SecProbe.io

CORRESP
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        James Stevens

        404.885.3721 telephone

        404.885.3900 facsimile

        james.stevens@troutmansanders.com

        TROUTMAN SANDERS LLP

        Attorneys at Law

        Bank of America Plaza

        600 Peachtree Street NE, Suite 5200

        Atlanta, Georgia 30308-2216

        404.885.3000 telephone

        troutmansanders.com

July 1, 2015

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Era Anagnosti, Legal Branch Chief

 Re: United Community Banks, Inc.

Registration Statement on Form S-4

Filed June 15, 2015

File No. 333-204977

Dear Era:

On behalf of our client,
United Community Banks, Inc. (the “Company,” “we,” “us” or “our”), we have set
forth herein the Company’s response to the comments contained in the comment letter, dated June 29, 2015 (the “Comment
Letter”), from the Staff of the Division of Corporation Finance (the “Staff”) of the United States Securities
and Exchange Commission (the “SEC”), with respect to the Registration Statement on Form S-4 filed by the Company on
June 15, 2015 (File No. 333-204977) (the “Registration Statement”).

For your convenience, we
have set forth the comment from the Comment Letter in bold typeface and have included the Company’s response below it. The
numbered paragraph in this letter corresponds to the numbered paragraph of the Comment Letter.

Prospectus Cover Page

 1. We note your disclosure on page 49 stating that if the stock price falls below a certain floor,
United, subject to certain conditions, would have the option of increasing the consideration payable to Palmetto shareholders “by
increasing the exchange ratio…or by paying them cash merger consideration…” [emphasis added]. Please
revise your disclosure at the end of the third paragraph to state that the completion of the merger is subject to a floor price
which, if reached prior to completion of the merger, could result in more United shares being issued or the merger being terminated.
In addition, please provide a representative value of the

Atlanta
  BEIJING   CHARLOTTE   Chicago   Hong Kong   New York   Orange County
Portland   RAleigh

Richmond   San Diego   San francisco   Shanghai   Tysons Corner
Virginia Beach   Washington, DC

Era Anagnosti

United States Securities and Exchange Commission

July 1, 2015

Page 2

aggregate merger
consideration as of the most recently practicable date. At the end of the fifth paragraph, disclose a recent price quote for the
UCBI common stock.

  Response

  The Company intends to file an amendment to the Registration Statement which will (i) state that
the completion of the merger is subject to a price floor which, if reached prior to completion of the merger, could result in more
United shares being issued or the merger being terminated, (ii) provide a representative value of the aggregate merger consideration
as of the most recently practicable date, and (iii) disclose a recent price quote for the UCBI common stock. A copy of the proposed
disclosure is attached as Exhibit A.

Material
U.S. Federal Income Tax Consequences and Opinion of Tax Counsel, page 67

Consequences
to Shareholders, page 68

 2. Please remove the inappropriate assumption in the first paragraph of your disclosure since it
“assumes away” the very issue that counsel must opine upon.

  Response

  The Company intends to file an amendment to the Registration Statement which will remove the assumption
in the first paragraph of the Company’s disclosure. A copy of the proposed disclosure is attached as Exhibit B.

Exhibit 8.2 – Opinion
and Consent of Nelson Mullins Riley & Scarborough, L.L.P. as to the federal income tax consequences of the merger to United
and Palmetto

 3. Please have counsel revise the fifth paragraph of its opinion to opine that the merger will
qualify as a reorganization under the Internal Revenue Code. In the alternative, to the extent that counsel elects to provide a
short form opinion, the opinion and the tax disclosure in the prospectus both must state clearly that the disclosure in the tax
consequences section of the prospectus is the opinion of counsel, and the disclosure must clearly identify and articulate the opinion
being rendered. Refer to Section III.B.2 of Staff Legal Bulletin No. 19 (CF) dated October 14, 2011.

  Response

  Legal counsel has revised the fifth paragraph of its opinion to opine that the merger will qualify
as a reorganization under the Internal Revenue Code. A copy of the proposed disclosure is attached as Exhibit C.

Era Anagnosti

United States Securities and Exchange Commission

July 1, 2015

Page 3

  In preparing our response to the Staff’s comments, the Company acknowledges that:

·	should
the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission
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 and 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 let me know if you
have any further questions about the Registration Statement or this response to the Comment Letter. I can be reached at (404) 885-3721.

Thank you for your prompt
attention to this matter.

    Sincerely,

    /s/ James Stevens

    James Stevens

 cc: Jimmy C. Tallent

Exhibit A

The information in this document is not
complete and may be changed. We may not sell the securities offered by this document until the registration statement filed with
the Securities and Exchange Commission is effective. This document is not an offer to sell these securities, and we are not soliciting
an offer to buy these securities, in any state where the offer or sale is not permitted.

SUBJECT
TO COMPLETION, DATED JUNE 15, 2015

PROXY
STATEMENT/PROSPECTUS

MERGER PROPOSED
— YOUR VOTE IS VERY IMPORTANT

These materials
are a proxy statement of Palmetto Bancshares, Inc. (“Palmetto”) and a prospectus of United Community Banks, Inc. (“United”).
They are furnished to you in connection with the notice of special meeting of Palmetto shareholders to be held on [•], 2015.
At the special meeting of Palmetto shareholders, you will be asked to vote on the merger of Palmetto with and into United described
in more detail herein and to approve, on a non-binding advisory basis, the compensation that certain executive officers of Palmetto
will receive in connection with the merger pursuant to existing agreements or arrangements with Palmetto.

As of [•],
2015, the record date for the Palmetto shareholders meeting, there were [•] shares of common stock outstanding and entitled
to vote at that meeting. Approval of the merger agreement requires the affirmative vote of two-thirds of the outstanding shares
of Palmetto common stock. Approval of the merger-related compensation proposal requires that the number of votes cast at the special
meeting, in person or by proxy, in favor of the proposal exceeds the number of votes cast against the proposal. You will also be
asked to vote on a proposal to adjourn or postpone the special meeting, if necessary or appropriate, including to solicit additional
proxies to approve the merger agreement, which proposal will be approved if the number of votes cast at the special meeting, in
person or by proxy, in favor of the proposal exceeds the number of votes cast against the proposal.

Subject
to the election and adjustment procedures described in this document, in connection with the merger if approved and consummated,
holders of Palmetto common stock will be entitled to receive, in exchange for each share of Palmetto common stock, consideration
equal to either (i) 0.97 shares of United common stock, or (ii) $19.25 in cash, without interest; provided, that the total merger
consideration shall be prorated as necessary to ensure that 30% of the total outstanding shares of Palmetto common stock will be
exchanged for cash and 70% of the total outstanding shares of Palmetto common stock will be exchanged for shares of United common
stock. The completion of the merger is subject to a price
floor which, if reached prior to the completion of the merger, could result in more United shares being issued or the merger being
terminated. As of July [•], 20151, the most recently
practicable date prior to the filing of this document, the aggregate merger consideration is approximately $[•] million.

As a result, a maximum
of 8,868,775 shares of United common stock will be issued to Palmetto shareholders if the merger is approved and consummated and
there is no adjustment to the stock consideration paid by United. This document is a United prospectus with respect to the offering
and issuance of such 8,868,775 shares of United common stock.

United’s common stock trades on
the NASDAQ Global Select Market under the ticker symbol

1
Note: This disclosure will be revised to be as of the day before the filing of the amendment to the registration statement.

“UCBI”. The
closing price of United common stock on July [•], 20152
was $[•] per share.

The accompanying
materials contain information regarding the proposed merger and the companies participating in the merger, and the Agreement and
Plan of Merger pursuant to which the merger will be consummated if approved. We encourage you to read the entire document carefully,
including “Risk Factors” section beginning on page 17, for a discussion of the risks related to the proposed merger.

Neither the
Securities and Exchange Commission nor any state securities commission has approved or disapproved of these securities or passed
upon the adequacy or accuracy of these materials. Any representation to the contrary is a criminal offense. Shares of common stock
of United are not savings accounts, deposits or other obligations of any bank and are not insured or guaranteed by the Federal
Deposit Insurance Corporation or any other governmental agency.

The date of
these materials is [•], 2015, and they are expected to be first mailed to shareholders on or about [•], 2015.

2
Note: This disclosure will be revised to be as of the day before the filing of the amendment to the registration statement.

Exhibit B

companies; mutual funds; tax-exempt organizations;
S corporations or other pass-through entities (or investors in such entities); regulated investment companies; real estate investment
trusts; dealers in securities or currencies; persons subject to the alternative minimum tax provisions of the Code; former citizens
or residents of the United States; persons whose functional currency is not the U.S. dollar; traders in securities that elect to
use a mark-to-market method of accounting; persons who own more than 5% of the outstanding common stock of Palmetto; persons who
hold Palmetto common stock as part of a straddle, hedge, constructive sale or conversion transaction; and U.S. holders who acquired
their shares of Palmetto common stock through the exercise of an employee stock option or otherwise as compensation.

For purposes of
this section, the term “U.S. holder” means a beneficial owner of Palmetto common stock that for United States federal
income tax purposes is: a citizen or resident of the United States; a corporation, or other entity treated as a corporation for
U.S. federal income tax purposes, created or organized in or under the laws of the United States, any state thereof or the District
of Columbia; an estate that is subject to U.S. federal income tax on its income regardless of its source; or a trust, the substantial
decisions of which are controlled by one or more U.S. persons and which is subject to the primary supervision of a U.S. court,
or a trust that validly has elected under applicable Treasury regulations to be treated as a U.S. person for U.S. federal income
tax purposes.

If a partnership
(including any entity or arrangement that is treated as a partnership for U.S. federal income tax purposes) holds Palmetto common
stock, the tax treatment of a partner generally will depend on the status of the partners and the activities of the partnership.
Partnerships and partners in such a partnership should consult their tax advisers about the tax consequences of the merger to them.

Holders of Palmetto
common stock are urged to consult with their own tax advisors as to the tax consequences of the merger in their particular circumstances,
including the applicability and effect of the alternative minimum tax and any state, local or foreign and other tax laws and of
any changes in those laws.

The Merger

The merger is intended
to constitute a “reorganization” within the meaning of Section 368(a) of the Code. Consummation of the merger is conditioned
upon each of United and Palmetto receiving a written tax opinion, dated the closing date of the merger, from their respective outside
legal counsels to the effect that, based upon facts, representations and assumptions set forth in such opinions, (i) the merger
will be treated for federal income tax purposes as a reorganization within the meaning of Section 368(a) of the Code, and (ii)
United and Palmetto will each be a party to that reorganization within the meaning of Section 368(b) of the Code. An opinion of
counsel represents the counsel’s best legal judgment and is not binding on the IRS or any court, and as a result, there can
be no assurance that the IRS will not asset, or that a court would not sustain, a position contrary to any such opinion. In addition,
if any of the representations or assumptions upon which these opinions is based are inconsistent with the actual facts, the U.S.
federal income tax consequences of the merger could be adversely affected. Accordingly, each Palmetto shareholder should consult
its tax advisor with respect to the particular tax consequences of the merger to such holder.

Consequences to United and Palmetto

Each of United and Palmetto will
be a party to the merger within the meaning of Section 368(b) of the Code, and neither United nor Palmetto will recognize any
gain or loss as a result of the merger.

Consequences to Shareholders

Assuming
the merger qualifies as a reorganization within the meaning of Section 368(a) of the Code, the
The
federal income tax consequences of the merger to a Palmetto shareholder generally will depend on whether the Palmetto shareholder
exchanges its Palmetto common stock for cash, United common stock or a combination of cash and United common stock.

Exchange Solely for Cash.
In general, if pursuant to the merger a U.S. holder exchanges all of its shares of Palmetto common stock solely for cash, that
shareholder will recognize gain or loss equal to the difference between the amount of cash received and its adjusted tax basis
in the shares of Palmetto common stock surrendered. Such gain or loss must be calculated separately for each identifiable block
of

Exhibit C

Palmetto Bancshares, Inc.

Page 2

In rendering
such opinion, we have assumed, with your permission, that (i) the Merger will be effected in accordance with the provisions of
the Merger Agreement, (ii) the statements concerning the Merger set forth in the Merger Agreement and the Registration Statement
are true, complete and correct and will remain true, complete and correct at all times up to and including the Effective Time,
(iii) the representations made by Parent and PLMT in their respective Representation Letters are true, complete and correct and
will remain true, complete and correct at all times up to and including the Effective Time, (iv) any representations made in the
Merger Agreement or the Representation Lette