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[PEAPACK-GLADSTONE FINANCIAL CORP. LETTERHEAD]

September 10, 2012

VIA EDGAR/US MAIL/FACSIMILE

United States Securities & Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549-5546

Attention: Sharon Blume, Assistant Chief Accountant

 Re: Peapack-Gladstone Financial Corp.

Form 10-K for the Fiscal Year Ended December 31, 2011

Form 10-Q for the Quarterly Period Ended March 31, 2012

File No. 001-16197

Dear Ms. Blume,

We are in receipt of your letter
dated August 7, 2012, containing comments to the Annual Report on Form 10-K for the year ended December 31, 2011 and to the Quarterly
Report on Form 10-Q for the quarterly period ended March 31, 2012 of Peapack-Gladstone Financial Corporation (the “Corporation”).
Set forth below is our response to each of the numbered comments in your letter.

 1. SEC Comment: We note your disclosure on page six that the Corporation maintains its
conservative underwriting standards at the time of origination and continues its diligence in managing the loan portfolio. However,
we are unable to locate a complete discussion of your underwriting policies and procedures for each loan category. Please revise
future filings to provide this information. Discuss documentation requirements, loan to value ratios, FICO scores and all other
significant criteria considered in deciding to underwrite a loan. Discuss whether or not variable rate loans are underwritten at
the fully indexed rate and, if not, how you capture the associated risk in the underwriting process. To the extent your underwriting
policies and procedures have changed between periods, discuss the changes and ensure that your revisions address all types of loans
that you hold at each balance sheet date.

Response: Future filings will include the
following discussion regarding our material loan portfolios:

Primary Residential Mortgages.
The Bank originates one to four family residential mortgage loans within or around its primary geographic market area. When reviewing
residential mortgage loan applications, the Bank obtains detailed verifiable information regarding income, assets and indebtedness,
a credit report, and an independent appraisal of the property to be mortgaged. The Bank makes residential mortgage loans up to
80%

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September 10, 2012

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of the appraised value and up to 95% with private mortgage insurance. The Bank uses lower loan-to-value ratios for large loans
and loans on either second (vacation) homes or investment properties. The Bank’s underwriting guidelines include (i) minimum
credit report scores of 680 and (ii) a maximum debt to income ratio of 40% if the loan to value is 70% or higher and 45% if the
loan to value is less than 70%. Variable rate residential mortgage loans are underwritten using the higher of the fully indexed
rate or the note rate plus 200 basis points for 3/1 and 5/1 ARMS and the higher of the fully indexed rate or the note rate for
7/1 and 10/1 ARMS. Interest-only ARMS are underwritten using the same rate guidelines, but based on fully-amortizing payments.
The Bank may consider an exception to any guideline if the remaining characteristics of the application are sufficiently strong
to compensate. The Bank generally retains in its portfolio residential mortgage loans with adjustable rate features and/or shorter
maturities while loans with fixed interest rates and/or longer maturities are generally sold to third party financial institutions.
The Bank does not originate, purchase or carry any sub-prime mortgage loans.

Primary risk characteristics associated
with residential mortgage loans typically involve major living or lifestyle changes to the borrower, including unemployment or
other loss of income; unexpected significant expenses, such as for major medical issues or catastrophic events; divorce or death.
In addition, residential mortgage loans that have adjustable rates could expose the borrower to higher debt service requirements
in a rising interest rate environment. Further, real estate value could drop significantly and cause the value of the property
to fall below the loan amount, creating additional potential exposure for the Bank.

Bank management believes that the
underwriting guidelines previously described addresses the primary risk characteristics. Further, the Bank has dedicated staff
and system resources to monitor and collect on any potentially problematic residential mortgage loans.

Home Equity Lines of Credit.
The Bank provides revolving lines of credit collateralized by one to four family residences within or around its primary geographic
market. When reviewing residential mortgage loan applications, the Bank obtains detailed verifiable information regarding income,
assets and indebtedness, a credit report, and an independent appraisal of the property to be mortgaged. For home equity lines of
credit, the Bank utilizes the same underwriting standards as for primary residential mortgages, except variable rate home equity
lines of credit are underwritten using the rate floor (currently 3.50%) plus 200 basis points.

Primary risk characteristics associated
with home equity lines of credit typically involve major living or lifestyle changes to the borrower, including unemployment or
other loss of income; unexpected significant expenses, such as for major medical issues or

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catastrophic events; divorce or death.
In addition, home equity lines of credit typically are made with variable or floating interest rates, such as the Prime Rate, which
could expose the borrower to higher debt service requirements in a rising interest rate environment. Further, real estate value
could drop significantly and cause the value of the property to fall below the loan amount, creating additional potential exposure
for the Bank.

Bank management believes that the
underwriting guidelines previously described addresses the primary risk characteristics. Further, the Bank has dedicated staff
and system resources to monitor and collect on any potentially problematic home equity lines of credit.

Junior Lien Loan on Residence.
The Bank provides junior lien loans (“JLL”) against one to four family properties within or around its primary geographic
market area. Junior liens loans can be either in the form of an amortizing home equity loan or a revolving home equity line of
credit. These loans are subordinate to a first mortgage which may be from another lending institution. The Bank will require that
the mortgage securing the JLL be no more junior than a second lien position. The Bank will evaluate these applications in the same
manner as it underwrites primary residential mortgages. The combined first mortgage and junior lien loan must be no more than 80%
of the appraised value of the property when the combined debt is less than or equal to $800,000. For JLL amounts where the combined
debt exceeds $800,000, the maximum LTV ratio is 65%.

Primary risk characteristics associated
with junior lien loans typically involve major living or lifestyle changes to the borrower, including unemployment or other loss
of income; unexpected significant expenses, such as for major medical issues or catastrophic events; divorce or death. Further,
real estate value could drop significantly and cause the value of the property to fall below the loan amount, creating additional
potential exposure for the Bank.

Bank management believes that the
underwriting guidelines previously described addresses the primary risk characteristics. Further, the Bank has dedicated staff
and system resources to monitor and collect on any potentially problematic junior lien loans.

Multifamily and Commercial Real
Estate Loans. The Bank provides mortgage loans for multifamily properties (i.e. buildings which have five or more residential
units) and other commercial real estate that is either owner occupied or managed as an investment property. Commercial real estate
properties primarily include office and medical buildings, retail space, and warehouse or flex space. Some properties are considered
“mixed use” as they are a combination of building types, such as an apartment building that may have also have retail
space. In these cases the Bank determines which component provides the majority of the rental income for the property and utilizes
that component for the loan classification.

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The terms and conditions of all commercial
mortgage loans are tailored to the specific attributes of the borrower, the property or project, and any guarantors. In the case
of multifamily and investment commercial real estate properties, the Bank reviews, among other things, the nature of and diversity
of the underlying tenants and leases, the resources and experience of the sponsor, and the condition and location of the subject
property. With an owner occupied property, a detailed credit assessment is also made of the operating business. While the Bank’s
policy allows loan to value ratios of up to 80% of an appraised value, the majority of the loans are originated at loan to value
ratios of 70% or lower. Commercial real estate loans are generally made on a fixed rate basis with periodic rate resets every five,
seven or ten years over an underlying market index. The Bank requires an independent appraisal, a property conditions assessment
from an engineering firm, and appropriate environmental due diligence.

Multifamily and commercial real estate
loans are expected to be repaid from the cash flow of the underlying property so the collective amount of rents must be sufficient
to cover all operating expenses, property management and maintenance, taxes and debt service. In underwriting a commercial real
estate loan, the Bank evaluates the property’s historical operating income as well as its projected sustainability and generally
requires a minimum debt service coverage ratio that provides for an adequate cushion for unexpected or uncertain future events
such as the potential impact of changes in interest rates, vacancy levels and lease rates. The Bank’s credit analysis includes
stress testing each commercial mortgage loan for interest rate increases of at least 200 basis points (on variable rate loans or
for rate reset dates on fixed rate loans) as well as adverse changes in vacancy rates and rent levels.

The primary risk characteristics
are increases in vacancy rates, interest rates or other changes in general economic conditions that can all have an impact on the
borrower and their ability to repay the loan. Commercial real estate loans are generally considered to have a higher degree of
credit risk than multifamily loans as they may be dependent on the ongoing success and operating viability of a fewer number of
tenants who are occupying the property and who may have a greater degree of exposure to economic conditions. To mitigate this risk,
the Bank will generally require a standby assignment of leases, greater direct recourse to the owners, and/or a risk appropriate
interest rate and loan structure.

Bank management believes that the
underwriting guidelines previously described addresses the primary risk characteristics. Further, the Bank has dedicated staff
and system resources to monitor and collect on any potentially problematic multifamily and commercial real estate loans.

Commercial and Industrial Loans.
The Bank provides lines of credit and term loans to

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operating companies for business purposes. The loans are generally secured
by business assets such as accounts receivable, inventory and equipment. When underwriting business loans, among other things,
the bank evaluates the historical profitability and debt servicing capacity of the borrowing entity and the financial resources
and character of the principal owners and guarantors. When underwriting commercial and industrial loans, the Bank will evaluate
the potential impact of higher interest rates of at least 200 basis points.

Commercial and industrial loans are
typically repaid first by the cash flow generated by the borrower’s business operation. The primary risk characteristics
are specific to the underlying business and its ability to generate sustainable profitability and resulting positive cash flow.
Factors that may influence a business’s profitability include, but are not limited to, demand for its products or services,
quality and depth of management, degree of competition, regulatory changes, and general economic conditions. Commercial and industrial
loans are generally secured by business assets; however, the ability of the Bank to foreclose and realize sufficient value from
the assets is often highly uncertain.

To mitigate the risk characteristics
of commercial and industrial loans, the Bank may include financial covenants and/or require more frequent reporting requirements
from the borrower in order to better monitor its business performance.

Bank management believes that the
underwriting guidelines previously described addresses the primary risk characteristics. Further, the Bank has dedicated staff
and system resources to monitor and collect on any potentially problematic commercial and industrial loans.

Commercial Construction. The
Bank has substantially wound down its commercial construction lending activity since 2008. New construction loans are considered
only to experienced and reputable local builders and developers that have the capital and liquidity to carry a project to completion
and stabilization and for projects that are supported by either a permanent take-out or acceptable executed leases or sales contracts.
When evaluating a construction loan request, the Bank will also review the construction plans and drawings, costs estimates from
architects, and an independent appraisal. Construction loans typically have a 12-24 month period of interest only and a maximum
70% LTV ratio. Construction loans are considered riskier than commercial financing on improved and established commercial real
estate. The risk of potential loss increases if the original cost estimates or time to complete are significantly off.

Bank management believes that the
underwriting guidelines previously described addresses the primary risk characteristics. Further, the Bank has dedicated staff
and system resources to monitor and collect on any potentially problematic commercial construction loans.

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Exchange Commission
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 2. SEC Comment: Please revise future filings to disclose how you determine that future
payments are reasonably assured in order to return a nonaccrual loan to accrual status. Specifically disclose if a borrower needs
to make a certain number of monthly payments before returning a loan to accrual status.

Response:
We will revise future filings as follows:

A nonaccrual
loan is returned to accrual status only when interest and principal payments are brought current and future payments are reasonably
assured, generally when the Bank receives contractual payments for a minimum of six consecutive months.

 3. SEC Comment: Please tell us and revise future filings to disclose the following information
regarding your accounting policies for your troubled debt restructurings (TDR’s):

·
All factors you consider at the time a loan is restructured to determine whether the loan should accrue interest.

·
For your troubled debt restructurings that accrue interest at the time the loan is restructured, how you determine that
the loan has been restructured so as to be reasonably assured of repayment and of performance according to the modified terms and
that it is supported by a current, well-documented credit assessment of the borrower’s financial condition and prospects
for repayment