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CORRESP
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    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

    December 1, 2006

     Re:
    Banco Santander
          Central Hispano, S.A.

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

Response Letter dated September 25, 2006

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 November 16, 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 to our response
          letter dated September 25, 2006 (the “1st Response”)
          to your comment letter, dated August 30, 2006, relating 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. As we have
          done in our 1st Response
          letter, in order 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 the representation
          in your response letter dated September 25, 2006, that you have correspondent
          relationships with Iranian banks, including Bank Saderat. Please expand
          your qualitative materiality analysis to address the fact that the
          United States Department of the Treasury has recently identified Bank
          Saderat as facilitating Iran’s transfer of funds to terrorist
          organizations. Please also discuss any measures you have in place to
    stem terrorism financing, and their impact on your Iran-related operations.

         In
        assessing the materiality of our contacts with Iran, particularly considering
        the fact that the United States Department of the Treasury has recently
        identified Bank Saderat as facilitating Iran’s transfer of funds
        to terrorist organizations, we confirm the belief expressed in our 1st Response
    that our contacts
          with Iran are not material to our results of operations or financial
          condition, and of course, such contacts would be even less material
          if we consider in isolation our correspondent relationship with Bank
          Saderat. 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. This assessment of qualitative factors includes
          consideration of the potential impact of our corporate activities in
    Iran upon our reputation and share value.

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

          Further,
          we reiterate our belief that none of our past or current contacts with
          Iran (whether including or excluding our Bank Saderat contacts) 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 institutions from any number of countries
          abroad. To the extent Iran is among the countries with which we have
          these customary banking relationships (including our correspondent
          relationship with Bank Saderat), we do not believe a reasonable investor
          would consider this material in making an investment decision about
          our shares.

            With
          respect to your specific request to “discuss any measures you
          have in place to stem terrorism financing, and their impact on your
    Iran-related operations”, please note the following:

       Each transaction undertaken by the Bank
          on behalf of its customers is screened
          automatically with software developed internally by the Bank. This
          screening process enables us immediately to detect both attempts to
          open accounts and to execute transactions involving individuals or
          entities designated in the so-called
            “Applicable Lists” of relevant EU Regulations, in
            order to block the account opening or the attempted transaction immediately
            and place the funds at the disposal of the designated authorities.
            The Applicable Lists include the lists of terrorist individuals and
            organizations issued by the UN Security Council’s 1267 Committee
            (concerning Usama bin Laden, the Al-Qaida Network, and the Taliban),
            as incorporated into EU law by Council Regulation (EC) No. 881/2002,
            as amended, and the EU’s frequently-amended supplemental list
            of terrorist individuals and organizations issued by the Council
            of the European Union pursuant to its Regulation (EC) No. 2580/2001.
            For local regulatory reasons, OFAC’s List of Specially Designated
            Nationals and Blocked Persons (the “ SDN List ”) – while
            applied – is used only for subsequent
            scrutiny. Notwithstanding this, our experience has shown that the
            majority of names included on the OFAC SDN List for terrorism reasons
            is also reflected in the terrorist lists issued under the EU Regulations.

       This anti-terrorism screening process
          is observed in every jurisdiction where
          Grupo Santander operates, given the global, groupwide nature of our
          policies. These requirements are sent to our various business units
          in a centralized manner from Madrid. This process commenced with the
          initial UN Security Council sanctions against the Milosevic regime
          in 1999.

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

     Additionally, Grupo Santander has a consolidated
      reputational risk management policy
      distributed throughout its business units, which obligates
      these units to report to the parent company any important events relating
      to money laundering or the financing of terrorism.

   The transactions monitoring systems applied
      to our costumers include different cases
      which are internationally recognised as linked to financing of
      terrorism. Specifically, we have established very strict criteria for the opening
      of banking relations with exchange bureaux and money transmitters,
      and also fractioned transactions involving small amounts are monitored.
      Likewise, regular controls are carried out on the portfolios of those
      customers who are nationals or residents in countries considered of high-risk
      in terms of money laundering or financing of terrorism.

   In the correspondent banking area, a country-risk
      evaluation is made with regard to money
      laundering and the financing of terrorism. All countries internationally
      viewed as sensitive in the financing of terrorism (including Iran)
      are considered high-risk; therefore, enhanced due diligence is applied to
      banks established there.

   In the case of correspondent banking transactions,
      our operations are screened against
      the aforementioned lists, applying the same criteria.

   The monitoring procedures established for
      correspondent banking transactions contemplate,
      among other matters, enhanced due diligence concerning
      transactions involving exchange bureaux, structured transactions,
      and multiple negotiations of small-denomination cheques.
    The selection of transactions regarded as suspicious
    is also influenced by the country of origin
    and/or destination of the funds.

   The training given to our employees explains
      the risks associated with the financing
      of terrorism.

   In accordance with local legislation, our
      internal review programme is audited
      by an external expert (in this case, Deloitte). This year’s report found
      no areas needing improvement.

          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. Given the current geopolitical tensions with Iran,
          our activities involving Iran, both through the Iran representative
          office and through our financing activities, will continue to be carefully
    reviewed and approached in a conservative manner.

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

     2.
     Please
            address the applicability to your Iran-related operations of Section
            5(b) of the Iran and Libya Sanctions Act of 1996 (now the Iran Sanctions
            Act of 1996), as revised by the Iran Freedom Support Act, enacted
            on September 30, 2006.

         Section
        5(b) of the Iran Sanctions Act, as amended, is not applicable to our
        business activities in Iran, which do not involve arms or weapons trade
    or production financing, nor the Iranian military.

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

         In
        providing the above responses, and in response to the Staff’s request,
    we hereby acknowledge that:

       Santander is responsible for the adequacy
          and accuracy of the disclosure in
          its filings with the Commission;

       Staff comments or changes to this disclosure
          in response to Staff comments do
          not foreclose the Commission from taking any action with
          respect to the filing; and

       Santander 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.

         If
          you have any questions regarding this letter or the responses, please
          do not hesitate to contact the undersigned in Madrid at 011-34-91-259-6611
          or fax: 011-34-91- 257-1282, or our counsel, Nicholas Kronfeld of Davis
    Polk & Wardwell, at 212-450-4950 or fax: 212-450-3950.

    Very
        truly yours,

    /s/ Alfredo Sáenz

    Alfredo
        Sáenz

    Chief
        Financial Officer

    cc: Mr. Jack Guggenheim