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    Alfredo Sáenz Abad

  Vicepresidente 2° y Consejero Delegado

    February 2, 2007

      Re:

      Banco Santander Central Hispano, S.A.

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

      Response Letter dated September 25, 2006

      Response Letter dated December 1, 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 December 20, 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 December 1, 2006 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” or the “Company”).

       We set forth
  below our responses to the Staff’s comments. 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 your response to comment 1
      of our letter dated November 16, 2006. It appears to the staff that it
      would be appropriate for future filings to include disclosure regarding
      your Iran-related operations, including the fact that you maintain a correspondent
      relationship with Bank Saderat and the fact that the U.S. has identified
      Bank Saderat as facilitating Iran’s transfer of funds to terrorist
    organizations.

    Alfredo Sáenz Abad

  Vicepresidente 2° y Consejero Delegado

    Please advise us whether your dealings
          with Bank Saderat are limited to your correspondent relationship, and
          describe for us the nature and extent of any additional dealings with
          Bank Saderat. Any disclosure in future filings regarding your dealings
          with Bank Saderat should make clear the nature and extent of your dealings
    with the bank.

    Please provide us with the text of the
          disclosure you propose to include in response to this comment prior
    to including it in a filed document.

     We confirm that
    our only business dealings with Bank Saderat are those resulting from our
    correspondent relationship with them. More specifically, through this correspondent
    relationship, we process payment orders from and to Bank Saderat and also
    receive, advise and if applicable confirm letters of credit that are issued
    by Bank Saderat to our clients. As part of the correspondent relationship,
    Bank Saderat maintains current accounts at Banco Santander for use in reimbursement
of the aforementioned transactions.

       In addition, we note that the
  U.S. Department of Treasury has also recently identified Bank Sepah as providing
  financial services to Iranian entities responsible for developing missiles
capable of carrying weapons of mass destruction.

       We confirm that we have a correspondent
  relationship, as described in our letter to the Staff dated September 25, 2006,
  with Bank Sepah and our only business dealings with this bank are those resulting
  from our correspondent relationship with them. More specifically, through this
  correspondent relationship, we process payment orders from and to Bank Sepah
  and also receive, advise and if applicable confirm letters of credit that are
  issued by Bank Sepah to our clients. As part of the correspondent relationship,
  Bank Sepah maintains a current account at Banco Santander for use in reimbursement
of the aforementioned transactions.

       With respect
  to the Staff’s comment that Santander include disclosure in its future filings regarding its operations in Iran, we respectfully reiterate our belief, which we have reconsidered in
depth on the basis of the Staff’s comments, that Santander’s operations in Iran are neither qualitatively nor quantitatively material. Moreover, we do not believe that, independent of materiality, there is any form requirement pursuant to
which disclosure of such operations would be necessary.  Form 20-F requires disclosure only as to the “principal markets in which the company competes” and does not otherwise require disclosure as to the Company’s
operations in Iran (or in any other specified country). Accordingly, we do not
believe that, under current circumstances, such disclosure should be included
in our future filings.

    Alfredo Sáenz Abad

  Vicepresidente 2° y Consejero Delegado

    2.
    We note the reference in your response
          to comment 1 to “customers who are nationals or residents in countries
          considered of high-risk in terms of money laundering or financing of
          terrorism.” Please identify for us the countries to which you
          refer. To the extent that you have contacts with additional countries
          identified by the U.S. as state sponsors of terrorism, provide the
          same type of information and analysis regarding your contacts with
          those countries as we requested regarding your contacts with Iran in
    our letter dated August 30, 2006.

    We inform the Staff that the following countries
        are those countries that we consider to be of high-risk in terms of money
        laundering or financing of terrorism: Afghanistan, Palestine, Iran, Iraq,
    North Korea, Pakistan, Sudan, Somalia, Syria and Yemen.

    With respect to the Staff’s
        request that we identify and describe our contacts with those countries
        identified by the U.S. as state sponsors of terrorism, we inform you
        that Santander, within the framework of its global business activities,
        maintains an exclusively commercial relationship in support of the export
        activities of its Spanish customers with the following countries identified
        by the U.S. as states sponsors of terrorism (in addition to Iran): Cuba,
        Sudan and Syria. We set forth below the same type of information and
        analysis regarding our contacts with these three countries as was requested
        by the Staff regarding our contacts with Iran in the Staff’s letter
    dated August 30, 2006.

     Our
  contacts with Cuba, Sudan and Syria considered individually or in the aggregate
  are de minimis. To our knowledge, we have not provided
any financing or other products or services to Cuba, Sudan or Syria relating
  to dual use or military use products. Furthermore, our contacts with, or financial
services related to, Cuba, Sudan and Syria are limited to the following:

    CUBA

    •
    Correspondent Relationships. As is
        customary in the banking sector, we have correspondent
        relationships with banks in a number of different
        countries, including Cuba, namely, Banco de Crédito y Comercio,
        Banco Popular de Ahorro, Banco Financiero Internacional,
        Banco Internacional de Comercio and Banco Exterior de
        Cuba, for the purpose of carrying out commercial transactions on behalf
        of our customers. Our volume of commercial transactions to and
        from Cuba pursuant to these correspondent relationships has historically
    been very low.

    •
    Export Letters of Credit. In connection
        with the exportation of goods and services to Cuba,
        certain of our customers are issued letters of credit
        by Cuban correspondent banks. We serve as the advising bank for
        these letters of credit, and forward them to the exporters without adding
    our confirmation (i.e., we do not guarantee payment against

    Alfredo Sáenz Abad

      Vicepresidente 2° y Consejero Delegado

    conforming documents). Consequently, these
        letters of credit are not paid until sufficient funds are received for
    their payment.

    For the twelve months ended December 31, 2005
        and the six months ended June 30, 2006, we had effected transactions
        in letters of credit issued by Cuban banks in an aggregate principal
    amount of approximately €8.5 million and €2.2 million, respectively.

    SUDAN

    •
    Correspondent Relationships. In order to support
        the commercial activity of our customers in Sudan,
        we maintain a correspondent banking relationship
        with the Omdurman National Bank. Our volume of
        commercial transactions to and from Sudan pursuant to this
    correspondent relationship has historically been de minimis.

    •
    Export Letters of Credit. In connection with the
        exportation of goods to Sudan, certain of our customers
        are issued letters of credit by Omdurman National
        Bank. We serve as the advising bank for these letters
        of credit, and forward them to the exporters without adding our
        confirmation (i.e., we do not guarantee payment against conforming
        documents). Consequently, these letters of credit are not paid
        until sufficient funds are received for their payment.

    For the twelve months ended December 31, 2005 and the
        six months ended June 30, 2006, we had effected transactions in letters
        of credit issued by Sudanese banks in an aggregate principal amount of
        approximately €0.005
    million and €0.035 million, respectively.

    SYRIA

    •
    Correspondent Relationships. We also maintain correspondent relationships
        with two banks in Syria, namely, Banque Bamo Saudi Fransi
        and Commercial Bank of Syria, for the purpose of carrying out commercial
        transactions on behalf of our customers. Our volume of commercial
        transactions to and from Syria pursuant to these correspondent
    relationships has historically been very low.

    We note that the Commercial Bank of Syria has been designated
        by the U.S. Department of Treasury as a bank of “primary money laundering
    concern”.

    We confirm that our only business dealings with the Commercial
        Bank of Syria are those resulting from our correspondent relationship
        with them. More specifically, through this correspondent relationship,
        we effect payment orders to and from the Commercial

    Alfredo Sáenz Abad

      Vicepresidente 2° y Consejero Delegado

    Bank of Syria on behalf of our clients, and
        also serve as the advising bank for letters of credit, and forward them
    to the exporters without adding our confirmation.

    •
    Export Letters of Credit. In connection
        with the exportation of goods to Syria, certain
        of our customers are issued letters of credit by Syrian
        correspondent banks. We serve as the advising bank for these letters
        of credit, and forward them to the exporters without adding our
        confirmation (i.e., we do not guarantee payment against conforming
        documents). Consequently, these letters of credit are not paid
        until sufficient funds are received for their payment. For the twelve
        months ended December 31, 2005 and the six months ended June
        30, 2006, we had effected transactions in letters of credit issued by
        Syrian banks in an aggregate principal amount of approximately €0.516
    million and €0, respectively.

    In addition, in connection with one of our customer’s
        importation of goods from Syria, we have issued one letter of credit
        to a Syrian private company on behalf of that customer. As of June 30,
        2006, this letter of credit was outstanding in an aggregate principal
        amount of approximately €0.125
    million.

     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 comment
  #2 in the Staff’s letter
dated August 30, 2006. 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 Cuba, Sudan or Syria
  or that a reasonable investor would expect further disclosure with respect
to those contacts in our Form 20-F for 2005.

       As noted above, our contacts with
  Cuba, Sudan and Syria are an entirely insignificant and immaterial component
  of our business. In assessing the materiality of our contacts with these countries,
  both individually and in the aggregate, we have considered both quantitative
  and qualitative factors. For the reasons we describe below, we believe that
  our contacts with Cuba, Sudan and Syria 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 these countries upon our reputation and share value.

       In quantitative terms, we believe
  that our contacts with these countries, individually and in the aggregate,
  are not material. We estimate that less than 0.005% of our net attributable
  income and 0.003% of our net interest income for the year ended December 31,
  2005, and 0.004% of our net attributable income and 0.002% of our net interest
income for the six months ended June 30, 2006,

    Alfredo Sáenz Abad

      Vicepresidente 2° y Consejero Delegado

  were generated from our contacts with these countries. 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 these countries 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 such as
  ours to have correspondent banking relationships throughout the countries of
  the world with which the Spanish Government maintains trade relations and to
  have letters of credit related to the commercial activities of our Spanish
  customers with such countries. To the extent that Cuba, Sudan and Syria are
  among the countries with which we have these customary banking relationships,
  we do not believe a reasonable investor would consider this material in making
an investment decision about our shares.

      3.

      We note your response to comment 2 of our letter dated November 16, 2006. If you participate in transactions that result, directly or indirectly, in the payment of cash to the Iranian government, please address specifically the
applicability of amended Section 5(b) of ISA to your participation in such transactions.

  The following are the only transactions that we participate
      in that result, directly or indirectly, in the payment of cash to the Iranian
    government:

  •
  Interest Paid on Deposits from Iranian Central Bank.
      Bank Markazi, the Iranian Central Bank, maintains
      deposits with Banco Santander in Spain. In 2005, on U.S. dollar deposits
      of approximately US$587 million, Banco Santander
paid approximately €7.4 million (approximately US$8.7 million) in interest
to Bank Markazi at market rates.

  For the first six months of 2006, on Euro deposits of approximately €302
      million (approximately US$238 million) and on US dollar deposits of
      approximately US$190 million, Banco Santander paid approximately €6.6
      mil