SecProbe.io

February 27, 2012
 Via Email

Rex S. Schuette Executive Vice President and Chief Financial Officer United Community Banks, Inc. 125 Highway 515 East Blairsville, GA 30512
Re: United Community Banks, Inc.
  Registration Statement on Form S-1
Filed June 29, 2011
  File No. 333-175226

Dear Mr. Schuette:
 We have limited our review of your registra tion statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not beli eve our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Form S-1 filed February 23, 2012

 Selling Shareholders, page 13

1. Revise to identify all selling shareholders that are broker/dealers or affiliates of
broker/dealers or, confirm that the entities described under footnotes  (13) through (18)
are the only selling shareholders that are broker/dealers or their affiliates.

2.  For those entities identified as broker/dealers or affiliates of broker/dealers, revise to add
disclosures stating that; the sell er purchased in the ordinary c ourse of business; and, at the
time of the purchase of the securities to be resold, the seller had no agreements or
understandings, directly or  indirectly, with any person to di stribute the securities. If such
representation cannot be made, revise toi di sclose such seller is an underwriter.

Rex S. Schuette United Community Banks, Inc. February 27, 2012 page 2

 3. Revise the footnotes, where applicable, to identi fy the person or persons who have sole or
shared voting or investment control of th e securities. See CD&I Q&A 140.02 of the Rule
S-K CD&I’s.
4. Confirm for Registration Statement 333-174420 that Elm Ridge Master Fund and Elm
Ridge Value Partners are not broker/dealers or affiliates of broker/dealers or make the disclosures requested above.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Rex S. Schuette United Community Banks, Inc. February 27, 2012 page 3

Please contact me at (202) 551-3434 with any questions.

Sincerely,
   /s/ Michael R. Clampitt
Michael R. Clampitt Senior Counsel
 cc: James W. Stevens
      Kilpatrick Townse nd & Stockton LLP