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      José
        Manuel de Araluce Larraz

      Subdirector
        General

      Cumplimiento
        y Relaciones Institucionales

    October
      5,
      2007

    Via
      EDGAR (Correspondence) and Courier

    Mr.
      Kevin
      W. Vaughn

    Branch
      Chief

    Division
      of Corporation Finance

    U.S.
      Securities and Exchange Commission

    100
      F
      Street, N.E.; mail stop 4561

    Washington,
      D.C. 20549

    U.S.A.

              Re:

              Banco
                Santander Central Hispano,
                S.A.

    Form
      20-F for the Fiscal Year Ended December 31, 2006

    File
      No. 001-12518

    Dear
      Mr.
      Vaughn:

    By
      letter
      dated October 4, 2007, you provided comments, in addition to those provided
      by
      letter dated September 5, 2007, on behalf of the staff (the “Staff”) of the U.S.
      Securities and Exchange Commission (the “SEC”) with respect to the Bank’s annual
      report on Form 20-F for the fiscal year ended December 31, 2006 (“Form 20-F”).
      In response to your comments and on behalf of the Bank, we have provided
      responses to those comments and supplementary information as indicated below.
      The text set forth below in bold-faced type, immediately following each
      paragraph number, is a verbatim reproduction of the comments included in your
      letter and appears in the order set forth therein.

    Consolidated
      Financial Statements

    Note
      1. – Introduction, basis of presentation of the consolidated financial
      statements and other information

    b)
      Basis of presentation of the consolidated financial statements, page
      F-7

              1.

              Please
                refer to our previous comment 1. In your response, you propose to
                disclose
                that Loan Losses are excluded from “Net Operating Income”. However, Loan
                Losses are only one example of various operating expenses including
                multiple provision and impairment charges that are excluded from
                your
                measure titled “Net Operating Income”. For purposes of transparency,
                please revise your proposed disclosures to specifically disclose
                that the
                profit and loss account mandatory presentation excludes certain operating
                expenses, including various impairment and provision charges from
“Net
                Operating Income”, and reduces “Gross Income” by certain
                expenses.

    Response

    In
      future
      filings, we will revise these disclosures to address the Staff’s
      comments.

    d)
      Measurement of financial assets and liabilities and recognition of fair value
      changes iii) Valuation techniques, page F-19

              2.

              We
                note your proposed enhanced disclosures in response to our previous
                comment 3. Paragraph BC38 of IFRS 7 specifies that the assumptions
                used in
                internal valuation models (for those models that could result in
                a
                significantly different estimate of fair value) shall be disclosed
                to give
                users of financial statements a sense of the potential variability
                of fair
                value estimates and of the sensitivity of fair value estimates to
                the main
                valuation assumptions. Therefore, please revise your future filings
                to
                disclose the main assumptions used for each valuation model disclosed.
                Additionally, please revise your proposed disclosures to identify
                the
                extent to which a particular valuation model is used to value certain
                of
                your asset and liability
                classes.

    Response

    In
      future
      filings, we will revise these disclosures to address the Staff’s
      comments.

    Note
      58.5 – Consolidated financial statements, page F-174

              3.

              Please
                refer to our previous comment 6. On page F-175, you state that these
                financial statements are prepared in accordance with EU-IFRS and
                are
                merely reclassified to conform to the presentation requirements of
                Regulation S-X. Therefore, it remains unclear why you have reclassified
                certain amounts to conform to FIN 46-R for this presentation, since
                FIN
                46-R is not within the scope of Regulation S-X. Please revise your
                future
                filings accordingly, or
                advise.

    Response

    In
      future
      filings, we will revise these disclosures to address the Staff’s
      comments.

    *  *  *  *

    In
      addition, as requested, we acknowledge that:

              ·

              The
                Bank is responsible for the adequacy and accuracy of the disclosure
                in the
                filing;

              ·

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

              ·

              The
                Bank 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.

    Should
      you
      have any questions about the responses contained herein, please contact José
Manuel de Araluce at +34-91-289-33-92.

    Very
      truly
      yours,

    /s/
      José
Manuel de Araluce

    José
      Manuel de Araluce

    Global
      Head of Compliance

    Cc:

    Mr.
      Nicholas Adams Kronfeld, Davis Polk & Wardwell

    Mr.
      Germán
      de la Fuente, Deloitte, S.L.

    Mr.
      Manuel
      Arranz, Deloitte, S.L.

    Mr.
      Fernando Ros, Deloitte, S.L.

    Ms.
      Mónica
      Cueva, Banco Santander, S.A.

    Mr.
      José
Galiana, Banco Santander, S.A.

    Mr.
      Javier
      del Castillo, Banco Santander, S.A.