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Via EDGAR

January 31, 2011

Mr. Amit Pande

Accounting Branch Chief

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street N.E.

Washington, D.C. 20549

    Re:

     Glacier Bancorp, Inc.

Form 10-K for Fiscal Year Ended December 31, 2009

Filed March 1, 2010

Form 10-Q for the Quarterly Periods Ended March 31, 2010,

June 30, 2010, and September 30, 2010

File No. 000-18911

Dear Mr. Pande:

Consistent with telephone conversations with Ms. Lindsay McCord, Accountant, the following response
has been prepared by Glacier Bancorp, Inc. (the “Company”) to your January 12, 2011 comment letter
regarding the Form 10-K filed by the Company for the fiscal year ended December 31, 2009 and Forms
10-Q for the quarterly periods ended March 31, 2010, June 30, 2010 and September 30, 2010. The
time for responding to the comment letter was extended to January 31, 2011 in order to provide each
of the Company’s eleven bank subsidiaries sufficient time to separately accumulate certain
requested information and thereby provide the Staff with a complete and comprehensive response to
each of the comments.

For convenience and ease of review, we have reprinted below the text of the comment in your
correspondence, followed by the Company’s response.

Form 10-Q for the Fiscal Quarter Ended September 30, 2010

Note (12) Fair Value of Financial Instruments, page 22

    1.

    We note from your response to prior comments two and five of our letter dated June 25, 2010
that you rely either on new or updated appraisals and evaluations or you adjust the last
appraisal or evaluation to determine the valuation of your collateral-dependent

Mr. Amit Pande, Accounting Branch Chief

United States Securities and Exchange Commission

Page 2 of 13

    impaired loans and other real estate owned. We note the adjustments made to fair value
determined by appraisal or evaluation are based on other factors and events in the
environment including the timing of cash flows expected to be received. Please revise
future filings to include the above information that was provided in your response for both
impaired loans and other real estate owned.

Response:

In addition to the expanded discussion regarding the appraisal and evaluation process that
will be included (see below) in the Company’s Form 10-K for the year ended December 31,
2010, the following is an expanded discussion consistent with the request that will be
included in the fair value of financial instruments footnote in future filings as deemed
necessary:

Other real estate owned: other real estate owned is carried at the lower of fair value at
acquisition date or current estimated fair value, less estimated cost to sell. Estimated
fair value of other real estate owned is based on appraisals or evaluations. Other real
estate owned is classified within Level 3 of the fair value hierarchy.

Collateral-dependent impaired loans, net of ALLL: loans included in the Company’s financials
for which it is probable that the Company will not collect all principal and interest due
according to contractual terms are considered impaired in accordance with FASB ASC Topic
310, Receivables. Estimated fair value of collateral-dependent impaired loans is based on
the fair value of the collateral, less estimated cost to sell. Collateral-dependent
impaired loans are classified within Level 3 of the fair value hierarchy.

In determining fair values of the above “other real estate owned” and the
“collateral-dependent impaired loans” categories, the Company considers the appraisal or
evaluation as the starting point for determining fair value and the Company also considers
other factors and events in the environment that may affect the current fair value.

Provided below is the “Appraisal and Evaluation Process” discussion that will also be
included in the Company’s Form 10-K for the year ended December 31, 2010:

Appraisal and Evaluation Process

The Company reviews appraisals and evaluations, giving consideration to the highest and best
use of the collateral, with values reduced by discounts to consider lack of marketability
and estimated costs to sell. Although the Company considers the appraised value of
collateral as the starting point for determining fair value, the Company also considers
other factors and events in the environment that may affect the current fair value,
including the Company’s experience with whether the appraised values of impaired
collateral-dependent loans are actually realized, and

Mr. Amit Pande, Accounting Branch Chief

United States Securities and Exchange Commission

Page 3 of 13

the timing of cash flows expected to be received from the underlying collateral to the
extent such timing is significantly different than anticipated in the most recent appraisal.
After review and acceptance of the appraisal or evaluation (new or updated), adjustments to
an impaired loan’s value may occur. New or updated appraisals or evaluations are generally
obtained when it has been determined that a collateral-dependent loan has become impaired,
when it is likely that a real-estate loan will be foreclosed upon, and for other real estate
owned in connection with its transfer to the Company. Thereafter, appraisals or evaluations
(new or updated) are reviewed at least quarterly and more frequently based on current market
conditions, including deterioration in a borrower’s financial condition and when property
values may be subject to significant volatility.

The Company’s Loan Policy and credit administration practices adopt and implement the
applicable requirements of the Interagency Appraisal and Evaluation Guidelines (and the
Interagency Guidelines for Real Estate Lending Policies in Appendix A to Part 365 of Title
12, CFR) (collectively, the “Guidelines”) and the Uniform Standards of Professional
Appraisal Practice (“USPAP”) as established and amended by the Appraisal Standards Board.
The Company’s Loan Policy establishes criteria for obtaining appraisals or evaluations,
including transactions that are otherwise exempt from the appraisal requirements set forth
within the Guidelines. The time between ordering an appraisal or evaluation is typically
two to three weeks for residential property and four to six weeks for non-residential
property. For real estate properties that are of highly specialized or limited use,
significantly complex or large, additional time beyond the typical times may be required for
new appraisals or evaluations.

As part of the Company’s credit administration and portfolio monitoring practices, the
Company’s regular internal and external credit examinations review a significant number of
individual loan files. Appraisals and evaluations are reviewed to determine whether the
methods, assumptions, and findings are reasonable and in compliance with the Company’s Loan
Policy and credit administration practices, the Guidelines and USPAP standards. Such
reviews include the adequacy of the steps taken by the Company to ensure that the
individuals who perform appraisals and evaluations are appropriately qualified and are not
subject to conflicts of interest. Deficiencies, if any, are reported to the Board of
Directors and prompt corrective action is taken.

    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 value of an impaired loan can be made
through a provision for loan loss, a charge-off, or a recovery. Please tell us and revise
future filings to describe the facts and circumstances that would lead to an upward
adjustment or recovery in the carrying value of an impaired loan. In addition,

Mr. Amit Pande, Accounting Branch Chief

United States Securities and Exchange Commission

Page 4 of 13

    please tell us the total recoveries for the nine months ended September 30, 2010 due to
the adjustments made to the carrying value of a loan.

Response:

The following is an expanded discussion consistent with the request that will be included in
future filings as deemed necessary:

In determining the appropriate balance of the Allowance for Loan and Lease Losses (“ALLL”),
the Company attributes portions of the ALLL to loans that it evaluates and
determines to be impaired under FAS 114 and to groups of loans that it evaluates
collectively under FAS 5. However, the ALLL is available to cover all charge-offs that
arise from the loan portfolio.

At the time a loan is identified as impaired, it is measured for impairment and thereafter
reviewed and measured on at least a quarterly basis for additional impairment.
The amount of the impairment is measured based on the present value of expected future
cash flows discounted at the loan’s effective interest rate, except when it is determined
that repayment of the loan is expected to be provided solely by the underlying collateral.
For collateral-dependent loans, impairment is measured by the fair value of the collateral
less the estimated cost to sell. The Company measures impairment on collateral-dependent
loans on a loan-by-loan basis.

Facts and circumstances that would lead to an upward adjustment or recovery in the value of
an impaired loan where impairment is measured based on the present value of expected cash
flows includes an increase in the expected cash flows. For example, if the present value of
expected cash flows for an impaired loan (that is not collateral-dependent) increases by
$1,000,000, the specific portion of the ALLL attributed to such impaired loan may
decrease by an identical amount.

Facts and circumstances that would lead to an upward adjustment or recovery in the carrying
value of an impaired collateral-dependent loan includes (i) an appraisal or evaluation (new
or updated) that reflects an increase in the value of the collateral underlying the impaired
loan, or (ii) a decrease in the estimated costs to sell the underlying collateral. Like the
example in the prior paragraph, if the appraised value of real estate collateral underlying
a collateral-dependent loan increases by $1,000,000, the specific portion of the ALLL
attributed to such impaired loan may decrease by an identical amount.

However, upward adjustments or recoveries in the fair value of an impaired loan during 2009
and 2010 have been and are expected to continue to be very rare in occurrence in recognition
of the continuing economic downturn with its stress upon cash flows and collateral values,
especially real estate related. Upward adjustment

Mr. Amit Pande, Accounting Branch Chief

United States Securities and Exchange Commission

Page 5 of 13

or recovery in the fair value of an impaired loan is recognized by the Company only when
supported by independent third-party documented information.

Item 2. Management’s Discussion and Analysis 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 combination 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. Please tell us and include in future
filings, how you considered these aggressive market strategies in your determination of
estimated selling costs for your real estate and other assets 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 efforts and the amount of related loss.

Response:

The following is an expanded discussion consistent with the request. This expanded
discussion will be included in future filings as deemed necessary:

With respect to the $6.3 million of loss realized in the nine months ended September 30,
2010 from dispositions of other real estate owned, $3.1 million resulted from the sales of
individual or a combination of properties through auctions conducted by several of the bank
subsidiaries. Of the other real estate owned properties sold during the third quarter,
whether sold individually or through auction, several were sold at less than fair value,
such strategic decisions taking into account the potential for increases or decreases in the
property’s value over time and related holding period costs. Costs of the auctions,
including property-specific marketing costs and service fees paid to the third-party auction
firms, are aggregated with other directly-related selling costs in determining the loss
realized from disposition of the other real estate owned.

The use of auctions during the third quarter of 2010 was undertaken by the Company as a step
in evaluating strategic alternatives and consideration of more aggressive efforts to market
other real estate and other assets owned outside of the Company’s geographic operations to
attract additional interest. In addition to auctions, the Company utilizes real estate
companies (local and national franchises) as well as showcasing select properties through
the websites of the bank subsidiaries. Strategies for disposition of other real estate and
other assets owned

Mr. Amit Pande, Accounting Branch Chief

United States Securities and Exchange Commission

Page 6 of 13

by each subsidiary are developed specific to each property. The Company does not intend to
use auctions for disposition of other real estate or other assets owned until the second or
third quarters of 2011, if at all.

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 information Management determined that the value of the
underlying collateral is adequate to minimize 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 collectability of the remaining balance
of $38.4 million at September 30, 2010. Due to the significant impact the collateral value
has to your valuation of impaired loans and charge-offs please disclose the following in
future filings:

    •

    How partially charged-off loans measured for impairment based on the collateral
value are classified and accounted for subsequent 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 losses impact the coverage ratio (total
allowance for loan losses divided by total nonperforming loans). For example,
consider providing the following types of disclosure:

    •

    Nonperforming loans for which the full loss has
been charged-off to total loans;

    •

    Nonperforming loans for which the full loss has
been charged-off to total nonperforming loans;

    •

    Charge-off rate for nonperforming loans for which
the full loss has been charged-off;

    •

    Coverage ratio net of nonperforming loans for which
the full loss has been charged-off;

    •

    Total Allowance / (Total loans — Nonperforming
loans for which the full loss has been charged-off); and

    •

    Allowance for individually impaired loans / Total
loans that are individually impaired.

Response:

The following is an expanded discussion consistent with the request that will be included in
future filings as deemed necessary:

At the time a loan is identified as impaired, it is measured for impairment and thereafter
reviewed and measured on at least a quarterly basis for additional

Mr. Amit Pande, Accounting Branch Chief

United States Securities and Exchange Commission

Page 7 of 13

impairment. For collateral-dependent loans, impairment is measure