 2005 and 2004, we
      classified AOP net principal charge-offs as “Other Expense” under noninterest
      expense in our consolidated statements of income. We used this accounting
      treatment because, at that time, our allowance for loan loss methodology did
      not
      include providing for AOP charge-offs through the provision for loan losses
      due
      to the short-term nature (no later than 60 days) of these charge-offs. After
      reviewing the Joint Guidance on Overdraft Protection Programs and discussion
      with our independent auditors, we determined that the reclassification of AOP
      net principal charge-offs from noninterest expense to the allowance for loan
      losses would have resulted in a higher provision for loan losses approximately
      equal to the amount of AOP net charge-offs through “Other Expense,” thus having
      no effect on net income reported for the years ended December 31, 2005 and
      2004.
      Moreover, due to the very short-term nature of the AOP product as stated above,
      we believe that earlier implementation of the Joint Guidance on Overdraft
      Protection Programs would have had an insignificant effect on the allowance
      for
      loan losses as of December 31, 2005 and 2004, and that the effect on
      comparability between reporting periods was immaterial.

        1

    At
      December 31, 2006, 2005, and 2004, AOP principal net charge-offs were
      approximately $729,000 and an estimated $676,000 and $567,000, respectively.
      Because our system did not breakout principal and fees for total AOP charge-offs
      prior to January 1, 2006, we estimated AOP principal net charge-offs for 2005
      and 2004 by applying the percentage of AOP principal charge-offs compared to
      total AOP charge-offs for 2006. Total AOP charge-offs includes the AOP principal
      charged off against the allowance for loan losses and fees expensed outside
      of
      the provision for loan losses. We believe that this approach for the comparative
      reporting periods presents a reasonable estimate of the AOP net charge-offs
      that
      would have been charged off against our allowance for loan losses.

    2)
      We
      noted your disclosures on page 27 that you had $2.1 million of reserves acquired
      in business combinations in 2005. Please describe for us the composition of
      the
      portfolios acquired and quantify the amount of specifically identified impaired
      loans as of the acquisition date. Tell us how you considered the applicability
      of SOP 03-3 with respect to the acquired loans.

    RESPONSE:

    The
      business combinations mentioned in the disclosure on page 27 refer to our
      acquisition of New Commerce Bancorp on April 8, 2005 and Sun Bancshares, Inc.
      on
      November 18, 2005. The New Commerce Bancorp had total loans of $70.1 million
      and
      the portfolio consisted of $41.5 million in mortgage real estate loans, $11.5
      million in commercial loans, $8.8 million in consumer loans, and $8.3 million
      in
      construction real estate loans. As of the acquisition date, there were no
      impaired loans. Sun Bancshares, Inc. had total loans of $86.8 million and the
      portfolio consisted of $47.3 million in commercial and industrial loans, $21.4
      million in mortgage real estate loans, $12.4 million in construction real estate
      loans, and $5.7 million in consumer and other loans. As of the acquisition
      date,
      there were no impaired loans. We did not acquire loans in these acquisitions
      requiring accounting under SOP 03-3, Accounting
      for Certain Acquired Loans or Debt Securities.

    3)
      We
      noted that in excess of 95% of your total time deposits mature and/or reprice
      during 2007. You state that you introduced competitive certificates of deposit
      products in certain South Carolina markets during 2006 which lead to a
      significant increase in this product. Please tell us and revise all relevant
      future filings to include a discussion of your deposit retention plan, impact
      on
      liquidity and alternative sources of funding if you are unsuccessful, and the
      impact on your net interest margin and spreads from either
      scenario.

        2

    RESPONSE:

    We
      have
      shortened the maturities of our certificates of deposit products in response
      to
      the current rate environment. Our approach may provide us with an opportunity
      to
      lower our cost of funds as we anticipate declining interest rates. We remain
      in
      accordance with our contingency funding plan and liquidity management
      policy.

    We
      engage
      in routine activities to retain deposits intended to enhance our liquidity
      position. These routine activities include various measures, such as (1)
      emphasizing relationship banking to new and existing customers, where borrowers
      are encouraged and normally expected to maintain deposit accounts with our
      banks, (2) pricing deposits, including certificates of deposit, at rate levels
      that will attract and/or retain a level of deposits that will enhance our banks’
asset/liability management and net interest margin requirements, and (3)
      continually working to identify and introduce new products that will attract
      customers or enhance our banks’ appeal as a primary provider of financial
      services.

    Our
      ongoing philosophy is to remain in a liquid position as evidenced by such
      indicators as (1) earning assets typically including some level of federal
      funds
      sold, reverse purchase agreements, and/or short-term investments, (2) strong
      asset quality, (3) well-capitalized position, and (4) profitable operating
      results. Cyclical and other economic trends and conditions can disrupt our
      banks’ desired liquidity position at any time. It is expected that these
      conditions will generally be of short-term nature. Under such circumstances,
      the
      banks’ federal funds sold position serves as the primary source of immediate
      liquidity. When exhausted, the banks would turn to short-term borrowings as
      an
      alternative immediate funding source, and we may consider other appropriate
      actions such as promotions to increase core deposits or the sale of a portion
      of
      our investment portfolio.

    Our
      contingency funding plan provides several potential stages from low to crisis
      liquidity levels. Our Board of Directors reviews liquidity benchmarks quarterly.
      Also, we review on at least an annual basis our liquidity position and our
      contingency funding plans with our principal banking regulator. Our subsidiary
      banks maintain various wholesale sources of funding. If our deposit retention
      plan were to be unsuccessful, our banks would utilize these sources of funding.
      Depending on the external source of funds, our interest cost may vary based
      on
      the range of interest rates charged to our banks. This could increase our banks’
cost of funds, impacting net interest margins and net interest
      spreads.

    In
      all
      relevant future filings we will include a discussion of our deposit retention
      plan, impact on liquidity and alternative sources of funding if we are
      unsuccessful, and the impact on our net interest margin and spreads from either
      scenario.

        3

    We
      acknowledge 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.

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

    Sincerely,

    /s/
      John C. Pollok

    John
      C.
      Pollok

    Chief
      Financial Officer

    cc:
      William T. Pouncey, CPA, Partner, J.W. Hunt and Company, LLP

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