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    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

     April 27, 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

Response Letter dated February 2, 2007

File No. 1-12518

     Ms. Cecilia
        D. Blye

    Chief, Office of Global Security Risk

Division of Corporation Finance

    United States Securities and Exchange Commission

100 F Street N.E.

    Washington, D.C. 20549

     Dear Ms. Blye:

         Thank
          you for your letter dated March 21, 2007, 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 February 2, 2007 to your comment letter, dated December
          20, 2006, relating to the annual report on Form 20-F for the year
          ended December 31, 2005 of Banco Santander Central Hispano, S.A. (“Santander”).

            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 our responses follow each comment.

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

     General-

     1.
     We note your
          response to comment 1 of our letter dated December 20, 2006. We remain
          of the view 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. Department of the Treasury

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

    has
          identified Bank Saderat as facilitating Iran’s transfer of funds
          to terrorist organizations. The disclosure should also include the
          fact that you maintain a correspondent relationship with Bank Sepah
    and the fact that the U.S. Department of the Treasury has designated  Bank
    Sepah for providing support and services to designated Iranian proliferation
    firms.

             We
        inform the Staff that Santander has recently terminated its correspondent
        relationships with both Bank Sepah and Bank Saderat. As a result, Santander
        will no longer conduct any new business with either of these two banks.
        However, the following residual business transactions between Santander
    and these two banks will remain in place until their maturity:

    Bank Sepah

         Bank Sepah had a Euro account with Santander
            which has been cancelled. Pursuant to the European Union’s implementation
            of the United Nation Security Council’s sanctions against Iran,
            Santander has frozen the €204 balance from that account belonging
            to Bank Sepah.

        Santander has outstanding
            confirmed commercial letters of credit issued by, and export credit
            facility financings (in the form of “on-lending loans” as
            discussed in our response letter to the Staff dated September 25,
            2006) with, Bank Sepah in the amount of approximately €77 million
            (with varied maturity dates extending through 2014). Of this amount,
            approximately €74 million is insured by the Compañía
            Española de Crédito a la Exportación (“CESCE”),
            the Spanish export credit agency. As a result, Santander’s exposure
            under these letters of credit and export credit facility financings
            is limited to approximately €3 million.

        In addition to the aforementioned
            confirmed commercial letters of credit, Santander has acted as the
            advising bank on other commercial letters of credit issued by Bank
            Sepah which are unconfirmed, and therefore Santander has no financial
            exposure thereunder. Finally, there may be outstanding commercial
            letters of credit that were issued by Santander for its Spanish customers
            and confirmed or advised by Bank Sepah, but any risk of non-payment
            relating to those letters of credit rests with Santander’s customers
            (and with Bank Sepah). With respect to the unconfirmed commercial
            letters of credit issued by Bank Sepah as well as any commercial
            letters of credit issued by Santander

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

      and confirmed
              or advised by Bank Sepah, because
              Santander does not have any financial exposure thereunder, Santander’s
              systems do not track the amounts outstanding thereunder, if any. However,
              Santander estimates that any such outstanding amounts are de minimis.

      Although
                Santander has terminated its correspondent relationship with
          Bank Sepah, there is no contractual basis under any of these letters
          of credit and export credit facility financings for Santander to require
          repayment and/or to terminate them at this time. As a result, Santander
          cannot eliminate these residual transactions without writing off the
          amounts outstanding and/or breaching the relevant agreements. However,
          Santander will not confirm any additional letters of credit issued
          by Bank Sepah. In addition, Santander will not issue any
          additional letters of credit for confirmation
          by, nor extend any export credit facility financings to, Bank Sepah.

    Bank
            Saderat

         Santander has outstanding confirmed commercial
            letters of credit issued by Bank Saderat in the amount of approximately €9.1
            million (with varied maturity dates extending through 2007). Of this
            amount, however, approximately €8.3 million is insured by CESCE.
            As a result, Santander’s exposure under these letters of credit
            is limited to approximately €0.8 million.

         In addition to the aforementioned
            confirmed commercial letters of credit, Santander has acted as the
            advising bank on other commercial letters of credit issued by Bank
            Saderat which are unconfirmed, and therefore Santander has no financial
            exposure thereunder. Finally, there may be outstanding commercial
            letters of credit that were issued by Santander for its Spanish customers
            and confirmed or advised by
            Bank Saderat, but any risk of non-payment relating to those letters
            of credit rests with Santander’s customers (and with Bank Saderat).
            With respect to any unconfirmed commercial letters of credit issued
            by Bank Saderat as well as the commercial letters of credit issued
            by Santander and confirmed or advised by
            Bank Saderat, because Santander does not have any financial exposure
            thereunder, Santander’s systems do not track the amounts outstanding
            thereunder, if any. However, Santander estimates that any such outstanding
            amounts are de minimis.

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

        Although
            Santander has terminated its correspondent relationship with Bank Saderat,
            there is no contractual basis under these letters of credit for Santander
            to require repayment and/or to terminate them at this time. As a result,
            Santander cannot eliminate these residual transactions without writing
            off the amounts outstanding and/or breaching the relevant agreements.
            However, Santander will neither confirm any additional letters of credit
            issued by Bank Saderat, nor issue any additional letters of credit for
        confirmation by Bank Saderat.

              While
        Santander continues to be engaged in certain de
        minimis activities relating to Iran
        (as described in Santander’s response letters to the Staff dated
        September 25, 2006, December 1, 2006 and February 2, 2007), these activities
        are neither qualitatively nor quantitatively material to investors in
        our securities. For the reasons stated in our prior letters, we believe
        that Santander’s Iran-related activities have at no time been
        either qualitatively or quantitatively material, but in view of the particular
        sensitivities to institutions such as Bank Sepah and Bank Saderat, we
        have terminated our correspondent relationships with these banks. In
        the absence of these relationships, we do not believe that our remaining
        activities relating to Iran could potentially be viewed as material from
        any perspective. Accordingly, we do not believe that under current circumstances,
    disclosure  regarding Santander’s Iran-related
    operations should be included in our future filings.

     2.
      We
            note your response to comment 2 of our letter dated December 20,
            2006. It appears to the staff that it would be appropriate for future
            filings to include disclosure regarding the fact that you maintain
            a correspondent relationship with the Commercial Bank of Syria and
            that the U.S. Department of the Treasury has designated the Commercial
            Bank of Syria as a bank of primary money laundering concern.

              We
        inform the Staff that Santander has recently terminated its correspondent
        relationship with the Commercial Bank of Syria. As a result, Santander
        will no longer conduct any new business with this bank. However, the
        following residual business transactions between Santander and the Commercial
    Bank of Syria will remain in place until their maturity:

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

         Santander has issued guarantees (in the
            form of “bid bonds”) on behalf of its Spanish customers
            in favor of the Commercial Bank of Syria’s customers in the
            amount of approximately €3 million. Because of their nature
            as bid bonds, these guarantees will remain in place until the Spanish
            customers have complied with their obligations relating to the relevant
            bid. To the extent Santander would be required to make any payments
            under these guarantees, it would have recourse against the relevant
            Spanish customer, and not the Commercial Bank of Syria. Therefore,
            any risk of non-payment that Santander may bear as a result of
            issuing these guarantees is to its Spanish customers, and not to
            the Commercial Bank of Syria.

         In addition to these bid bonds, Santander
            may have acted as the advising bank on other commercial letters of
            credit issued by the Commercial Bank of Syria which are unconfirmed,
            and therefore Santander would have no financial exposure thereunder.
            Finally, there may be outstanding commercial letters of credit that
            were issued by Santander for its Spanish customers and confirmed
            by the Commercial Bank of Syria, but any risk of non-payment
            relating to those letters of credit rests with Santander’s customers
            (and with the Commercial Bank of Syria). With respect to any unconfirmed
            commercial letters of credit issued by the Commercial Bank of Syria
            as well as any commercial letters of credit issued by Santander and
            confirmed or advised by
            the Commercial Bank of Syria, because Santander does not have any
            financial exposure thereunder, Santander’s systems do not track
            the amounts outstanding thereunder, if any. However, Santander estimates
            that any such outstanding amounts are de
            minimis.

      Although
            Santander has terminated its correspondent relationship with the Commercial
            Bank of Syria, there is no contractual basis under the guarantees or
            the letters of credit for Santander to terminate them at this time. As
            a result, Santander cannot eliminate these residual transactions without
            breaching the relevant agreements. However, Santander will not issue
            or extend any additional guarantees to, or letters of credit for confirmation
        by, the Commercial Bank of Syria.

              While
        Santander’s activities with the Commercial Bank of Syria have historically
        been de minimis,
        in view of the particular sensitivities to institutions such as the Commercial
    Bank of Syria, we have terminated our correspondent

    Alfredo
    Sáenz Abad

    Vicepresidente
    2° y Consejero Delegado

     relationship
        with this bank. As a result, we do not believe it is necessary to include
        disclosure in our future filings relating to our now-terminated relationship
    with the Commercial Bank of Syria.

    3.
     Please
          provide us with the text of the disclosure you propose to include in
          response to the foregoing comments prior to including it in a filed
    document.

              For
        the reasons discussed above in response to Comments #1 and #2, we do
        not believe the requested disclosure should be included in our future
    filings.

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

            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