SecProbe.io

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 September 19, 2025

Frank A. Cavallaro
Senior Executive Vice President, Chief Financial Officer
Peapack-Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

 Re: Peapack-Gladstone Financial Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-16197
Dear Frank A. Cavallaro:

 We have completed our review of your filings. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
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 NASDAQ: PGC       September 18, 2025   VIA EDGAR   U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549-0303 Attention: Sarmad Makhdoom and Lory Empie   Re: Peapack-Gladstone Financial Corporation Form 10-K for the Fiscal Year Ended December 31, 2024 Form 8-K filed July 21, 2025 File No. 001-16197   Dear Mr. Makhdoom and Ms. Empie:   On behalf of Peapack-Gladstone Financial Corporation (the “Company”) set forth below are the comments from the Staff’s letter dated September 10, 2025, as well as the Company’s responses to such comments.   Form 10-K filed March 12, 2025   Management’s Discussion and Analysis of Financial Condition and Results of Operations Wealth Management Division, page 54   1. We note assets under management (“AUM") and Assets under Administration (“AUA”) increased from $10.9 billion at December 31, 2023 to $11.9 billion at December 31, 2024. In future filings, please address the following points within your disclosure:   • Provide a roll forward of your AUM from beginning to ending balances showing inflows, outflows and market appreciation or depreciation for the periods presented within your financial statements. • Quantify your AUM and AUA balances separately, and to the extent possible, include a breakdown of AUM and the AUM roll forward by investment product or class in order show more meaningful changes in composition and trends impacting AUM.

 • Disclose your weighted average fee rates and how they correlate to movements within your AUM/AUA and changes in revenue for the periods presented within your financial statements. The Company hereby confirms that it will address the itemized points above within its disclosure in future periodic reports.   Form 8-K filed July 21, 2025   Exhibit 99.1 Non-GAAP Financial Measures Reconciliation, page 18   2. We note that your presentation of tangible equity excluding other comprehensive loss and tangible book value per share excluding other comprehensive loss represent individually tailored accounting measures given that the adjustment to exclude the impact of other comprehensive loss has the effect of changing the recognition and measurement principles required to be applied in accordance with GAAP. Therefore, please remove the presentation of this measure from future filings. Refer to Question 100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.   The Company confirms that it will remove the presentation of tangible equity excluding other comprehensive loss and tangible book value per share excluding other comprehensive loss from future filings. * * * * *   We believe the foregoing is responsive to the staff’s comments. Should you have any questions, please do not hesitate to contact the undersigned at (908) 306-8933.   Very truly yours,     /s/ Frank A. Cavallaro Frank A. Cavallaro Senior Executive Vice President and CFO

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 September 10, 2025

Frank A. Cavallaro
Senior Executive Vice President, Chief Financial Officer
Peapack-Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

 Re: Peapack-Gladstone Financial Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2024
 Form 8-K filed July 21, 2025
 File No. 001-16197
Dear Frank A. Cavallaro:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K filed March 12, 2025
Managements Discussion and Analysis of Financial Condition and Results of
Operations
Wealth Management Division, page 54

1. We note assets under management ("AUM") and Assets under Administration
 ("AUA") increased from $10.9 billion at December 31, 2023 to $11.9
billion at
 December 31, 2024. In future filings, please address the following
points within your
 disclosure:
 Provide a roll forward of your AUM from beginning to ending balances
showing
 inflows, outflows and market appreciation or depreciation for the
periods
 presented within your financial statements.
 Quantify your AUM and AUA balances separately, and to the extent
possible,
 include a breakdown of AUM and the AUM roll forward by investment
product
 or class in order show more meaningful changes in composition and
trends
 impacting AUM.
 Disclose your weighted average fee rates and how they correlate to
movements
 September 10, 2025
Page 2

 within your AUM/AUA and changes in revenue for the periods presented
within
 your financial statements.

Form 8-K filed July 21, 2025
Exhibit 99.1
Non-GAAP Financial Measures Reconciliation, page 18

2. We note that your presentation of tangible equity excluding other
comprehensive loss
 and tangible book value per share excluding other comprehensive loss
represent
 individually tailored accounting measures given that the adjustment to
exclude the
 impact of other comprehensive loss has the effect of changing the
recognition and
 measurement principles required to be applied in accordance with GAAP.
Therefore,
 please remove the presentation of this measure from future filings.
Refer to Question
 100.04 of the Division of Corporation Finance s Compliance &
Disclosure
 Interpretations on Non-GAAP Financial Measures and Rule 100(b) of
Regulation G.
 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Sarmad Makhdoom at 202-551-5776 or Lory Empie at
202-551-3714
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
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 PEAPACK-GLADSTONE FINANCIAL CORPORATION

500 Hills Drive, Suite 300

Bedminster, New Jersey 07921

July 26, 2024

 VIA
EDGAR

 Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

Re:

Peapack-Gladstone Financial Corporation

  

Registration Statement on Form S-3 (Registration No. 333- 280838)

 Request for Acceleration of Effectiveness

 Ladies and Gentlemen:

Peapack-Gladstone Financial Corporation, a New Jersey corporation (the “Company”), hereby requests that the above-referenced
Registration Statement on Form S-3 be declared effective at 4:00 p.m., Eastern time, on July 30, 2024, or as soon thereafter as is practicable.

 Very truly yours,

 /s/ Frank A. Cavallaro

 Frank A. Cavallaro

 Chief Financial Officer

 (Duly Authorized Representative)

July 25, 2024
Douglas L. Kennedy
Chief Executive Officer
Peapack-Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921
Re:Peapack-Gladstone Financial Corporation
Registration Statement on Form S-3
Filed July 16, 2024
File No. 333-280838
Dear Douglas L. Kennedy:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that
the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Aisha Adegbuyi at 202-551-8754 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Scott Brown, Esq.

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    PEAPACK-GLADSTONE FINANCIAL CORPORATION

    500 Hills Drive, Suite 300

    Bedminster, New Jersey 07921

    January 19, 2021

    Via Edgar

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549

    Re:  Peapack-Gladstone Financial Corporation

    Registration Statement on Form S-4 (Registration Number 333-252046)

    Request for Acceleration of Effectiveness

    Ladies and Gentlemen:

    Peapack Gladstone Financial Corporation, a New Jersey corporation (the “Company”), hereby requests that the Company’s Registration
      Statement on Form S-4 be declared effective on January 22, 2021 at 12:00 noon, or as soon thereafter as is practicable.

            Sincerely,

          /s/ Jeffrey J. Carfora

            Jeffrey J. Carfora

            Senior Executive Vice President and Chief Financial Officer

            (Duly Authorized Representative)

United States securities and exchange commission logo
January 15, 2021
Jeffrey J. Carfora
Chief Financial Officer
Peapack-Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921
Re:Peapack-Gladstone Financial Corporation
Registration Statement on Form S-4
Filed January 12, 2021
File No. 333-252046
Dear Mr. Carfora:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie, Legal Branch
Chief, at 202-551-3469 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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CORRESP

 PEAPACK-GLADSTONE FINANCIAL
CORPORATION

 500 Hills Drive, Suite 300

Bedminster, New Jersey 07921

 May 27,
2020

 VIA EDGAR

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
 Peapack-Gladstone Financial Corporation

 Registration Statement on Form S-3 (Registration
No. 333-238267)

 Request for Acceleration of
Effectiveness

 Ladies and Gentlemen:

Peapack-Gladstone Financial Corporation, a New Jersey corporation, hereby requests that the above-referenced Registration Statement on Form S-3 be declared effective at 1:30 p.m., Eastern time, on May 29, 2020, or as soon thereafter as is practicable.

Very truly yours,

/s/ Jeffrey J. Carfora

Jeffrey J. Carfora

Senior Executive Vice President and
Chief Financial Officer

(Duly Authorized Representative)

United States securities and exchange commission logo
May 26, 2020
Douglas Kennedy
Chief Executive Officer
Peapack-Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921
Re:Peapack-Gladstone Financial Corporation
Registration Statement on Form S-3
Filed May 14, 2020
File No. 333-238267
Dear Mr. Kennedy:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please contact Susan Block at 202-551-3210 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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PEAPACK-GLADSTONE FINANCIAL CORPORATION

500 Hills Drive, Suite 300

Bedminster, New Jersey 07921

January 4, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Katelyn Donovan

    Re:
    Peapack-Gladstone Financial Corporation

    Registration Statement on Form S-3

    File No. 333-215176

Dear Ms. Donovan:

I am the Senior Executive
Vice President and Chief Financial Officer of Peapack-Gladstone Financial Corporation, a New Jersey corporation (the “Company”),
and am authorized to request the acceleration of the effective date of the Company’s Registration Statement on Form S-3 filed
on December 19, 2016 (Registration Number 333-215176).

Pursuant to Rule 461
under the Securities Act of 1933, as amended, I hereby request that the Securities and Exchange Commission (the “Commission”)
accelerate the effective date of the Registration Statement so that the Registration Statement may be declared effective on Friday,
January 6, 2017 at 10:00 a.m. Eastern Time, or as soon as possible thereafter.

Please contact our outside counsel, Michael
T. Rave of Day Pitney LLP, at (973) 966-8123, to confirm effectiveness or if you have any questions about this request.

    Very truly yours,

    PEAPACK-GLADSTONE

 FINANCIAL CORPORATION

    By: /s/ Jeffrey J. Carfora

    Jeffrey J. Carfora

    Senior Executive Vice President and

    Chief Financial Officer

Mail Stop 4720
December 23, 2016

Jeffrey J. Carfora
Senior Executive Vice President and Chief Financial Officer
Peapack -Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

Re: Peapack -Gladstone  Financial Corporation
  Registration Statement on Form S-3
Filed  December 19, 2016
  File No.  333-215176

Dear Mr. Carfora :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please  contact Katelyn Donova n, Staff Attorney, at (202) 551 -8636, or me, at
(202) 551 -3369  with any questions.

Sincerely,

 /s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Services
cc: Michael T. Rave, Esq.
 Day Pitney LLP

December 12 , 2012

Via E -mail
Jeffrey J. Carfora
Executive Vice President and
Chief Financial Officer
Peapack -Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

Re: Peapack -Gladstone Financial Corporation
  Form 10 -K for th e Fiscal Year Ended December 31 , 2011
Filed March 15 , 2012
File No. 001-16197

Dear Mr. Carfora :

We have completed our review of your filings.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filings and the company 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.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filings to be certain that the filings include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Sharon Blume

Sharon Blume
Assistant Chief Accountant

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[PGFC Letterhead]

December 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

    Filed March 15, 2012

    File No. 001-16197

Dear Ms. Blume,

We are in receipt of your follow-up
letter dated November 14, 2012, containing additional comments to our letter dated October 26, 2012 responding to your original
comments to the Annual Report on Form 10-K for the year ended December 31, 2011 of Peapack-Gladstone Financial Corporation (the
“Corporation”). Set forth below is our response to the comments in your letter.

SEC Comment:

We have reviewed your response to prior comment one from our letter
dated October 15, 2012. We believe a three to six month delay in timing of the restructured payment period is not insignificant
to the frequency of payments due under the debt. Please revise future filings to update your accounting policy and related disclosures.

Response:

The Company will revise future filings to update accounting policy
and related disclosures as noted.

SEC Comment:

In your response, you state that “while in forbearance period,
although these loans are not classified as nonaccrual, the Bank does not record any income from the loans since payments are not
being received.” Please revise future filings to classify these loans as nonaccrual, as you are not recording any income
on them.

Response:

The Company will revise future filings to consider these loans nonaccrual
when over 90 days past due.

We acknowledge
that (1) the Corporation is responsible for the adequacy and accuracy of the disclosure in our filings with the SEC, (2) Staff
comments or changes to disclosure in response to Staff comments do not foreclose the SEC from taking any action with respect to
any of our filings with the SEC; and (3) the Corporation may not assert Staff comments as a defense in any proceeding initiated
by the SEC or any person under the federal securities laws of the United States.

My direct
phone number is 908-719-4308. If you cannot reach me, you can speak to our Comptroller, Mary Russell, at 908-719-4309.

    Sincerely,

    /s/ Jeffrey J. Carfora

    Jeffrey J. Carfora

    Executive Vice President,

    Chief Financial Officer and

    Chief Accounting Officer

CORRESP
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[PEAPACK-GLADSTONE
FINANCIAL CORP. LETTERHEAD]

November 20, 2012

Sharon Blume

Assistant Chief Accountant

U.S. Securities and Exchange Commission

Washington, DC 20549

Via EDGAR (Correspondence)

Dear Ms. Blume,

We are in receipt of your comment letter dated
November 14, 2012. In order to provide a complete and accurate response, given the upcoming holiday, as well as vacations, additional
time beyond ten business days is needed. In addition to the time needed to prepare the response, we would like to have the response
reviewed by several outside parties, including our accountants and counsel. Accordingly, we plan on providing our response to the
Commission on or before December 10, 2012.

Please contact me at 908-719-4308 or Mary Russell,
Comptroller at 908-719-4309, if you have any questions.

Sincerely,

/s/ Jeffrey J. Carfora

Jeffrey J. Carfora

EVP and Chief Financial Officer

cc: William Schroeder, Staff Accountant

November 14 , 2012

Via E -mail
Jeffrey J. Carfora
Executive Vice President and
Chief Financial Officer
Peapack -Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

Re: Peapack -Gladstone Financial Corporation
  Form 10 -K for th e Fiscal Year Ended December 31 , 2011
Filed March 15 , 2012
File No. 001 -16197

Dear Mr. Carfora :

We have reviewed your filing  and have the following comment s.  In some of our
comment s, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   Where we have requested changes in future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosures.   If you do not belie ve our
comment s apply  to your facts and circumstances or do not believe an amendment  is appropriate,
please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  commen ts, including the draft of your proposed disclosures, we may have
additional comments.

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

Exhibit 13

1. Summary of Significant Accounting Policies

Loans, page 48

1. We have reviewed your response to prior comment one from our letter dated October 15,
2012.  We believe a three to six month delay in timing of the restructured payment period

Jeffrey J. Carfora
Peapack -Gladstone Financial Corporation
November 14 , 2012
Page 2

 is not insignificant to the frequency of payments due under the debt.  Please re vise future
filings to update your accounting policy and related disclosures.

2. In your response, you state that “while  in forbearance period, although these loans are not
classified as nonaccrual, the Bank does not record any income from the loans since
payments are not being received.”  Please revise future filings to classify the se loans as
nonaccrual , as you are not recording any income on them.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be  certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsib le for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment s, please provide  a written statement from the company
acknowledging that:

 the company 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 company 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.

You may contact William Schroeder , Staff Accountant, at (202) 551 -3294 or  me at (202)
551-3474  if you have questions regarding our comment s on the financial statements and related
matters .

Sincerely,

 /s/ Sharon M. Blume

Sharon M. Blume
Assistant Chief Accountant

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[PEAPACK-GLADSTONE FINANCIAL CORP. LETTERHEAD]

October 26, 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

Form 10-Q for the Quarterly Period Ended June 30, 2012

File No. 001-16197

Dear Ms. Blume,

We are in receipt of your follow-up
letter dated October 15, 2012, containing additional comments to our letter dated September 10, 2012 responding to your original
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 the comments in your letter.

SEC Comment:

We have reviewed your response to prior comment five from our letter
dated August 7, 2012. In your response you state that modifications of residential mortgage loans for which a borrower is experiencing
a temporary hardship may include a deferment of up to six months of loan payments which, in Management’s judgment, does not
reflect a significant delay, given that these loans typically have original maturities of 15 to 30 years. Please provide us with
the following as it relates to these short-term loan modifications:

 · Discuss the types of temporary hardships experienced by these borrowers;

 · Quantify the amounts of loans that have been modified using this type of workout strategy each period presented. Clarify whether
these short-term modifications are only made on mortgage loans or various types of loans;

 · Provide additional analysis supporting your conclusion that these short-term modifications should not be classified as troubled
debt restructurings;

 · Tell us how the loans are classified (performing vs. non-performing) and whether they continue to accrue interest;
                                                                                                                                                                                                                           and

 · Describe whether these loans are included in your ASC 450-20 or ASC 310-10 impairment analysis.

Response:

The Company has applied the following guidance to determine insignificant
delays: ASC 310-40-15-17 states the following:

The following factors, when considered together, may indicate that
a restructuring results in a delay in payment that is insignificant:

 a. The amount of the restructured payments subject to the delay is insignificant relative to the unpaid principal or collateral
value of the debt and will result in an insignificant shortfall in the contractual amount due.

 b. The delay in timing of the restructured payment period is insignificant relative to any one of the following:

 1. The frequency of payments due under the debt

 2. The debt’s original contractual maturity

 3. The debt’s original expected duration

Pursuant to the above literature and to respond to the questions,
we note the following:

Temporary hardships experienced by borrowers associated with modifications
of residential mortgage loans that include a deferment of loan payments for up to six months have been generally caused by temporary
unemployment and related loss of income. These type of short term modifications (forbearances) have only been done for residential
first mortgage loans.

When residential first mortgage loan borrowers are granted deferral
periods, the deferred payments are added to the back end of the loan, thereby extending the maturity by the number of deferred
payments. Therefore, there have been no principal concessions granted. The average forbearance period for these loans is between
three to six months, and the average remaining life of these loans is generally in excess of 300 months. Therefore, on average,
the forbearance period is a very small or insignificant percentage of the remaining life of the loan and the overall cash flows
on the loan. When this insignificant period (six months or less) relative to the overall maturity of the loan is combined with
past payment performance, no previous forbearances that would put the combined total forbearance period in excess of six months,
and a full expectation the loan will return to the contractual payment status within six months, these loans are not considered
TDRs. While in the forbearance period, although these loans are not classified as nonaccrual, the Bank does not record any income
from the loans since payments are not being received.

During the year ended December 31, 2011, 13 residential first mortgage
loan borrowers were granted a payment deferral up to six months due to temporary hardships being experienced by the borrowers.
Three of these forbearances were still in effect as of December 31, 2011. Two of the 13 loans were categorized as TDRs because
they had also been granted a deferral period in a prior year and the cumulative amount of deferral period was greater than six
months. The aggregate amount of the other 11 loans that were not considered TDRs was $3.5 million. Of the $3.5 million, two residential
loans totaling $1.1 million paid off prior to year end, leaving $2.4 million of modified residential loans not considered TDRs.

During the quarter ending March 31, 2012, one residential first
mortgage loan borrower with a principal balance of $61,000 was granted three months forbearance.

During the quarter ending June 30, 2012, six residential first mortgage
loans totaling $1.2 million were granted payment deferrals up to six months. Two of the loans totaling $263 thousand had been granted
forbearances in prior periods bringing the total overall forbearance period to greater than six months, and, because the cumulative
period for each was greater than six months, were categorized as TDRs.

When loans are granted a forbearance period, the Bank reflects them
as criticized assets and includes them with other Special Mention loans in its ALLL methodology when calculating the level of general
(pooled) reserves (ASC 450-20). Special Mention loans carry a higher level of reserves than pass-grade loans. Any loan that is
categorized as a TDR is considered a substandard classified asset and undergoes impairment analysis to determine an appropriate
specific reserve (if it is performing) or partial charge off (if nonperforming) under ASC 310-10. If a loan which has been granted
a forbearance period demonstrates a satisfactory payment record, generally a minimum of six months, then the Bank may remove it
from the Special Mention loans and designate it as a pass-grade loan.

We acknowledge
that (1) the Corporation is responsible for the adequacy and accuracy of the disclosure in our filings with the SEC, (2) Staff
comments or changes to disclosure in response to Staff comments do not foreclose the SEC from taking any action with respect to
any of our filings with the SEC; and (3) the Corporation may not assert Staff comments as a defense in any proceeding initiated
by the SEC or any person under the federal securities laws of the United States.

My direct
phone number is 908-719-4308. If you cannot reach me, you can speak to our Comptroller, Mary Russell, at 908-719-4309.

    Sincerely,

    /s/ Jeffrey J. Carfora

    Jeffrey J. Carfora

    Executive Vice President,

    Chief Financial Officer and

    Chief Accounting Officer

October 15 , 2012

Via E -mail
Jeffrey J. Carfora
Executive Vice President and
Chief Financial Officer
Peapack -Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

Re: Peapack -Gladstone Financial Corporation
  Form 10 -K for th e Fiscal Year Ended December 31 , 2011
Filed March 15 , 2012
Form 10 -Q for the Quarterly Period Ended March 31, 2012
Filed May 9 , 2012
Form 10 -Q for the Quarterly Period Ended June 30, 2012
Filed August 9, 2012
File No. 001-16197

Dear Mr. Carfora :

We have reviewed your response letter dated September 10, 2012 and have the following
comment.   In our comment , we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this le tter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
belie ve our comment  applies  to your facts and circumstances , please tell us why in your
response.

After reviewing any information you provide in response to this  comment , we may have
additional comments.

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

Exhibit 1 3
1. Summary of Significant Accounting Policies
Loans, page 48

1. We have reviewed your response to prior comment five from our letter dated August 7,
2012.  In your response you state that modifications of residential mortgage loans for
which a borrower i s experiencing a temporary hardship may include a deferment of up to
six months of loan payments which, in Management’s judgment, does not reflect a

Jeffrey J. Carfora
Peapack -Gladstone Financial Corporation
October 15 , 2012
Page 2

 significant delay, given that these loans typically have original maturities of 15 to 30
years.  Please pro vide us with the following as it relates to these short -term loan
modifications:

 Discuss  the types of temporary hardships experienced by these borrowers;
 Quantify the amounts  of loans that have been modified using this type of workout
strategy in each period presented.   Clarify whether these short -term modifications
are only made on mortgage loans or various types of loans;
 Provide additional analysis supporting your conclusio n that these short -term
modifications should not be classified as troubled debt restructurings;
 Tell us how the loans are classified (performing vs. non -performing) and whether
they continue to accrue interest; and
 Describe whether these loans are include d in your ASC 450 -20 or ASC 310 -10
impairment analysis.

You may contact William Schroeder , Staff Accountant, at (202) 551 -3294 or  me at (202)
551-3474  if you have questions regarding our comment  on the financial statements and related
matters .

Sincerely,

 /s/ Sharon Blume

Sharon Blume
Assistant Chief Accountant

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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%

    United States Securities &
Exchange Commission
September 10, 2012

Page 2

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

    United States Securities &
Exchange Commission
September 10, 2012

Page 3

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.

    United States Securities &
Exchange Commission
September 10, 2012

Page 4

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

    United States Securities &
Exchange Commission
September 10, 2012

Page 5

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.

    United States Securities &
Exchange Commission
September 10, 2012

Page 6

 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

CORRESP
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[PEAPACK-GLADSTONE
FINANCIAL CORP. LETTERHEAD]

August 9, 2012

Sharon Blume

Assistant Chief Accountant

U.S. Securities and Exchange Commission

Washington, DC 20549

Via EDGAR (Correspondence)

Dear Ms. Blume,

We are in receipt of your comment letter dated
August 7, 2012. In order to provide a complete and accurate response, additional time beyond ten business days is needed. In addition
to the time needed to prepare the response, we would like to have the response reviewed by several outside parties, including our
accountants and counsel. Accordingly, we plan on providing our response to the Commission on or before September 10, 2012.

Please contact me at 908-719-4308 or Mary Russell,
Comptroller at 908-719-4309, if you have any questions.

Sincerely,

/s/ Jeffrey J. Carfora

Jeffrey J. Carfora

EVP and Chief Financial Officer

cc: William Schroeder, Staff Accountant

August 7 , 2012

Via E -mail
Jeffrey J. Carfora
Executive Vice President and
Chief Financial Officer
Peapack -Gladstone Financial Corporation
500 Hills Drive, Suite 300
Bedminster, NJ 07921

Re: Peapack -Gladstone Financial Corporation
  Form 10 -K for th e Fiscal Year Ended December 31 , 2011
Filed March 15 , 2012
Form 10 -Q for the Quarterly Period Ended March 31, 2012
Filed May 9 , 2012
File No. 001-16197

Dear Mr. Carfora :

We have reviewed your filing s and have the following comment s.  In our comment s, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providin g the requested information, or by advising us when you will provide the requested
response.   Where we have requested changes in future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosures.   If you  do not belie ve our
comment s apply  to your facts and circumstances or do not believe an amendment  is appropriate,
please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comment s, including the draft of your proposed disclosures, we may have
additional comments.

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

Exhibit 13

Managemen t’s Discussion and Analysis of  F inancial Condition and Results of Operations

Loan s, page 16

1. 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

Jeffrey J. Carfora
Peapack -Gladstone Financial Corporation
August 7, 2012
Page 2

 the loan portfolio.  However, we are unable to locate a complete discu ssion 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 de ciding 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.

Notes to Consolidated Financial Statements

1. Summary of Significant Accounting Policies

Loans, page 48

2. 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.

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

 All the 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 rep ayment under th e revised terms;
 For your troubled debt restructurings that accrue interest at the time the loan is
restructured, whether you have charged -off any portion of the loan.  If you have,
explain  how you concluded that repayment of interest and principal contrac tually due
on the enti re debt is reasonably assured;
 How you determine whether the borrower has demonstrated repayment performance
with modified terms.  Specifically , disclose h ow many payments the borrower needs
to make before retu rning a loan to accrual status; and
 Describe any conditions that would cause you to remove a loan from TDR status .

4. Please revise future filings to disclose your  policy for recording payments received on
nonaccrual financing receivables . Refer to ASC 310-10-50-6 (b).

Jeffrey J. Carfora
Peapack -Gladstone Financial Corporation
August 7, 2012
Page 3

 5. We note yo ur disclosure on page 67 regarding certain loans modified that did not meet
the definition of a troubled debt restructuring.  Please tell us and revise future filings to
disclose how you determine a delay in payment is insignificant.

New Accounting Polici es, page 52

6. We note your reference to accounting guidance on comprehensive income issued in June
2011 but not yet adopted.  We also note that other accounting guidance, for example
ASU 2011 -04 Fair Value Measurement (Topic 820) , was issued in 2011 .  Pleas e confirm
that there was no other guidance  issued but not yet adopted whose impact on your
financial position and results of operations was expected to be material  at December 31,
2011 and revise your future filings if necessary .  Refer to ASC 250 -10-S99-5.

4. Loans, page 58

7. Please revise future filings to describe the risk characteristics of each loan portfolio
segment.  Refer to ASC 310 -10-50-11B (a) (2).

9. Fair Value, page 71

8. Please revise your future filings to disclose how often you obtain updated  appraisals for
your impaired collateral dependent loans and if this policy varies by loan type.  Describe
in more detail the types of adjustments you make to appraised values, including those
made as a result of outdated appraisals.  Discuss how you consi der the potential for
outdated appraisal values in your determination of the allowance for loan losses.  Also,
quantify the amount of collateral dependent loans for which you are using an appraisal
performed within the past 12 months to serve as the primar y basis of your valuation.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rul es require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment s, please provide  a written statement from the company
acknowledging that:

 the company 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 tak ing any action with respect to the filing; and

Jeffrey J. Carfora
Peapack -Gladstone Financial Corporation
August 7, 2012
Page 4

  the company 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.

You may contact William Schroeder , Staff Accountant, at (202) 551 -3294 or  Sharon Blume,
Assistant Chief Accountant , at (202) 551 -3474  if you have questions regarding our comment s on
the financial statements and related matters .

Sincerely,

 /s/ Sharon Blume

Sharon Blume
Assistant Chief Accountant

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

DIVISION OF
  CORPORATION FINANCE

Mail Stop 4720
December 9, 2009

By U.S. Mail and facsimile to (908) 781-2046
Mr. Jeffrey Carfora Chief Financial Officer  Peakack-Gladstone Financial Corp.  158 Route 206 North  Gladstone, New Jersey 07934
Re: Peapack-Gladstone Financial Corp.
  Form 10-K for the Fiscal Year December 31, 2008
  File No. 001-16197

Dear Mr. Carfora:

We have completed our review of your Form 10-K and related filings and have no
further comments at this time.

        S i n c e r e l y ,          A m i t  P a n d e         Accounting Branch Chief

June 24, 2009
  Jeffrey Carfora Chief Financial Officer Peapack-Gladstone Financial Corp. 158 Route 206 Gladstone, New Jersey  07934
Re: Peapack-Gladstone Financial Corp.
       Form 10-K for December 31, 2008        File Number 1-16197
Dear Mr. Carfora:

We have reviewed the above referenced filing and related materials and have the
following comments.  Where indicated, we thi nk your documents should be revised.  If you
disagree, we will consider your explanation as to why our comments are inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In your response, please indicate your intent to include the requested revision in future filings and provide a draft of your proposed disclosure.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may have additional comments.              The purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Peapack-Gladstone Financial Corp.
June 24, 2009 Page 2

Form 10-K for the period ended December 31, 2008

Signatures, page 23

1. This report must be signed by the company’s chief accounting office.  If one of the
people signing this report is that person, please advise us supplementally.  In future reports, the person signing as the chief accounting officer should be so identified.
 Managements Discussion and Analysis   page 2

 2. We note that your management discussion and analysis does not contain a discussion of your holdings of subprime loans nor any discu ssion of “Alt-A” type mortgages.  If you
do not hold or have not made or invested in these types of loans, please so note in future filings.  If your holdings are other than inconsequential, please disclose and discuss in future filings.
 3. In the penultimate paragraph on page 2 you mention that much of the impairment charge was for the corporation’s trust preferred pooled securities.  In future reports please augment this discussion so that the reader has a better understanding of these securities.
 Financial Statements

 Note 2, Investment Securities Held to Maturity, page 42

 4. We note the summary of investment securities held to maturity includes an “Other Securities” line item for $11.5 million, equal to 22% of total securities held as of December 31, 2008.  Considering the relatively inactive trading market for these securities, please tell us and in future filings discuss in MD&A any recent economic trends or other factors that could trigger an other-than-temporary impairment and its expected effect on future operations, cash flow and liquidity.
 5. We refer to the $55.3 million other-than-temporary impairment charge recorded in 2008 related to the trust preferred portfolio with a cost of $67.1 million and to related discussion in the “Other Income” section of Management’s Discussion and Analysis on page 15 of Exhibit 13.  Please tell us and describe in future filings how the $55.3 million impairment charge was determined.  Consider in your response your disclosure in Note 3, “Investment Securities Held to Maturity” on page 10 of your September 30, 2008 10-Q which states that gross unrealized losses for “Other Securities” with a carrying amount of $48.4 million was $29.4 million.

Peapack-Gladstone Financial Corp.
June 24, 2009 Page 3
 6. Please tell us and discuss in future filings what specific events occurred between the filing date your September 30, 2008 10-Q and December 31, 2008 which resulted in the fourth quarter $55.3 million other-than-temporar y impairment charge.  Consider in your
response the disclosure in Note 3 on page 11 of the September 30, 2008 10-Q states the following:

• Management expected all these securities to return 100% of all their principal and interest.

• The estimated fair value of these securities was $19.0 million with an original cost of
$67.1 million.

• The Company had senior and mezzanine tranche in the trust preferred securities
which were protected from defaults by over-collateralization and cash flow default protection provided by subordinated tranches.
 Note 3, Securities Available For Sale, page 44

 7. We refer to the “Other Securities” line item for $4.3 million that has gross unrealized losses of $1.2 million, equal to 21% of total gross unrealized losses of $5.7 million and 71% of unrealized losses twelve months or longer as of December 31, 2008.   Please tell us and in future filings provide the following additional disclosure:

• Describe the nature of these securities and their credit risk characteristics including any contractual conditions that provide protection against defaults.

• State the reasons why these unrealized losses on these securities were considered
other-than-temporary as of December 31, 2008.

• Discuss in MD&A any recent market trends that could result in the recognition of
other-than-temporary impairments and their expected maximum effect on future operations, cash flow and liquidity.
 Note 9, Fair Value of Financial Instruments, page 49

 8. We refer to the table on page 50 that describes assets measured on a non-recurring basis which shows held-to-maturity securities valued using Level 3 inputs. Please tell us and in future filings include, for fair value measurements using Level 3 inputs, the reconciliation showing changes due to realized and unrealized and gains and loses  as required by

Peapack-Gladstone Financial Corp.
June 24, 2009 Page 4
paragraphs 32(c) and 32(d) of SFAS 157.  Refe r to sample disclosure in paragraph A35
of SFAS 157.
9. We refer to the methodology discussed on page 50 to determine the fair value of the trust preferred securities using discounted cash flow analysis.  Please tell us and in future filings provide the following information:

• Tell us how the Company determined the validity and appropriateness of the various assumptions and input data used that were considered indicators of the collateral likely to default in future periods.

• Discuss any procedures to periodically update the assumptions and input data based
on changes in the financial credit market that can affect the fair value of the underlying collateral

• Tell us the factual basis for assuming constant and not variable probable rates of
default in excess of those based on historical performance was a valid assumption in the currently volatile financial credit market.
 10. We refer to the statement on page 50 that in prior periods the Company used a constant rate of default derived from the historical performance of the underlying collateral and during the fourth quarter of 2008 employed “the methodology described in the preceding
paragraph” to assess other-than-temporary impairments of fair value. Taking into consideration that the preceding paragraph also referred to the use of a constant rate of default, please tell us and discuss in future filing the following:

• Describe the specific differences between the methodology previously used and that adopted during the fourth quarter of 2008.

• Explain why the change in valuation methodology employed during the fourth quarter
of 2008 is preferable to that previously used.

• Provide us with a summary comparing the differences between both valuation
methodologies and how the change has affected the valuation of the trust preferred securities.
     Note 16, Business Segments, page 60

Peapack-Gladstone Financial Corp.
June 24, 2009 Page 5

11. We note the Company has adopted separate segment disclosure for the Banking and PGB
Trust & Investments operations.  In future filings please include in Management’s Discussion and Analysis a discussion of the results of operations and liquidity of your operating segments.  Refer to Item 303(A) of Regulation S-K.

   *  *  *  *  *

 Please respond to this comment within 10 business days or tell us when you will provide
us with a response.  Your response letter should key your responses to our comments, indicate
your intent to include the requested revision in future filings, provide a draft of your proposed
disclosure and provide any requested information.  We may have additional comments after reviewing your response.    We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.     In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
‚ the company 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 company 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.

Peapack-Gladstone Financial Corp.
June 24, 2009 Page 6
In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.
Please direct any questions on accounting ma tters to Edwin Adames at 202-551-3447, or
to Amit Pande, Accounting Branch Chief, at 202- 551-3423.  Please direct any other questions to
David Lyon at 202-551-3421, or to me at 202-551-3418.

Sincerely,

William C-L Friar Senior Financial Analyst
             By FAX to: Jeffrey Carfora                    908-781-2046

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    corresp-102426_pgfc.htm

August 10, 2009

VIA EDGAR/US MAIL/FACSIMILE

United States Securities & Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-5546

Attention: William C-L Friar, Senior Financial Analyst

Re:

Peapack-Gladstone Financial Corp.

Form 10-K for the Fiscal Year Ended December 31, 2008

File No. 0-23537

Dear Mr. Friar:

We are in receipt of your letter dated June 24, 2009 containing comments to the Annual Report on Form 10-K for the year ended December 31, 2008 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:  This report must be signed by the company’s chief accounting officer.  If one of the people signing this report is that person, please advise us supplementally.  In future reports, the person signing as the chief accounting officer should be so identified.

Response:  Arthur F. Birmingham, the chief financial officer at December 31, 2008 was also the Corporation’s chief accounting officer.  Mr. Birmingham has since retired.  In future reports, our current chief financial
officer, Jeffrey J. Carfora, will also be identified as the chief accounting officer.

2.

SEC Comment:  We note that your management discussion and analysis does not contain a discussion of your holdings of subprime loans nor any discussion of “Alt-A” type mortgages.  If you do not hold or have not made or invested in these types of
loans, please so note in future filings.  If your holdings are other than inconsequential, please disclose and discuss in future filings.

Response:  We do not hold, have not made nor invested in subprime loans or “Alt-A” type mortgages.  We had noted this in previous filings, but did not in the Form 10-K for the year ended December 31, 2008.  We will
indicate that we have no such holdings in future filings.

United States Securities &

Exchange Commission

August 10, 2009

Page 2

3.

SEC Comment:  In the penultimate paragraph on page 2 you mention that much of the impairment charge was for the Corporation’s trust preferred pooled securities.  In future reports please augment this discussion so that the reader has a better understanding of these securities.

Response:  We will incorporate additional discussion in future filings.

4.

SEC Comment:  We note the summary of investment securities held to maturity includes an “Other Securities” line item for $11.5 million, equal to 22% of total securities held as of December 31, 2008.  Considering the relatively inactive trading market for these securities, please tell us and in future
filings discuss in MD&A any recent economic trends or other factors that could trigger an other-than temporary impairment and its expected effect on future operations, cash flow and liquidity.

Response:  The $11.5 million is the total remaining balance of the Corporation’s trust preferred pooled securities portfolio, which is discussed in Management’s Discussion and Analysis and the Notes to Consolidated Financial Statements,
particularly Note 9.  The Corporation has already recorded a substantial write-down of its Trust Preferred Pooled Securities Portfolio. The carrying value of $11.5 million at December 31, 2008 represents approximately 17% of previous carrying value. However, further significant downturns in the real estate markets and/or the economy could cause additional banks/companies to defer paying dividends on these securities and/or ultimately default. Such occurrences, if beyond those assumed in our current
valuation, could cause an additional write-down of the portfolio, with a negative impact on earnings. We believe, however, that such an additional write-down, if necessitated, would not have a material effect on our cash flow or liquidity position. We will incorporate such discussion in future filings.

5.

SEC Comment:  We refer to the $55.3 million other-than-temporary impairment charge recorded in 2008 related to the trust preferred portfolio with a cost of $67.1 million and to related discussion in the “Other Income” section of Management’s Discussion and Analysis on page 15 of Exhibit 13.  Please
tell us and describe in future filings how the $55.3 million impairment charge was determined. Consider in your response your disclosure in Note 3, “Investment Securities Held to Maturity” on page 10 of your September 30, 2008 10-Q which states that gross unrealized losses for “Other Securities” with a carrying amount of $48.4 million was $29.4 million.

Response:  The trust preferred securities had been originally held in the available for sale portfolio at a carrying amount of $67.1 million.  As of July 1, 2008, management changed the accounting treatment for the portfolio from available
for sale to held to maturity.  As of that date, the fair value of $48.4 million became the new book value with the decline, net of tax, of $11.2 million recorded as a component of accumulated other comprehensive income to be amortized into income over the remaining lives of the

United States Securities &

Exchange Commission

August 10, 2009

Page 3

securities.  The December 31, 2008 impairment charge was calculated on the original carrying amount of $67.1 million.

We believe the description contained in Note 9 to the Consolidated Financial Statements provides an adequate description of how the $55.3 million impairment charge was determined.  The trust preferred pooled securities are collateralized by trust preferred securities issued primarily by individual banks, but also by insurance
companies and real estate investment trusts.  To determine fair value, and determine whether the securities were other than temporarily impaired, the Corporation retained and worked with a third party to review the issuers (the collateral) underlying each of the securities.  Among the factors analyzed were the issuers’ profitability, credit quality, asset mix, capital adequacy, leverage and liquidity position, as well as an overall assessment of credit, profitability and capital trends
within the portfolio’s issuer universe.  These factors provided an assessment of the portion of the collateral of each security which was likely to default in future periods.  The cash flows associated with the collateral likely to default, together with the cash flows associated with collateral which had already deferred or defaulted, were then eliminated.  In addition, the Corporation assumed constant rates of default in excess of those based upon the historic performance
of the underlying collateral.  The resulting cash flows were then discounted to the current period to determine fair value for each security. The discount rate utilized was based on a risk free rate (LIBOR) plus spreads appropriate for the product, which include consideration of liquidity and credit uncertainty. Such description of the discount rate will be incorporated in future filings, as appropriate.

In periods prior to the fourth quarter of 2008, the Corporation used a constant rate of default derived from the historic performance of the underlying collateral to assess other-than-temporary impairment.  However, during the fourth quarter of 2008, after the filing of our September 30, 2008 Form 10-Q, a significant portion
of the Corporation’s trust preferred pooled securities were downgraded from investment grade to below investment grade; as a result, in the fourth quarter of 2008 the Corporation chose to employ the valuation methodology set forth in the preceding paragraph to assess fair value and other-than-temporary impairment with respect to the pooled trust preferred securities. Please see our response to your comment # 6 on the next page for more specific details concerning the timing of the downgrades.

6.

SEC Comment:  Please tell us and discuss in future filings what specific events occurred between the filing date of your September 30, 2008 10-Q and December 31, 2008 which resulted in the fourth quarter $55.3 million other-than-temporary impairment charge. Consider in your response the disclosure in, Note 3 on page 11 of
the September 30, 2008 10-Q states the following:

United States Securities &

Exchange Commission

August 10, 2009

Page 4

§

Management expected all these securities to return 100% of all their principal and interest.

§

The estimated fair value of these securities was $19.0 million with an original cost of $67.1 million.

§

The Company had senior and mezzanine tranche in the trust preferred securities which were protected from defaults by over-collateralization and cash flow default protection provided by subordinated tranches.

Response:  As of November 7, 2008, when we filed the September 30, 2008 Form 10-Q, Management expected the securities to return 100% of their principal and interest.  At that time, over 91% of the Corporation’s trust preferred
pooled securities still carried investment grade ratings. As noted in a December 30, 2008 Press Release and Form 8-K, it was not until November 12, 2008 that Moody’s downgraded 180 tranches of 44 trust preferred pooled securities including many of the securities held by the Corporation. Additionally, Moody’s placed most of the Corporation’s remaining investment grade trust preferred pooled securities on credit watch for possible future downgrade.  The market value of these securities
continued to sharply decline during the quarter as the liquidity in the debt markets dropped to unprecedented levels and we did not believe the market values would recover within the foreseeable future.  The number of notices of deferral and default by the underlying institutions accelerated during this period.

7.

SEC Comment:  We refer to the “Other Securities” line item for $4.3 million that has gross unrealized losses of $l.2 million, equal to 21% of total gross unrealized losses of $5.7 million and 71% of unrealized losses twelve months or longer as of December 31, 2008. Please tell us and in future filings provide
the following additional disclosure:

§

Describe the nature of these securities and their credit risk characteristics including any contractual conditions that provide protection against defaults.

§

State the reasons why these unrealized losses on these securities were considered other-than-temporary as of December 31, 2008.

§

Discuss in MD&A any recent market trends that could result in the recognition of other-than-temporary impairments and their expected maximum effect on future operations, cash flow and liquidity.

Response:  Other securities include three corporate bonds that total $4.3 million.  The Corporation recognized an other-than-temporary impairment charge of $680 thousand on one of them at December 31, 2008.  The $1.2 million
unrealized loss is related to one of the bonds, a trust preferred security, which was originally issued by MBNA, which subsequently merged with Bank of America (“BAC”).  The turmoil in the financial

United States Securities &

Exchange Commission

August 10, 2009

Page 5

markets and the merger with Merrill Lynch had resulted in sharp declines in all the securities of BAC.  The bond, however, continued to be rated investment grade by Moody’s, with an A2 rating at December 31, 2008.  Currently, the bond continues to be rated investment grade by Moody’s.

Other factors considered before determining not to recognize impairment were:

1.

BAC approximate capital level was $177 billion at December 31, 2008 and received an additional $10 billion in January 2009 for a total of $187 billion.

2.

All BAC debt is senior to capital, including current TARP capital of $45 billion.

3.

The U.S. Government has agreed to absorb 90% of the Merrill Lynch losses after BAC realizes the initial $10 billion.

4.

Credit losses are predicted to level off in late 2009 or early 2010.

5.

Floating rate issues (such as this bond) have been hit the hardest in the market due to the historically low LIBOR rates.

We concluded that BAC’s capital and the support of the U.S. Government in the form of TARP are positive factors.  BAC recently declared dividends on all of the preferred stock issues, which are junior to all debt issues.  Their capital and liquidity levels appear to remain strong.

Additionally, at June 30, 2009, the market value of this bond has improved relative to its March 31, 2009 value, and we continue to determine that this bond is not other-than-temporarily impaired.

We will incorporate an abbreviated version of such discussion in future filings.

8.

SEC Comment:  We refer to the table on page 50 that describes assets measured on a non-recurring basis which shows held-to-maturity securities valued using Level 3 inputs. Please tell us and in future filings include, for fair value measurements using Level 3 inputs, the reconciliation showing changes due to realized and
unrealized and gains and losses as required by paragraphs 32(c) and 32(d) of SFAS 157.  Refer to sample disclosure in paragraph A35 of SFAS 157.

Response:  We note that paragraph 32 refers to assets measured on a recurring basis.  We believe that we have complied with SFAS 157 for the initial recognition of assets measured on a non-recurring basis.

9.

SEC Comment:  We refer to the methodology discussed on page 50 to determine the fair value of the trust preferred securities using discounted cash flow analysis.  Please tell us and in future filings provide the following information:

United States Securities &

Exchange Commission

August 10, 2009

Page 6

§

Tell us how the Company determined the validity and appropriateness of the various assumptions and input data used that were considered indicators of the collateral likely to default in future periods.

§

Discuss any procedures to periodically update the assumptions and input data based on changes in the financial credit market that can affect the fair value of the underlying collateral.

§

Tell us the factual basis for assuming constant and not variable probable rates of default in excess of those based on historical performance was a valid assumption in the currently volatile financial credit market.

Response:  We believe the description contained in Note 9 of the Annual Report on Form 10-K provides an adequate description of how the $55.3 million impairment charge was determined.  The trust preferred pooled securities are collateralized
by trust preferred securities issued primarily by individual banks, but also by insurance companies and real estate investment trusts.  To determine fair value, and determine whether the securities were other than temporarily impaired, the Corporation retained and worked with a third party to review the issuers (the collateral) underlying each of the securities.  Among the factors analyzed were the issuers’ profitability, credit quality, asset mix, capital adequacy, leverage and liquidity
position, as well as an overall assessment of credit, profitability and capital trends within the portfolio’s issuer universe.  These factors provided an assessment of the portion of the collateral of each security which was likely to default in future periods.  The cash flows associated with the collateral likely to default, together with the cash flows associated with collateral which had already deferred or defaulted, were then eliminated.  In addition, the Corporation assumed
constant rates of default in excess of those based upon the historic performance of the underlying collateral.  The resulting cash flows were then discounted to the current period to determine fair value for each security. The discount rate utilized was based on a risk free rate (LIBOR) plus spreads appropriate for the product, which includes consideration of liquidity and credit uncertainty.

To periodically assess the credit assumptions and related input data that could affect the fair value of each security, each quarter we compare actual deferrals and defaults to the assumed deferrals a

CORRESP
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    corresp-101942_pgfc.htm

July 21, 2009

William C. L. Friar

Senior Financial Analyst

US Securities and Exchange Commission

Washington DC, 20549

Via EDGAR (Correspondence)

Dear Mr. Friar,

With regard to your comment letter dated June 24, 2009, we filed correspondence via EDGAR on June 26, 2009, indicating that we planned on providing our response to the Commission on or before July 22, 2009. At this point, we realize that in order to provide a complete and accurate response, additional time beyond this
time period is needed. Given the time of the year, we are in the midst of our quarter end work, including adoption of the new FSP’s issued in April 2009 and preparation of our 10-Q filing. Additionally, we would like to have the response reviewed prior to submission by several outside parties, including our accountants and counsel. Accordingly, and as I discussed with Mr. Lyon, we now plan on providing our response to the Commission on or before August 12, 2009.

Please note that we are not operating under directives from our primary regulator, including memorandums of understanding. Additionally, during the June quarter, there have been no adverse changes in our assumptions supporting our past impairment charges and no additional impairment charges have been recorded. Further,
there have been no material events in the June quarter that would adversely affect our financial condition.

Please contact me at 908-719-4308 or Mary Russell, Comptroller at 908-719-4309, if you have any questions.

Sincerely,

/s/ Jeffrey J. Carfora

Jeffrey J. Carfora

EVP and Chief Financial Officer

CORRESP
1
filename1.htm

    corresp-101690_pgfc.htm

    June 26,
2009

    William
C. L. Friar

    Senior
Financial Analyst

    US
Securities and Exchange Commission

    Washington
DC, 20549

    Via EDGAR
(Correspondence)

    Dear Mr.
Friar,

    We are in
receipt of your comment letter dated June 24, 2009. In order to provide a
complete and accurate response, additional time beyond ten business days is
needed. Given the time of the year, our quarter end work begins in a few days.
Additionally, we would like to have the response reviewed by several outside
parties, including our accountants and counsel, and, due to the time of the
year, that process will likely take longer than otherwise. Accordingly, we plan
on providing our response to the Commission on or before July 22,
2009.

    Please
contact me at 908-719-4308 or Mary Russell, Comptroller at 908-719-4309, if you
have any questions.

    Sincerely,

    /s/
Jeffrey J. Carfora

    Jeffrey
J. Carfora

    EVP and
Chief Financial Officer

Mail Stop 4561

May 10, 2007

Mr. Arthur F. Birmingham
Executive Vice President and Chief Financial Officer
Peapack-Gladstone Financial Corporation
158 Route 206
Peapack-Gladstone, NJ 07934

Re: Peapack-Gladstone Financial Corporation
  Form 10-K for the Fiscal Year Ended December 31, 2006
  Filed March 16, 2007
  File No. 001-16197

Dear Mr. Birmingham:

We have completed our review of your Form 10-K and related filings and have no
further comments at this time.

Sincerely,

John P. Nolan
Accounting Branch Chief

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                         [PEAPACK-GLADSTONE LETTERHEAD]

                                                                     May 1, 2007

VIA EDGAR AND DHL

John P. Nolan - Accounting Branch Chief
United States Securities and Exchange Commission
Division of Corporation Finance - Mail Stop 4561
100 F Street, N.E.
Washington, DC 20549

                  Re:      Peapack-Gladstone Financial Corporation
                           Form 10-K for the Fiscal Year Ended December 31, 2006
                           Filed March 16, 2007
                           File No. 001-16197
                           -----------------------------------------------------

Dear Mr. Nolan:

         Please  accept this letter in response to your letter to me dated April
5, 2007 regarding the Form 10-K of Peapack-Gladstone  Financial Corporation (the
"Company") for the fiscal year ended December 31, 2006 filed with the Securities
 -------
and Exchange Commission (the "Commission") on March 16, 2007 (the "Form 10-K").
                              ----------                           ---------

         Item 1 of your  letter is  repeated  below and the  Company's  response
thereto follows each bullet point of Item 1:

         1. We note your disclosure that you make operating decisions and assess
performance  based on review of your banking  operations,  which  constitute the
only  operating  segment for  financial  reporting.  In light of the  increasing
significance  of your PGB Trust and  Investments  division  to your  results  of
operations,  please  refer  to  paragraphs  10 - 15 of SFAS  131 and tell us the
following:

         o  Describe your organization structure within the bank and the holding
            company,  identifying  who manages  this  division  and to whom that
            individual directly reports;

         Peapack-Gladstone  Financial Corporation (the "Corporation") was formed
         in 1997 and is the  holding  company  for  Peapack-Gladstone  Bank (the
         "Bank").  The bank,  founded in 1921, is a commercial bank operating 22
         branches in Somerset,  Hunterdon,  Morris and Union Counties. PGB Trust
         and Investments  (the  "Division")  was formed and began  operations in
         1972 for the purpose of providing trust

<page>

John P. Nolan - Accounting Branch Chief
May 1, 2007
Page 2

         services to bank customers.  Virtually all the clients of the trust and
         investment  division also are customers of the bank and have  non-trust
         products,  such as loan and deposit relationships.  Mr. Craig Spengeman
         manages the trust division on a day-to-day  basis and reports  directly
         to Mr. Frank  Kissel,  CEO of the Bank and the Company.  Mr.  Kissel is
         responsible  for managing and making all  important  decisions  for all
         banking operations, including the trust division.

         o  Describe  the  information  contained  in your  internal  management
            reports generated for this division and the banking operations;

         Internal  information  management reports are prepared for the division
         indicating the number of managed accounts and non-managed  accounts and
         the breakdown of total assets under administration by trust, investment
         management  and custody  accounts.  In  addition,  monthly  reports are
         prepared  listing fees  generated by type of accounts.  Profit and loss
         information is prepared on a quarterly  basis listing gross revenue and
         certain direct operating expenses,  such as salary and trust department
         expense.  This  report  does not  include  any  allocation  of indirect
         expenses. This information is used for the preparation of Schedule RC-T
         for the bank's regulatory  quarterly call report (Fiduciary and Related
         Services Income).

         Financial reports  generated for banking  operations on a monthly basis
         include detailed  consolidated  balance sheets and income statements at
         the bank level that compare changes with prior periods and variances to
         detailed budgets. Revenue and personnel costs relating to the trust and
         investment  division are  incorporated  into the Bank's annual  budget.
         Additional monthly reports that are prepared for the banking operations
         include  rate/volume  analysis,  loan  delinquency,  income and expense
         variance, deposits by branch, investment portfolio, long and short-term
         borrowings and certificate of deposits reports.

         o  Identify the  individual(s)  that review the information,  when they
            review it, and for what purpose they review it;

         Mr.  Spengeman  reviews  the client  data and fee  income  reports on a
         monthly basis for the purpose of monitoring the  division's  growth and
         budgeted fee income goals.

         The monthly financial reports, prepared for the banking operations, are
         reviewed by the executive  management group of Mr. Kissel,  Mr. Rogers,
         Mr.  Spengeman,  Mr.  Bromley and myself.  These  meetings focus on the
         bank's  overall  progress  toward its growth  and profit  goals.  These
         reports are then  presented to the Board of Directors at their  monthly
         meetings.

         o  Identify the  individual(s) who make resource  allocation  decisions
            for the division;

<page>

John P. Nolan - Accounting Branch Chief
May 1, 2007
Page 3

         Mr.  Spengeman,  under the supervision  and approval of Mr. Kissel,  is
         responsible  for  resource  allocation  decisions  for the Division and
         review the staffing requirements on an as needed basis.

         o  Identify the  individual(s)  who assess  performance of the division
            and describe the specific information used in the assessment; and

         Mr.  Spengeman,  with  the  supervision  of Mr.  Kissel,  assesses  the
         performance  of the Division.  The  information  reviewed and used on a
         monthly basis in the assessment  includes reports indicating the growth
         in  the  number  of  and  market  value   comparisons  of  managed  and
         non-managed  accounts  and the  investment  performance  on the various
         different types of accounts along with reports  indicating  gross trust
         fees recorded by type of account or service.

         Mr.  Kissel  evaluates the  performance  of the division as part of the
         overall  performance of the Banking operations as there is not separate
         financial  statement  information  prepared on a regular  basis for the
         division.  Performance  of the  division  is  evaluated  by Mr.  Kissel
         primarily on growth and retention of trust clients.

         o  Describe  the nature of  information,  if any,  with respect to this
            division that is presented to your board of directors.

         No separate monthly financial statements for the Division are presented
         to the Board. On a quarterly basis, Mr.  Spengeman  presents  financial
         data on the growth of client  accounts and balances and fees  generated
         by type of account to the Board.

         The Board of Directors is presented  monthly  financial  statements for
         the Bank  that  incorporates  the  revenue  and  expenses  of the Trust
         Division.  These statements include  consolidated income statements and
         balance  sheets at the bank  level  that  compare  changes  with  prior
         periods  and  variances  to  budget.  In  addition,  the board  reviews
         delinquency reports,  financial performance and liquidity ratio reports
         and investment securities activities reports.

         By way  of  this  letter,  we  acknowledge  that  (i)  the  Company  is
responsible  for the adequacy and accuracy of the  disclosure  in the Form 10-K;
(ii) staff  comments or changes to disclosure  in response to staff  comments do
not  foreclose  the  Commission  from taking any action with respect to the Form
10-K;  and (iii) the Company 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.

                                     *****

<page>

John P. Nolan - Accounting Branch Chief
May 1, 2007
Page 4

         Please contact me should you have any questions.

                                                 Very truly yours,

                                                 /s/ ARTHUR F. BIRMINGHAM

                                                 ARTHUR F. BIRMINGHAM
                                                 Executive Vice President and
                                                 Chief Financial Officer

cc:     Frank A. Kissel
        Anthony J. Consi, II
        Ronald H. Janis, Esq.
        Michael T. Rave, Esq.
        Stephen Geiger
        John G. Kendall

</TEXT>
</DOCUMENT>

Mail Stop 4561

April 5, 2007

Mr. Arthur F. Birmingham
Executive Vice President and Chief Financial Officer
Peapack-Gladstone Financial Corporation
158 Route 206
Peapack-Gladstone, NJ 07934

Re: Peapack-Gladstone Financial Corporation
  Form 10-K for the Fiscal Year Ended December 31, 2006
  Filed March 16, 2007
  File No. 001-16197

Dear Mr. Birmingham:

We have reviewed your filing and have the following comment.  We have limited
our review to only your financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  In our comment we ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2006

Exhibit 13 – Annual Report to Shareholders

Consolidated Financial Statements

Note 1 – Summary of Significant Accounting Policies, page 40

1. We note your disclosure that you make operating decisions and assess performance based on review of your banking operations, which constitute the only operating segment for financial reporting.  In light of the increasing significance of your PGB Trust and Investments division to your results of

Mr. Arthur F. Birmingham
Peapack-Gladstone Financial Corporation
4/5/2007 Page 2
operations, please refer to paragraphs 10 – 15 of SFAS 131 and tell us the following:

• describe your organization structure within the bank and the holding company, identifying who manages this division and to whom that individual directly reports;
• describe the information contained in your internal management reports generated for this division and the banking operations;
• identify the individual(s) that review the information, when they review it, and for what purpose they review it;
• identify the individual(s) who make resource allocation decisions for the division;
• identify the individual(s) who assess performance of the division and describe the specific information used in the assessment; and
• describe the nature of information, if any, with respect to this division that is presented to your board of directors.

* * * *
Please respond to this comment within 10 business days or tell us when you will
provide us with a response.  Please submit your response letter on EDGAR.  Please understand that we may have additional comments after reviewing your response to our comment.

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that:

• the company 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 company 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.

Mr. Arthur F. Birmingham
Peapack-Gladstone Financial Corporation
4/5/2007 Page 3
In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comment on your filing.

You may contact Joyce Sweeney, Staff A ccountant, at (202) 551-3449, or me at
(202) 551-3492 if you have any questions.

Sincerely,

John P. Nolan
Accounting Branch Chief

Mail Stop 3720

       November 15, 2006

Mr. Arthur F. Birmingham
Executive Vice President
  and Chief Financial Officer
Peapack-Gladstone Financial Corporation
158 Rout 206
Peapack-Gladstone, NJ 07934

Re:   Peapack-Gladstone Financial Corporation
 Item 4.01 Form 8-K
Filed November 15, 2006
 File No. 001-16197

Dear Mr. Birmingham:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with more information so we may
better understand your disclosure.  After re viewing this information, we may raise
additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
1. Please file a revised Form 8-K upon the co mpletion of the audit of the company’s
consolidated financial statements as of  and for the year ended December 31, 2006,
as discussed in Item 4.01 of your Form 8-K filed on November 14, 2006, to
include the date upon which the dismissal of  your auditors is effective.  Please
note that all portions of the Form 8- K should be updated, including the section
regarding any disagreements.  A new E xhibit 16 letter will also be required.

2. Please revise your disclosure to specif ically state whether there were any
disagreements, as described in Item 304( a)(1)(iv) of Regulat ion S-K, during the

Mr. Arthur F. Birmingham
Peapack-Gladstone Financial Corporation
November 15, 2006 Page 2
company’s two most recent fiscal years or any subsequent interim period through
the effective date of dismissal.

*    *    *    *

 As appropriate, please amend your filing and respond to these comments, via
EDGAR, within five business days or tell us when you will respond.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides
any requested information.  Detailed cover le tters greatly facilitate our review.  Please
understand that we may have additional comm ents after reviewing your amendment and
responses to our comments.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

‚ the company 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 company 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 If you have any questions, please call Kenya Wright Gumbs at (202) 551-3373.

        S i n c e r e l y ,

Robert S. Littlepage
 Accountant Branch Chief

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<TEXT>
                                                               November 17, 2006

VIA EDGAR

United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 3720
Washington, D.C. 20549

Attention:   Robert S. Littlepage, Accountant Branch Chief

Re:   Peapack-Gladstone Financial Corporation
      Item 4.01 Form 8-K
      Filed November 14, 2006
      File No. 001-16197

Dear Mr. Littlepage:

      We have reviewed the November 15, 2006 comment letter issued by the staff
of the United States Securities and Exchange Commission (the "Commission") and
addressed to Peapack-Gladstone Financial Corporation (the "Corporation" or "we")
relating to the Corporation's Current Report on Form 8-K dated November 14,
2006. Set forth below is our response to the Staff's comments. For ease of the
Staff's review, we have included the Staff's comment preceding our response.

Staff Comment
-------------

1.    Please file a revised Form 8-K upon the completion of the audit of the
      company's consolidated financial statements as of and for the year ended
      December 31, 2006, as discussed in Item 4.01 of your Form 8-K filed on
      November 14, 2006, to include the date upon which the dismissal of your
      auditors is effective. Please note that all portions of the Form 8-K
      should be updated, including the section regarding any disagreements. A
      new Exhibit 16 letter will also be required.

Response
--------

      We will file a Form 8-K/A upon the completion of the audit of the
Corporation's consolidated financial statements as of and for the year ended
December 31, 2006 to include the date upon which the dismissal of our auditors,
KPMG LLP ("KPMG"), is effective. The Form 8-K/A, including the section regarding
any disagreements, will be updated through the effective date of the dismissal
of KPMG and include a new Exhibit 16 letter.

<PAGE>

Staff Comment
-------------

2.    Please revise your disclosure to specifically state whether there were any
      disagreements, as described in Item 304(a)(I)(iv) of Regulation S-K,
      during the company's two most recent fiscal years or any subsequent
      interim period through the effective date of dismissal.

Response
--------

      We are filing on the date hereof a Form 8-K/A to revise our disclosure to
specifically state that there were no disagreements, as described in Item
304(a)(I)(iv) of Regulation S-K, during the Corporation's two most recent fiscal
years and the subsequent interim period through November 10, 2006. The third
paragraph of the Form 8-K/A reads as follows:

      "During the two fiscal years ended December 31, 2005, and the subsequent
interim period through November 10, 2006, there were no (1) disagreements with
KPMG on any matter of accounting principles or practices, financial statement
disclosure, or auditing scope or procedures, which disagreements if not resolved
to KPMG's satisfaction would have caused KPMG to make reference in connection
with their opinion to the subject matter of the disagreements in its audit
reports on the consolidated financial statements of the Corporation or (2)
"reportable events" as defined in Item 304(a)(1)(v) of Regulation S-K."

      By way of this letter, we acknowledge that (i) the Corporation is
responsible for the adequacy and accuracy of the disclosure in the filing; (ii)
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
(iii) the Corporation 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.

      We trust that these responses adequately address the Staff's comments.
However, if you have any points that that you would like to discuss further,
please contact the undersigned at (908) 719-4308.

                          Very truly yours,

                          PEAPACK-GLADSTONE FINANCIAL CORPORATION

                          By:      /s/ Arthur F. Birmingham
                             --------------------------------------------------
                          Name:    Arthur F. Birmingham
                          Title:   Executive Vice President and Chief Financial
                                   Officer

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