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CORRESP
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    Alfredo
          Sáenz Abad

    Vicepresidente
          2° y Consejero Delegado

     September 25, 2006

     Re:
     Banco Santander
          Central Hispano, S.A.

     Form 20-F for
          the fiscal year ended December 31, 2005

     File No. 1-12518

     Ms. Cecilia
        D. Blye

     Chief, Office
        of Global Security Risk

     Division of
        Corporation Finance

     United States
        Securities and Exchange Commission

     450 Fifth Street,
        N.W.

     Washington,
        D.C. 20549-5546

     Dear Ms. Blye:

         Thank
          you for your letter dated August 30, 2006, setting forth comments of
          the staff of the Office of Global Security Risk of the Division of
          Corporation Finance (the “Staff”)
          of the United States Securities and Exchange Commission (the “Commission”)
          to the annual report on Form 20-F for the year ended December 31, 2005
          (the “2005 Form 20-F”)
          of Banco Santander Central Hispano, S.A. (“Santander”).

            We
          set forth below our responses to the Staff’s comments. To facilitate
          the Staff’s review, we have reproduced the captions and numbered
          comments from the Staff’s comment letter in boldface text and
          have used captions in our responses which follow each comment.

     *******************************

     General-

     1.
     We note that your
          website lists a representative office in Iran. Iran is identified by
          the U.S. State Department as a state sponsor of terrorism, and is subject
          to U.S. economic sanctions. Please describe for us the extent and nature
          of your past, current, and anticipated contacts with Iran, whether
          through subsidiaries, affiliates, material investments, or other direct
          or indirect arrangements. Discuss financing and/or other services provided
          to, and other contacts with, the Iranian government, including government-owned
          or controlled entities, as well as with private parties. Please also
          describe any potential or actual financing, or services or products
          provided, related to dual use or military use products.

    Alfredo
          Sáenz Abad

    Vicepresidente
          2° y Consejero Delegado

         Our
          contacts with Iran are an insignificant component of our business,
          comprising less than 0.031% of our net attributable income and 0.018%
          of our net interest income for the year ended December 31, 2005. To
          our knowledge, our contacts with, or financial services related to,
          Iran are as follows:

       Representative Office

            We
          maintain a representative office in Tehran, Iran, which was established
          over 25 years ago and currently has 5 employees. The representative
          office’s primary functions are to serve as a local contact point
          for our non-Iranian clients (primarily Spanish, European and Latin
          American customers) with business interests in Iran. Through this representative
          office, our clients are informed about business opportunities in Iran,
          including oil and infrastructure contracts for which bids are being
          solicited.

       Banking Activities

             Grupo
          Santander’s banking activities relating to Iran are primarily
          conducted by Banco Santander in Spain, but also by certain of its branches
          and affiliates located in Brazil, Hong Kong, France, Belgium and the
          United Kingdom. In terms of our global activities in each of the areas
          of business in which we engage, our activities involving Iran are de
    minimis.

         Correspondent Relationships.
            We have, as is customary in the banking
            sector, correspondent relationships with banks in a number
            of different countries, including Iran, for purposes of effecting
            money transfers and making or receiving payments on behalf
            of our clients. These banks include Bank Pasargad, Bank Maskan,
            Bank Mellat, Bank Parsian, Bank Markazi, Bank of Industry
            and Mine, Bank Saderat, Bank Tejarat, Export Development
            Bank of Iran, Bank Keshavarazi, Bank Melli, Bank Refah
            Kargaran and Bank Sepah. Our volume of money transfers and
            payment activity to and from Iran pursuant to these correspondent
            relationships has historically been very low.

         Deposits from Iranian Entities. Bank
            Markazi, the Iranian Central Bank,
            maintains deposits with Banco Santander in Spain. As of December
            31, 2005 and June 30, 2006, Bank Markazi held approximately
            US$ 587 million and US$ 574 million, respectively, in
            deposits with Banco Santander.

          In addition, an Iranian private company with
          a presence in Spain opened an account
          at Banco Santander in Spain in July 2006. As of
          September 22, 2006, this company held approximately US$ 110,000
          in deposits with Banco Santander. (We note that because this
          account was opened in July 2006, the amount of this deposit is

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

        not included in the statistics relating to
        total deposits by Iranian entities set
        forth in response to Comment 2 below).

         Export Letters of Credit. In
            connection with their exportation of goods
            to Iran, certain of our clients are issued letters of credit by Iranian
            banks. Our credit exposure to Iranian banks arises from our confirming
            or refinancing their letters of credit issued to our clients to
            fund exports to Iran.

          As of December 31, 2005 and June 30, 2006,
          we had credit exposure in respect
          of letters of credit issued by Iranian banks in an aggregate
          principal amount of approximately US$ 66.1 million and US$ 7.8
          million, respectively (0.013% and 0.001% of our total loans
          to customers at such dates, respectively).

         Performance Guarantees.
            We also issue stand-by letters of credit to
            guarantee the obligations (either under tender documents or under
            contracting agreements) of primarily Spanish, but also other European,
            contractors who participate in public bids in Iran. The guarantees
            in favor of the relevant Iranian official body awarding the
            contract are issued by Iranian state-owned banks, who in turn enjoy
            the benefit of a back-to-back guarantee by Banco Santander. Our
            systems track our exposure with respect to these types of stand-by
            letters of credit on a per applicant (as opposed to on a per beneficiary)
            basis. As a result, we cannot, on an automated basis, calculate
            our aggregate exposure of performance guarantees with respect
            to which the beneficiary is an Iranian entity.

         Other Financing Activities ( Export
              Credits ). We also provide medium
              and long-term financing for commercial contracts of primarily
              Spanish, but also other European, exporters with business
              activities in Iran. These financings are in the form of “on-lending
              loans” to Iranian state-owned banks. The amount of any of
              these loans is limited to a maximum of 85% of the amount of the
              relevant commercial contract per OECD consensus rules regulating
              Export Credits. These loans are insured, for a percentage
              of between 95% and 99% of the principal amount of the
              loan, by official export credit agencies (principally Compañía Española
              de Crédito a la Exportación,
              the Spanish export credit agency)
              and also benefit from a corresponding guarantee by the Ministry
              of Finance of Iran. As of December 31, 2005 and June 30,
              2006, we had approximately US$ 196.9 million and US$ 176.7 million,
              respectively, of Iranian export loans outstanding, of which approximately
              US$ 194.3 million and US$ 174.3 million, respectively,
              was insured by export credit agencies.

    Alfredo
          Sáenz Abad

    Vicepresidente
          2° y Consejero Delegado

    In addition,
        in 2004, we participated in an export-backed finance transaction for
        the Iranian government-owned Iran Petrochemical Commercial Company (IPCC),
        in which the off-taker was the United Kingdom subsidiary of a commodities
        company based in Switzerland. As of December 31, 2005 and June 30, 2006,
        we had approximately US$ 60 million and US$ 50.8 million outstanding
        under this financing transaction, respectively.

          To
          our knowledge, no financing or other products or services are provided
          for Iranian military purposes or for dual use items.

             In
          addition, in light of current political tensions with Iran, we have
          decreased our internal country risk exposure limits to Iran twice since
          the summer of 2005. Moreover, as noted above, we have as a policy ensured
          that our export credit exposure to Iran is covered (generally more
          than 95%) by non-Iranian export credit agency insurance. Given the
          current geopolitical tensions with Iran, our activities involving Iran,
          both through the Iran representative office and through our financing
          activities as described above and in answer to Comment 2 below, will
          continue to be carefully reviewed and approached in a conservative
    manner.

     2.
     Discuss
            for us the materiality to you of your contacts with Iran, and whether
            those contacts constitute a material investment risk for your security
            holders. Please address materiality in quantitative terms, including
            the dollar amounts of any associated assets and liabilities, and
            revenues. Please also address materiality in terms of qualitative
            factors that a reasonable investor would deem important in making
            an investment decision, including the potential impact of corporate
    activities upon a company’s reputation and share value.

     We note, for example, that Arizona and Louisiana
          have adopted legislation that requires their state retirement systems
          to prepare reports regarding state pension fund assets invested in,
          and/or permits divestment of state pension fund assets from, companies
          that do business with U.S.-designated state sponsors of terrorism.
          The Pennsylvania legislature has adopted a resolution directing its
          Legislative Budget and Finance Committee to report annually to the
          General Assembly regarding state funds invested in companies that have
          ties to terrorism-sponsoring countries. The Missouri Investment Trust
          has established an equity fund for the investment of certain state-held
          monies that screens out stocks of companies that do business with U.S.-designated
          state sponsors of terrorism. Your materiality analysis should address
          the potential impact of the investor sentiment evidenced by such actions
    directed toward companies that operate in Iran.

    Alfredo
          Sáenz Abad

    Vicepresidente
          2° y Consejero Delegado

         In
          assessing the materiality of our contacts with Iran, we have considered
          both quantitative and qualitative factors. For the reasons we describe
          below, we believe that our contacts with Iran are not material to our
          results of operations or financial condition. We further believe that,
          in light of the de minimis size
          and nature of these contacts, such contacts do not constitute a material
          investment risk for our security holders. Our assessment of qualitative
          factors included consideration of the potential impact of our corporate
          activities in Iran upon our reputation and share value.

            In
          addition to the qualitative factors we considered in making our analysis,
          we are aware of the sentiments expressed in the state legislation described
          in the Staff’s comment above. Although recognizing the sentiment
          expressed and restrictions imposed through these statutes, we do not
          believe that the effect or purpose of such state statutes would impact
          our conclusions regarding the absence of material investment risk arising
          from our contacts with Iran or that a reasonable investor would expect
          further disclosure with respect to those contacts in our Form 20-F
          for 2005.

            In
          quantitative terms, as is also evident from our response to Comment
          1 above, we believe that our contacts with Iran, individually and in
          the aggregate, are not material. Our total deposits by Iranian entities
          (for which, as of the dates noted below, the only Iranian entity was
          the Iranian Central Bank) represented 0.109% and 0.104%, respectively,
          of our total deposits at December 31, 2005 and June 30, 2006. Our gross
          and net (of export credit insurance) outstanding credit exposure to
          Iran represented 0.050% and 0.012%, respectively, of our total credit
          exposure at December 31, 2005 and 0.038% and 0.009%, respectively,
          of our total credit exposure at June 30, 2006. Even in the event of
          a hypothetical loss of the full amount of our credit exposure to Iran,
          there would have been no material impact on our results of operations
          or financial condition as at or for the periods referred to above,
          and there would be no material impact in subsequent periods. Similarly,
          we estimate that less than 0.031% of our net attributable income and
          0.018% of our net interest income for the year ended December 31, 2005,
          and 0.023 % of our net attributable income and 0.012% of our net interest
          income for the six months ended June 30, 2006, was generated from our
          contacts with Iran. These contacts have made no material contribution
          to our results of operations or financial condition and are not expected
          to have any material impact in subsequent periods.

            Further,
          we do not believe that any of our other past or current contacts with
          Iran would be qualitatively material to a reasonable investor making
          an investment decision about our shares. Rather, we believe that any
          reasonable investor would expect a bank like ours to have correspondent
          banking relationships throughout the countries of the world with which
          the Spanish Government maintains commercial relations, to have credit
          exposure in respect of financing transactions and letters of credit
          related to the commercial activities of our Spanish and other clients
          with such countries, and, in the course of conducting our business
    in Spain and elsewhere, to have deposits under custody from

    Alfredo
          Sáenz Abad

    Vicepresidente
          2° y Consejero Delegado

    institutions from
          any number of countries abroad. To the extent Iran is among the countries
          with which we have these customary banking relationships, we do not
          believe a reasonable investor would consider this mater