SecProbe.io

January 12, 2011
 Ron J. Copher  Senior Vice President and CFO  Glacier Bancorp, Inc.  49 Commons Loop  Kalispell, MT 59901
Re: Glacier Bancorp, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 1, 2010 Forms 10-Q for the Quarterl y Periods Ended March 31, 2010,
June 30, 2010, and September 30, 2010
  File No. 000-18911

Dear Mr. Copher:
 We have reviewed your response letter da ted September 3, 2010 and have the following
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 within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested  response.  If you do not believe our comments
apply to your facts and circumstances or do not be lieve future revisions are appropriate, please
tell us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
            Form 10-Q for the Fiscal Qu arter Ended September 30, 2010

 Note (12) Fair Value of Fi nancial Instruments, page 22

1. We note from your response to prior comments tw o and five of our letter dated June 25,
2010 that you rely either on new or updated ap praisals and evaluati ons or you adjust the
last appraisal or evaluation to determine the valuation of your collateral-dependent
impaired loans and other real estate owned.  We note the adjustments made to the fair
value determined by the appraisal or evaluati on are based on other factors and events in
the environment including the timing of cash flows expected to be received.  Please

Ron J. Copher
Glacier Bancorp, Inc.  January 12, 2011 Page 2

revise future filings to include the above in formation that was provi ded in your response
for both impaired loans and othe r real estate owed.

2. In addition, we note your response to prior comment two of our letter dated June 25, 2010
that states the adjustments to the carrying va lue of an impaired loan can be made through
a provision for loan loss, a charge-off, or a re covery.  Please tell us and revise future
filings to describe the facts a nd circumstances that would lead  to an upward adjustment or
recovery in the carrying value of an impaire d loan. In addition, pl ease tell us the total
recoveries for the nine months ended Sept ember 30, 2010 due to the adjustments made to
the carrying value of a loan.
Item 2. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Non-Interest Expense, page 31

3. We note your response to prior comment five  of our letter dated June 25, 2010 that you
considered taking aggressive efforts to market  the real estate and other assets owned (e.g.,
auctions of individual properties or combina tion of properties).  In addition, we note your
disclosure on page 31 that the loss on sale of other real estate owned was $6.3 million for
the nine months ended September 30, 2010.  Plea se tell us and include in future filings,
how you considered these aggressive market stra tegies in your determination of estimated
selling costs for your real estate and other as sets owned.  In addition, please expand your
disclosures on the loss due to sale  of other real estate owned to include a discussion of the
changes made in your marketing effort s and the amount of related loss.
 Additional Management’s Discussion and Analysis

 Non-Performing Assets, page 42

4. We note your disclosure on page 43 that most  of the non-performing assets are secured
by real estate and based on current informati on Management determined that the value of
the underlying collateral is adequate to mini mize significant charge-offs or losses.  In
addition, we note that partial charge-offs totaling $25.8 million were made on impaired
loans that you continue to have concern about  the collectabil ity of the remaining balance
of $38.4 million at September 30, 2010.  Due to th e significant impact the collateral value
has to your valuation of impaired loans and charge-offs please disclose the following in
future filings:

Ron J. Copher
Glacier Bancorp, Inc.  January 12, 2011 Page 3

• How partially charged-off loans measured for impairment based on the collateral
value are classified and accounted for subs equent to receiving an updated appraisal.
For example, disclose whether the loans are returned to performing status or whether
they remain as nonperforming;
• Describe how charge-offs for confirmed lo sses impact the coverage ratio (total
allowance for loan losses divided by total nonperforming loans). For example,
consider providing the following types of disclosure:
o Nonperforming loans for which the full loss has been charged-off to total
loans;
o Nonperforming loans for which the full loss has been charged-off to total
nonperforming loans;
o Charge-off rate for nonperforming loans for which the full loss has been
charged-off;
o Coverage ratio net of nonperforming lo ans for which the full loss has been
charged-off;
o Total Allowance / (Total loans –Nonpe rforming loans for which the full loss
has been charged-off ); and
o Allowance for individually impaired loans / Total loans that are individually
impaired.

5. We note your response to prior comment one  of our letter dated June 25, 2010 and your
disclosure on page 44 that you had $30.6 million of loans that were issued to a single borrower or related party group of borrowers th at also had troubled  debt restructured
loans (TDRs) during the period that were classified as nonaccrual or partially charged-
off.  Please tell us and revise future filings  to disclose the factors you consider on an
ongoing basis to determine whether the non-re structured loans issued to the same
borrower(s) should continue  to accrue interest.

6. We note from your response to prior comment ten of our letter dated June 25, 2010 that
you consider new or updated appraisals or  evaluations, expected cash flows and the
timing thereof, and other current information in your determination of the fair value of
your construction and ADC loans.  Please revise  future filings to include the information
related to these portf olios from your response.  In addition, given that residential
construction and land, lot, and ot her construction portfolios acc ount for more than half of
your total net charge-offs and non-accrual lo ans, please provide enhanced disclosures
related to this concentration of credit risk and tell us the following for the five largest
loans in these portfolios:

Ron J. Copher
Glacier Bancorp, Inc.  January 12, 2011 Page 4

• General information about the borrower (i.e. commercial or residential land
developer, commercial  business, etc.);
• The type of collateral securing the loan;
• The amount of total credit exposure outstanding;
• The amount of the allowance allocate d to the credit relationship; and
• Additional information considered for suppor ting the allocated allowance for loan
loss for each credit.

7. We note your disclosure on page 44 that the majority of your commercial real estate
impaired loans had new or updated appraisals in the latter half of 2009 or 2010.  Please
tell us and include in future filings the a pproximate amount or percentage of impaired
loans for which the Company relied on a new or updated appraisal of  the collateral that
was not more than one year old to  assist in measuring impairment.

You may contact Lindsay McCord at 202- 551-3417 or me at 202-551-3423 if you have
any questions.
Sincerely,

Amit Pande Accounting Branch Chief