SecProbe.io

Mail Stop 4561   March 20, 2008

  Ron J. Copher Chief Financial Officer Glacier Bancorp, Inc. 49 Commons Loop Kalispell, MT 59901

 Re:       Glacier Bancorp
   Form 10-K for Fiscal Year Ended
   December 31, 2007    Filed February 29, 2008    File No. 0-18911

Dear Mr. Copher :
 We have reviewed your filing and have the following comments.  We have
limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of your documents.  Where indicated, we think you should revise the filing in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or revision is unnecessary.  Please be as detailed as necessary in your explanation.
Please understand that the purpose of our review process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings.  We look forward to working with you in these respects.  We welcome any questions you may have about our  comments or on any other aspect of our
review.  Feel free to call me at the telephone number listed at the end of this letter.  Form 10-K for the Fiscal Year ended December 31, 2007

 Management’s Discussion and Analysis, page 28

 Results of Operations, page 31

 Provision for Loan Losses, page 32

Mr. Copher
Glacier Bancorp, Inc. March 20, 2008 Page 2
 1. We note the increase in nonperforming loans from $7.4 million as of December
31, 2006 to $11.2 million as of December 31, 2007, resulting in nonperforming loans to total loans of 0.23% and 0.32% as of such dates.  However, we note that your allowance as a percentage of total loans decreased from 1.53% as of December 31, 2006 to 1.51% as of December 31, 2007.  We could not find an explanation in the document as to why your allowance decreased in 2007 despite the increase in nonperforming loans.
• Please tell us and revise future filings, as applicable, to explain how your
allowance and provisions are directionally consistent with changes in asset quality;
• Quantify and explain how changes in loan concentrations, quality, and
terms that occurred during the period are reflected in the allowance;
• Quantify and explain how changes in estimation methods and
assumptions affected the allowance, if applicable;
• Quantify and explain why reallocations of the allowance (or lack of
reallocations) among different parts of the portfolio or different elements of the allowance occurred; and
• Quantify and explain how actual changes and expected trends in
nonperforming loans affected the allowance.
 2. As a related matter, please tell us and revise future filings to provide your
accounting policy for: loan fees, recognizing interest income on impaired loans, cash payments received on impaired loans, and for charging off uncollectible loans.  Refer to SFAS 91, 118 and SOP 01-6, as appropriate.
 Financial Statements

 Note 21 – Operating Segment Information, page 74

 3. We note your segment titled “other” includes the parent company, non-bank
operating units and eliminations.  Please provide us with a break-out of the three components that make up the other column and explain to us why you believe the eliminations are not significant enough to break out into their own separate column.  Refer to paragraph 32 of SFAS 131.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing reviewed by the staff to be certain that they have provided all information investors require for an informed decision.  Since the registrant and its management are in possession of all facts relating to a registrant’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
 In connection with responding to our comments, please provide, in writing, a
statement from the registrant acknowledging that:

Mr. Copher
Glacier Bancorp, Inc. March 20, 2008 Page 3
 • the registrant 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 registrant 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.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.
As appropriate, please respond to these comments within 10 business days or tell
us when you will provide us with a response.  Please furnish a cover letter with your response that provides any requested supplemental information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Babette Cooper at ( 202) 551-3396 or me at (202) 551-3490 if
you have any questions.
Sincerely,    Don Walker Senior Assistant Chief Accountant