SecProbe.io

CORRESP
 1
 filename1.htm

 August 15, 2025

 Via EDGAR Filing and
e-mail

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

 Attention: Robert Arzonetti

 Re: Seacoast Banking Corporation of Florida (the " Company ") Registration Statement on Form S-4
(File No. 333-288902), as amended (the " Registration Statement ")-Acceleration Request

 Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended (the " Securities Act "), the Company hereby requests that the Securities
and Exchange Commission (the " Commission ") accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on August 18,
2025, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us
in writing.

 In connection with the Company's
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Sincerely,

 SEACOAST
 BANKING CORPORATION OF FLORIDA

 By:
 /s/ Charles M. Shaffer

 Charles
 M. Shaffer

 Chairman &
 Chief Executive Officer

 cc: 
 Randolph A. Moore III

 Alston & Bird LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 6, 2025

Charles M. Shaffer
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994

 Re: Seacoast Banking Corporation of Florida
 Registration Statement on Form S-4
 Filed July 23, 2025
 File No. 333-288902
Dear Charles M. Shaffer:

 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 Robert Arzonetti at 202-551-8819 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Randy Moore
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 May 14, 2025

 Via EDGAR Filing and
e-mail

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

 Attention: Robert Arzonetti

 Re: Seacoast Banking Corporation of Florida (the " Company ") Registration Statement on Form S-4
(File No. 333-286394), as amended (the " Registration Statement ")-Acceleration Request

 Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended (the " Securities Act "), the Company hereby requests that the Securities
and Exchange Commission (the " Commission ") accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 2:00 p.m., Eastern Time, on May 16, 2025,
or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us in writing.

 In connection with the Company's
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Sincerely,

 SEACOAST BANKING CORPORATION OF FLORIDA

 By:
 /s/ Charles M. Shaffer

 Charles M. Shaffer

 Chairman & Chief Executive
 Officer

 cc: Randolph A. Moore III

 Alston & Bird LLP

CORRESP
 1
 filename1.htm

 Document May 14, 2025 VIA EDGAR FILING AND E-MAIL U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549 Attention: Robert Arzonetti Re: Seacoast Banking Corporation of Florida (the “ Company ”) Registration Statement on Form S-4 (File No. 333-286394), as amended (the “ Registration Statement ”)— Acceleration Request Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “ Securities Act ”), the Company hereby requests that the Securities and Exchange Commission (the “ Commission ”) accelerate the effective date of the above-referenced Registration Statement and declare the Registration Statement, as amended, effective under the Securities Act at 2:00 p.m., Eastern Time, on May 16, 2025, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us in writing. In connection with the Company’s request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following: (1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Sincerely, SEACOAST BANKING CORPORATION OF FLORIDA By: /s/ Charles M. Shaffer Charles M. Shaffer Chairman & Chief Executive Officer cc:    Randolph A. Moore III Alston & Bird LLP

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 April 17, 2025

Charles M. Shaffer
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994

 Re: Seacoast Banking Corporation of Florida
 Registration Statement on Form S-4
 Filed April 4, 2025
 File No. 333-286394
Dear Charles M. Shaffer:

 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 Robert Arzonetti at 202-551-8819 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Randolph A. Moore III
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

November 10, 2022

Via EDGAR Filing and
e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Jessica Livingston

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form
S-4 (File No. 333-267739), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities and
Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 2:00 p.m., Eastern Time, on November 14, 2022,
or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us in writing.

In connection with the Company’s
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy
of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness as a defense in
any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    SEACOAST BANKING
    CORPORATION OF FLORIDA

    By:
    /s/ Charles M. Shaffer

    Charles M. Shaffer

    Chairman & Chief
    Executive Officer

    cc:
    Randolph A. Moore III

    Alston & Bird LLP

United States securities and exchange commission logo
October 12, 2022
Charles M. Shaffer
Chairman and Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994
Re:Seacoast Banking Corporation of Florida
Registration Statement on Form S-4
Filed October 4, 2022
File No. 333-267739
Dear Charles M. Shaffer:
            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 David Gessert at 202-551-2326 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

August 30,
2022

Via EDGAR Filing and
e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Jessica Livingston

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form S-4
(File No. 333-265988), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on September 1,
2022, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us
in writing.

In connection with the Company’s
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Sincerely,

  SEACOAST BANKING CORPORATION OF FLORIDA

  By: /s/ Charles M. Shaffer

  Charles M. Shaffer

  Chairman & Chief Executive Officer

    cc:
    Randolph A. Moore III

    Alston & Bird LLP

CORRESP
1
filename1.htm

August 10,
2022

Via EDGAR Filing and
e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Jessica Livingston

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form S-4
(File No. 333-265213), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on August 11,
2022, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us
in writing.

In connection with the Company’s
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    SEACOAST BANKING CORPORATION OF FLORIDA

    By:
     /s/ Charles M. Shaffer

    Charles M. Shaffer

    President & Chief Executive
    Officer

cc:            Randolph
A. Moore III

Alston & Bird LLP

United States securities and exchange commission logo
July 15, 2022
Charles Shaffer
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994
Re:Seacoast Banking Corporation of Florida
Registration Statement on Form S-4
Filed July 1, 2022
File No. 333-265988
Dear Mr. Shaffer:
            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

United States securities and exchange commission logo
June 6, 2022
Charles M. Shaffer
Chairman and Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, Florida 34994
Re:Seacoast Banking Corporation of Florida
Registration Statement on Form S-4
Filed May 25, 2022
File No. 333-265213
Dear Mr. Shaffer:
            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 John Stickel at 202-551-3324 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

November 15, 2021

Via EDGAR Filing and
e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Jessica Livingston

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form S-4
(File No. 333-259930), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on November 15,
2021, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us
in writing.

In connection with the Company’s
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    SEACOAST BANKING CORPORATION OF FLORIDA

    By:
               /s/ Charles M. Shaffer

    Charles M. Shaffer

    President & Chief Executive Officer

    cc:
    Randolph A. Moore III

    Alston & Bird LLP

CORRESP
1
filename1.htm

November 4, 2021

Via EDGAR Filing and
e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Jessica Livingston

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form
S-4 (File No. 333-259933), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461 under
the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities and
Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on November 4, 2021,
or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us in writing.

In connection with the Company’s
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy
of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness as a defense in
any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    SEACOAST
    BANKING CORPORATION OF FLORIDA

    By:
     /s/ Charles M. Shaffer

    Charles
    M. Shaffer

    President
    & Chief Executive Officer

    cc:
    Randolph A. Moore III

    Alston & Bird LLP

United States securities and exchange commission logo
October 5, 2021
Charles M. Shaffer
President and Chief Executive Officer
Seacoast Banking Corp of Florida
815 Colorado Avenue
Stuart, Florida 34994
Re:Seacoast Banking Corp of Florida
Registration Statement on Form S-4
Filed September 30, 2021
File No. 333-259933
Dear Mr. Shaffer:
            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 Jessica Livingston at 202-551-3448 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

June 15, 2021

Via EDGAR Filing and
e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Tanya Aldave

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form S-4
(File No. 333-256157), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on June 17, 2021,
or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us in writing.

In connection with the Company’s
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following:
(1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant
to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy
and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

    Sincerely,

    SEACOAST BANKING CORPORATION OF FLORIDA

    By:
    /s/ Charles M. Shaffer

    Charles M. Shaffer

    President & Chief Executive Officer

    cc:
    Randolph A. Moore III

    Alston & Bird LLP

United States securities and exchange commission logo
May 24, 2021
Charles Shaffer
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994
Re:Seacoast Banking Corporation of Florida
Registration Statement on Form S-4
Filed May 14, 2021
File No. 333-256157
Dear Mr. Shaffer:
            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 Tonya K. Aldave at (202) 551-3601 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Randolph A. Moore III, Esq.

CORRESP
1
filename1.htm

July 14, 2020

Via EDGAR Filing
and e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Tanya Aldave

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement
on Form S-4 (File No. 333-237585), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration
Statement and declare the Registration Statement, as amended, effective under the Securities Act at 4:00 p.m., Eastern Time, on
July 16, 2020, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date
and time to us in writing.

In connection with
the Company’s request for acceleration of the effective date of the above-referenced Registration Statement, the Company
hereby acknowledges the following: (1) should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the
Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company
from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) the Company may not assert
staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

    Sincerely,

    SEACOAST BANKING CORPORATION OF FLORIDA

    By:
    /s/ Charles M. Shaffer

    Charles M. Shaffer

    President & Chief Operating Officer

    cc:
    Randolph A. Moore III

    Alston & Bird LLP

April 10, 2020
Denis S. Hudson, III
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994
Re:Seacoast Banking Corporation of Florida
Registration Statement on Form S-4
Filed April 6, 2020
File No. 333-237585
Dear Mr. Hudson:
            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 Tonya K. Aldave at (202) 551-3601 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Randy Moore, Esq.

CORRESP
1
filename1.htm

February 5, 2020

Via EDGAR Filing
and e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Julie Griffith

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement
on Form S-4 (File No. 333-235892), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration
Statement and declare the Registration Statement, as amended, effective under the Securities Act at 5:00 p.m., Eastern Time, on
February 6, 2020, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective
date and time to us in writing.

In connection with
the Company’s request for acceleration of the effective date of the above-referenced Registration Statement, the Company
hereby acknowledges the following: (1) should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the
Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company
from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) the Company may not assert
staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

    Sincerely,

    SEACOAST BANKING CORPORATION OF FLORIDA

    By:
    /s/ Charles M. Shaffer

    Charles M. Shaffer

    Chief Financial Officer

    cc:
    Randolph A. Moore III

    Alston & Bird LLP

January 17, 2020
Dennis S. Hudson, III
Chief Executive Officer
SEACOAST BANKING CORP OF FLORIDA
815 Colorado Avenue
Stuart, FL 34994
Re:SEACOAST BANKING CORP OF FLORIDA
Registration Statement on Form S-4
Filed January 10, 2020
File No. 333-235892
Dear Mr. Hudson:
            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 Julia Griffith at 202-551-3267 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

CORRESP
1
filename1.htm

August 27, 2018

Via EDGAR Filing
and e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Erin Purnell

 Re: Seacoast Banking Corporation of Florida (the “Company”) Registration Statement
on Form S-4 (File No. 333-226225), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities
and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration
Statement and declare the Registration Statement, as amended, effective under the Securities Act at 4:30 p.m., Eastern Time, on
August 28, 2018, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective
date and time to us in writing.

In connection with
the Company’s request for acceleration of the effective date of the above-referenced Registration Statement, the Company
hereby acknowledges the following: (1) should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the
Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company
from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) the Company may not assert
staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

    Sincerely,

    SEACOAST BANKING CORPORATION OF FLORIDA

    By:
    /s/ Charles M. Shaffer

    Charles M. Shaffer

    Chief Financial Officer

 cc: Randolph A. Moore III

    	Alston & Bird LLP

July 24, 2018
Chuck Shaffer
Chief Executive Officer
Seacoast Banking Corp of Florida
815 Colorado Avenue
Stuart, FL 34994
Re:Seacoast Banking Corp of Florida
Registration Statement on Form S-4
Filed July 18, 2018
File No. 333-226225
Dear Mr. Shaffer:
            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 Erin Purnell, Staff Attorney, at (202) 551-3454 with any questions.
Division of Corporation Finance
Office of Financial Services

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 September 18, 2017

VIA EDGAR FILING AND E-MAIL

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

 Washington,
D.C. 20549

 Attention: David Gessert

 Re:

 Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on

 Form S-4 (File No. 333-219339), as amended (the “Registration Statement”)—

 Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby
requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement and declare the Registration Statement, as amended, effective under the Securities
Act at 4 p.m., Eastern Time, on Wednesday, September 20, 2017, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and time to us in writing.

In connection with the Company’s request for acceleration of the effective date of the above-referenced Registration
Statement, the Company hereby acknowledges the following: (1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to
the filing; (2) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in
the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Sincerely,

SEACOAST BANKING CORPORATION OF FLORIDA

 By:

 /s/ Charles M. Shaffer

 Charles M. Shaffer

Chief Financial Officer

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 September 13, 2017

VIA EDGAR FILING AND E-MAIL

 U.S. Securities and
Exchange Commission

 Division of Corporation Finance

 100 F
Street, NE

 Washington, D.C. 20549

 Attention: David Lin

Re:
 Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on

 Form S-4 (File No. 333-218873), as amended (the “Registration Statement”)—

 Acceleration Request

Ladies and Gentlemen:

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the
above-referenced Registration Statement and declare the Registration Statement, as amended, effective under the Securities Act at 4 p.m., Eastern Time, on Wednesday, September 13, 2017, or as soon thereafter as practicable. We also request that
the Commission specifically confirm such effective date and time to us in writing.

 In connection with the Company’s
request for acceleration of the effective date of the above-referenced Registration Statement, the Company hereby acknowledges the following: (1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

 Sincerely,

SEACOAST BANKING CORPORATION OF FLORIDA

By:

 /s/ Charles M. Shaffer

 Charles M. Shaffer

Chief Financial Officer

 :

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 One Atlantic Center

1201 West Peachtree Street

 Atlanta,
GA 30309-3424

 404-881-7000 | Fax: 404-881-7777

 Randolph A. Moore III

Direct Dial: 404-881-7794

Email: randy.moore@alston.com

 September 8, 2017

VIA EDGAR AND ELECTRONIC MAIL

Mr. David Lin

Office of Financial Services

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E., Mail Stop 4720

Washington, D.C. 20549

Re:
 Seacoast Banking Corporation of Florida

Registration Statement on Form S-4

Filed September 8, 2017

File No. 333-218873

Dear Mr. Lin:

On behalf of Seacoast Banking Corporation of Florida (the “Company”), set forth below are the Company’s
responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) provided orally to Alston & Bird LLP related to the Registration
Statement on Form S-4 (File No. 333-218873) (the “Registration Statement”), filed by the Company with the Commission on August 30, 2017.

The Company has filed via EDGAR Amendment No. 2 to the Registration Statement on Form S-4 (“Amendment No. 2”), which
reflects the Company’s responses to the oral comments received yesterday from the Staff and certain updated information. We are supplementally providing a blacklined copy of the Registration Statement, marked to show the changes from the
Registration Statement as filed on August 30, 2017.

 Oral Comment

Yesterday, the Staff requested that the Company expand certain disclosure and explain why Palm Beach Community Bank
(“PBCB”) is soliciting shareholder approval of certain payments and other benefits accruing to Calvin L. Cearley, chief executive officer of PBCB, James E. Springer, president, chief operating officer and chief credit officer of PBCB and
James E. Nugent, executive vice president and senior loan officer of PBCB, via written consent rather than pursuant to the Registration Statement.

 Alston & Bird LLP

www.alston.com

Atlanta | Beijing | Brussels | Charlotte | Dallas | Los Angeles | New York | Research Triangle | San Francisco | Silicon Valley
| Washington, D.C.

 August 30, 2017

Page 2

 Response

In response to the Staff’s oral comments, the Company has expanded the disclosure on page 59 of Amendment No. 2
(“Interests of PBCB Directors and Executive Officers in the Merger”) to include a statement that PBCB currently anticipates that a shareholder vote will be necessary to permit Messrs. Cearley, Springer and Nugent to receive certain
payments that would otherwise be deemed parachute payments (the “280G payments”), as defined in Section 280G of the Internal Revenue Code, as amended (the “Code”).

The Company further enhanced its disclosure on page 72 of Amendment No. 2 (“Approval of 280G Payments”) to describe
why shareholder approval may be necessary under Sections 280G and 4999 of the Code and to clarify that: (i) an exemption from these tax penalties under 280G of the Code applies to companies that qualify as an S corporation, (ii) however, PBCB does
not currently have a valid S corporation election so the 280G exemption does not apply and (iii) in the event that the Internal Revenue Service (the “IRS”) grants the letter ruling request regarding PBCB’s S corporation election prior
to the consummation of the merger, then the 280G payments to Messrs. Cearley, Springer and Nugent will be exempt from 280G and no shareholder vote will be required.

Consequently, PBCB has elected to solicit the written consent of PBCB shareholders pursuant to a consent statement rather than
pursuant to the Registration Statement because the shareholder vote may not be required (as outlined above) if PBCB receives a favorable ruling from the IRS regarding its S corporation status prior to closing the merger. Additionally, under IRS
guidance, the approval of a merger agreement (or other purchase agreement) cannot be contingent or otherwise conditioned on the approval of 280G payments. The Company believes that by separating these votes and seeking shareholder approval of
the merger prior to the 280G vote avoids any suggestion that PBCB shareholders were compelled to approve the 280G payments. Although PBCB is required by the terms of the merger agreement to hold the shareholder vote, if necessary, actual
shareholder approval of the 280G payments is not a condition of the merger. Approval of the 280G payments is an entirely separate and unrelated vote from the vote to approve the merger. Regardless of whether the shareholders of PBCB
approve or do not approve the 280G payments, the value of the stock and cash consideration a PBCB shareholder will receive if the merger is approved will not change.

Finally, the Company does not believe that instruction E.2 to Form S-4 requires inclusion of a separate vote for the 280G
payments in the Registration Statement. Instruction E.1 to Form S-4 provides the guiding language and describes a registrant’s submission of a proposal to security holders entitled “to vote on, or consent to, a transaction
(emphasis supplied) in which the securities being registered are to be issued” and such submission is subject to Regulation 14A. Instruction E.2 requires a registrant to file such proxy or information materials sent to security holders
as a part of the registration statement or as an amendment thereto if

 August 30, 2017

Page 3

 such materials are not
subject to Regulation 14A. The “transaction” in which the Company’s securities are being registered with the SEC and issued is the underlying merger. PBCB shareholders are properly voting to approve this
“transaction” where they will receive registered securities of the Company under the Registration Statement in exchange for their PBCB shares. On the contrary, the PBCB shareholder vote to approve or disapprove additional executive
compensation is not a “transaction in which the securities are being registered.” The approval or disapproval of the 280G payments has no bearing on the investment decision or the stock consideration that is being registered pursuant
to the Registration Statement. The Company believes that PBCB can properly seek shareholder approval of the 280G payments separate and apart from the shareholder approval of the merger pursuant to which such shareholders will receive the
Company’s registered securities. Consequently, approval of the 280G payments is properly excluded from the Registration Statement because it does not constitute a shareholder “vote on, or consent to, a transaction in which the
securities being registered are to be issued.”

 Thank you for your attention to the Company’s responses. If you
have any questions or comments regarding the foregoing, or have any additional questions or comments, please do not hesitate to contact me at (404) 881-7794.

Best regards,

/s/ Randolph A. Moore III

Randolph A. Moore III

cc:
 Charles M. Shaffer, Chief Financial Officer, Seacoast Banking Corporation

Bradley D. Houser, Holland & Knight LLP

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 One Atlantic Center

1201 West Peachtree Street

 Atlanta,
GA 30309-3424

 404-881-7000 | Fax: 404-881-7777

Randolph A. Moore III

Direct Dial: 404-881-7794

Email: randy.moore@alston.com

 August 30, 2017

VIA EDGAR AND ELECTRONIC DELIVERY

 Mr. David Lin

Office of Financial Services

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E., Mail Stop 4720

Washington, D.C. 20549

 Re:

 Seacoast Banking Corporation of Florida

Registration Statement on Form S-4

Filed June 21, 2017

 File No. 333-218873

 Dear Mr. Lin:

On behalf of Seacoast Banking Corporation of Florida (the “Company”), set forth below is the Company’s
responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter to the Company dated July 18, 2017 related to
the Registration Statement on Form S-4 (File No. 333-218873) (the “Registration Statement”), filed by the Company with the Commission on June 21,
2017.

 The Company is concurrently filing via EDGAR Amendment No. 1 to the Registration Statement on Form S-4 (“Amendment No. 1”), which reflects the Company’s responses to the comments received from the Staff and certain updated information. We are supplementally providing a blacklined copy of the
Registration Statement, marked to show the changes from the Registration Statement as filed on June 21, 2017.

 For
convenience of reference, each Staff comment contained in your letter is reprinted below in bold and is followed by the corresponding response of the Company.

Prospectus Cover Page

1.
 Please revise to provide a range of total merger consideration values that shareholders may receive for
each PBCB share they hold. For example, please disclose, if true, that the per share merger consideration is expected to be within a range of $26.93 and $28.65, unless the merger agreement is terminated. Please make corresponding revisions
throughout your prospectus as appropriate.

 Response:

The disclosure in the Registration Statement has been revised in response to the Staff’s comment. Please refer to the
cover page of Amendment No. 1, as well as pages 1, 2, 7, and 62 through 63 of Amendment No. 1.

 If the merger is
completed, each share of PBCB common stock will be converted into the right to receive merger consideration within a range of $26.93 per share (the minimum amount) and $28.65 per share (the maximum amount), consisting of a combination of shares of
Seacoast common stock (the “stock consideration”) and cash (the “cash consideration”), subject to adjustment and calculation as set forth in the proxy statement/prospectus.

 Alston & Bird LLP

www.alston.com

 Atlanta  |  Beijing  |
 Brussels  |  Charlotte  |  Dallas  |  Los Angeles  |  New York  |  Research Triangle  |  San Francisco  |  Silicon Valley  |  Washington, D.C.

 August 30, 2017

Page 2

2.
 Please revise the cover page to materially describe all potential adjustments to the merger consideration.
In this regard, we note that both parties have termination rights if the Seacoast closing price is less than $19.00, in which case Seacoast may prevent termination by adjusting the merger consideration. Alternatively, please cross-reference the
relevant disclosure in your Q&A or summary section that describes the potential adjustments.

 Response:

 The disclosure in the Registration Statement has been revised in response to the Staff’s comment. Please refer to the
cover page of Amendment No. 1, which cross-references the relevant disclosure in the Q&A section that describes the potential adjustments to the merger consideration.

Summary, page 6

3.
 Please disclose in your prospectus summary that PBCB shareholders have certain indemnification obligations
in the event that the tax insurance policy is insufficient to cover any taxes resulting from the letter ruling matter, as discussed on page 69, and also disclose the expiration of the same. Please make corresponding revisions to your Q&A
section.

 Response:

The disclosure in the Registration Statement has been revised in response to the Staff’s comment. Please refer to page 12
of the Summary section and page 3 of the Q&A section of Amendment No. 1, which discloses that PBCB shareholders have certain indemnification obligations in the event that the tax insurance policy is insufficient to cover any taxes resulting
from the letter ruling matter and further discloses that such obligations expire on May 4, 2024.

 Interests of PBCB Directors and Executive
Officers in the Merger

 Payments under Certain Contracts, page 59

4.
 Please revise this discussion regarding certain of PBCB officers’ employment agreements to quantify
the estimated payments and benefits that would be provided to each person individually.

 Response:

The disclosure in the Registration Statement has been revised in response to the Staff’s comment. Please refer to page 59
of Amendment No. 1, which includes the estimated payments and benefits that may be made to certain of PBCB’s officers pursuant to their employment agreements.

The Company anticipates that a shareholder vote will be necessary to permit Calvin Cearley to receive certain payments that
would otherwise be deemed a parachute payment. PBCB anticipates soliciting the written consent of PBCB shareholders pursuant to a consent statement to be mailed to PBCB shareholders following the date of the proxy statement/prospectus, but prior to
the effective time of the merger.

 August 30, 2017

Page 3

 Conditions to Completion of the Merger

Additional Closing Conditions to the Obligations of Seacoast, page 74

5.
 We note your disclosure of the closing condition that PBCB’s consolidated tangible shareholders’
equity shall be at least $36.5 million and general allowance for loan and lease losses shall be at least 0.75% of total loans and leases outstanding. Please disclose PBCB’s measurement for each requirement as of a recent date.

 Response:

PBCB’s consolidated tangible shareholders’ equity was approximately $42.3 million as of June 30, 2017 and
general allowance for loan and lease losses was approximately 0.75% of total loans and leases outstanding as of June 30, 2017. The disclosure in the Registration Statement has been revised in response to the Staff’s comment. Please refer
to page 75 of Amendment No. 1.

 Thank you for your attention to the Company’s responses. If you have any
questions or comments regarding the foregoing, or have any additional questions or comments, please do not hesitate to contact me at (404) 881-7794.

 Best regards,

 /s/ Randolph A. Moore III

 Randolph A. Moore III

 cc:

 Charles M. Shaffer, Chief Financial Officer, Seacoast Banking Corporation

Bradley D. Houser, Holland & Knight LLP

Mail Stop 4720
July 21, 2017

Dennis S. Hudson, III
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994

Re: Seacoast Banking Corporation of Florida
  Registration Statement on Form S-4
Filed  July 18, 2017
  File No.  333-219339

Dear Mr. Hudson :

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 David Gessert at (202) 551 -2326 with any questions.

Sincerely,

 /s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Services

Mail Stop 4720

July 18, 2017

Charles M. Shaffer
Executive Vice President and Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994

Re: Seacoast Banking Corporation of Florida
  Registration Statement on Form S-4
Filed  June 21, 2017
  File No.  333-218873

Dear Mr. Shaffer :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our com ments 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 registration statement and the information you
provide in response to these  comments, w e may have  additional comments.

Prospectus Cover Page

1. Please revise to provide a range of total merger consideration values that shareholders
may receive for each PBCB share they hold.  For example, please disclose, if true, that
the per share merger consideration is expected to be within a range of $26.93 and $28.65,
unless the merger agreement is terminated.  Please make corresponding revisions
throughout your prospectus as appropriate .

2. Please revise the cover page to materially describe all potential adjustments to the merger
consideration.  In this regard , we n ote that both parties have term ination rights if the
Seacoast closing price is less than $19.00, in which case Seacoast may prevent
termination by adjusting the merger consideration.  Alternatively, please cross -reference

Charles M. Shaffer
Seacoast Banking Corporation of Florida
July 18, 2017
Page 2

 the relevant disclosure in your Q& A or summary section that describes the potential
adjustments.

Summary, page 6

3. Please disclose in your prospectus summary that PBCB shareholders have certain
indemnification obligations in the event that the tax insurance policy is insufficient to
cover  any taxes resulting from the letter ruling matter, as discussed on page 69, and also
disclose the expiration date of the same.  Please make corresponding revisions to your
Q&A section.

Interests of PBCB Directors and Executive Officers in the Merger

Payments under Certain Contracts, page 59

4. Please revise this discussion regardi ng certain of PBCB officers’ employment agreements
to quantify the estimated payments and benefits that would be provided to each person
individually.

Conditions to Completion of the Merger

Additional Closing Conditions to the Obligations of Seacoast, page 74

5. We note your disclosure of the closing condition that PBCB’s consolidated tangible
shareholders’ equity shall be at least $36.5 million and general allowance for loan and
lease losses shall be at least 0.75% of tota l loans and leases outstanding.  Please disclose
PBCB’s measurement for each requirement as of a recent date.

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.

Refer to  Rules 460 and 461 regarding requests for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Charles M. Shaffer
Seacoast Banking Corporation of Florida
July 18, 2017
Page 3

Please contact Christopher Dunham, Staff Attorney,  at (202) 551 -3783 or me at (202)
551-3552  with any  questions.

Sincerely,

 /s/ David Lin

David Lin
Staff Attorney
Office of Financial Services

cc: Randolph A. Moore III , Esq.

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Seacoast Banking Corporation of Florida

815 Colorado Avenue

Stuart, Florida 34994

    February 10, 2017

    VIA EDGAR

    United States Securities and Exchange Commission

    Division of Corporation Finance

    100 F Street N.E.

    Washington, DC 20549

        Attn:    Michael R. Clampitt

        Katelyn Donovan

    Re:
    Seacoast Banking Corporation of Florida

    Registration Statement on Form S-4

    File No. 333-215181

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933 (the “Securities Act”), Seacoast Banking Corporation of Florida, a Florida corporation (the “Company”),
respectfully requests that the effective date of the above-referenced Registration Statement be accelerated by the Securities and
Exchange Commission (the “Commission”) so that the Registration Statement, as then amended, will become effective under
the Securities Act at 10:00 a.m. ET on February 13, 2017 or as soon thereafter as practicable.

The Company hereby acknowledges that:

·should
the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission
from taking any action with respect to the filing;

·the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·the
Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

We request that we be notified of such effectiveness
by a telephone call to Andrew P. Alin of Cadwalader, Wickersham & Taft LLP at (212) 504-6889 and that such effectiveness also
be confirmed in writing.

    Very truly yours,

    SEACOAST BANKING CORPORATION OF FLORIDA

        /s/ Stephen Fowle

        By: Stephen Fowle

    Title:  Executive Vice President and Chief Financial Officer

    cc:
    William P. Mills, Esq.

    Andrew P. Alin, Esq.

    Cadwalader, Wickersham & Taft LLP

    One World Financial Center

    New York, NY 10281

[Signature Page to Acceleration Request]

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February 2, 2017

Via EDGAR

        Michael R. Clampitt

        Senior Staff Attorney

        United States Securities and Exchange Commission

        Division of Corporation Finance

        100 F Street N.E.

        Washington, D.C. 20549

Re: Seacoast Banking Corporation
of Florida

Registration Statement on Form S-4

Filed December 20, 2016

File No. 333-215181

Dear Mr. Clampitt:

On behalf of Seacoast Banking Corporation of Florida (“Seacoast”),
this letter responds to your letter, dated January 10, 2017 (the “Comment Letter”), regarding the above-referenced
filing (the “Registration Statement”).

Each response of Seacoast is set forth in ordinary type beneath
the corresponding comment of the Staff contained in the Comment Letter, which appears in bold type. For ease of reference, the
headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.

We have provided under separate cover for your convenience a
marked copy of Amendment No. 1 to the Registration Statement, which is being filed today by electronic submission.

Opinion of GulfShore’s Financial Advisor, page 36

 1. We note the description of the fairness opinion prepared by Sandler O’Neill. We further note that Sandler O’Neill
relied on Gulfshore’s internal financial projections for years ending December 31, 2016 through December 31, 2019. Please
disclosure these internal financial projections applied to the analysis of the fairness opinion, or, in the alternative, please
provide factors of consideration for why this information should not be disclosed.

We acknowledge the Staff’s comment and have
revised the disclosure on pages 46 and 47 of the Registration Statement to include the requested internal financial projections.

Interests of GulfShore Directors and Executive Officers
in the Merger, page 50

 2. Please supplement your Registration Statement by filing as Exhibits, the employment agreements of Messrs. Caballero, O’Carroll,
Mocsari, and Peterson as disclosed on page 50 of the Prospectus.

Pursuant to the Staff’s comment and our further
discussions with the Staff, we have filed the employment agreements that Seacoast has entered into with Messrs. Caballero and O’Carroll
as Exhibits 10.25 and 10.26, respectively, to Amendment No. 1 to the Registration Statement.

If you have any questions or comments or require further information
with respect to the foregoing, please do not hesitate to call the undersigned at (212) 504-6889 or my colleague, William Mills,
at (212) 504-6436.

Sincerely,

/s/ Andrew P. Alin

Andrew P. Alin

Partner

Mail 4720
January 10, 2017

Dennis S. Hudson III
Chief Executive Office r
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994

Re: Seacoast Banking Corporation of Florida
  Registration Statement on Form S-4
Filed  December 20, 2016
  File No.  333-215181

Dear Mr. Hudson :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our com ments 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 registration statement and the information you
provide in response to these  comments, w e may have  additional comments.

Opinion of Gulfshore’s Financial Advisor, page 36

1. We note the description of the fairness opinion prepared by Sandler O’Neill.  We further
note that Sandler O’Neill relied on Gulfshore’s internal financial projections fo r years
ending December 31, 2016 through December 31, 2019.  Please disclosure these internal
financial projections applied to the analysis of the fairness opinion, or, in the alternative,
please provide factors of consideration for why this information sh ould not be disclosed.

Interests of Gulfshore Directors and Executive Officers in the Merger, page 50

2. Please supplement your Registration Statement by filing as Exhibits, the employment
agreements of Messrs. Caballero , O’Carroll , Mocsari , and Peterson  as disclosed on page
50 of the Prospectus.

Dennis S. Hudson III
Seacoast Banking Corporation of Florida
January 10, 2017
Page 2

 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.

Refer to Ru les 460 and 461 regarding requests for  acceleration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

Please contact Katelyn Donovan  at (202) 551 -8636  or me at (202) 551-3434  with any
other questions.

Sincerely,

 /s/ Michael R. Clampitt

Michael R. Clampitt
Senior Staff Attorney
Office of Financial Services

cc: William P. Mills
 Cadwalader, Wickersham & Taft LLP

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January 20,
2016

Via EDGAR

Erin E. Martin

Special Counsel

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549

    Re:
    Seacoast Banking Corporation of Florida

    Amendment No. 1 to Registration Statement on Form S-4

    Filed January 15, 2016

    File No. 333-208546

Dear Ms. Martin:

On behalf of Seacoast Banking Corporation of Florida (“Seacoast”),
this letter responds to your letter, dated January 19, 2016 (the “Comment Letter”), regarding the above-referenced
filing (the “Amendment to Registration Statement”).

Each response of Seacoast is set forth in ordinary type beneath
the corresponding comment of the Staff contained in the Comment Letter, which appears in bold type. For ease of reference, the
headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.

We have provided under separate cover for your convenience a
marked copy of Amendment No. 2 to the Registration Statement, which is being filed today by electronic submission.

Material U.S. Federal Income Tax Consequences of the Merger

The Merger, page 51

 1. We note your disclosure that the merger is conditioned in part upon receipt by Floridian of a tax opinion from Gunster,
and the receipt by Seacoast of a tax opinion from Cadwalader, each to the effect that, among other things, the merger will constitute
a “reorganization” within the meaning of Section 368(a) of the Internal Revenue Code. We further note that, in their
respective tax opinions, Gunster and Cadwalader opine only that the discussion contained in the relevant portion of the prospectus
accurately sets forth the material U.S. federal income tax consequences of the transaction. Please revise your disclosure to state
clearly that the discussion in the tax consequences section of the prospectus is counsels’ opinion or have counsel revise
to provide long-form tax opinions.

We acknowledge the Staff’s comment
and have revised the disclosure on pages 50 and 51 of the Amendment to the Registration Statement related to U.S. federal
income tax consequences of the merger to state clearly that the discussion is counsels’ tax opinions.

If you have any questions or comments or require further information
with respect to the foregoing, please do not hesitate to call the undersigned at (212) 504-6436 or my colleague, Andrew Alin, at
(212) 504-6889.

Sincerely,

/s/ William P. Mills

William P. Mills

Partner

    Page 2

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Seacoast Banking Corporation of Florida

815 Colorado Avenue

Stuart, Florida 34994

January 20, 2016

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, DC 20549

Attn:    Erin E. Martin

    Re:
    Seacoast Banking Corporation of Florida

    Registration Statement on Form S-4

    File No. 333-208546

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933 (the “Securities Act”), Seacoast Banking Corporation of Florida, a Florida corporation (the “Company”),
respectfully requests that the effective date of the above-referenced Registration Statement be accelerated by the Securities and
Exchange Commission (the “Commission”) so that the Registration Statement, as then amended, will become effective under
the Securities Act at 12:00 p.m. ET on January 21, 2016 or as soon thereafter as practicable.

The Company hereby acknowledges that:

    ·
    should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

    ·
    the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

    ·
    the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We request that we be notified of such effectiveness
by a telephone call to William P. Mills of Cadwalader, Wickersham & Taft LLP at (212) 504-6436 and that such effectiveness
also be confirmed in writing.

    Very truly yours,

    SEACOAST BANKING CORPORATION OF FLORIDA

    /s/ Stephen A. Fowle

    By:
    Stephen A. Fowle

    Title:
    Chief Financial Officer

    cc:
    William P. Mills, Esq.

    Andrew P. Alin, Esq.

    Cadwalader, Wickersham & Taft LLP

    One World Financial Center

    New York, NY 10281

[Signature Page to Acceleration Request]

Mail Stop 4720
January  19, 2016

Dennis S. Hudson, III
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, Florida 34994

Re: Seacoast Banking Corporation of Florida
Amendment No. 1  to Re gistration Statement on Form S -4
Filed January  15, 2016
  File No. 333 -208546

Dear Mr. Hudson :

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

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comment applies  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 registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our January  6, 2016  letter .

Material U.S. Federal Income Tax Consequences of the Merge r

The Merger, page  51

1. We note your disclosure that the me rger is conditioned in part upon receipt by Floridian
of a tax opinion from Gunster, and the receipt by Seacoast of a tax opinion from
Cadwalader, each to the effect that, among other things, the merger will constitute a
“reorganization” within the meaning  of Section  368(a) of the Internal Revenue Code.  We
further note that, in their respective tax opinions, Gunster and Cadwalader opine only that
the discussion contained in the relevant portion of the prospectus accurately sets forth the
material U.S. fede ral income tax consequences of the transaction.  Please revise your
disclosure to state clearly that the discussion in the tax consequences section of the
prospectus is counsels’ opinion or have counsel revise to provide long -form tax opinions.

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida
January  19, 2016
Page 2

Please contact William H. Dorton, Staff Attorney,  at (202) 551 -3107  or me at (202) 551 -
3391  with any other questions.

Sincerely,

/s/ Erin E. Martin

Erin E. Martin
Special Counsel
Office of Financial Services

CORRESP
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January 15,
2016

Via EDGAR

Erin E. Martin, Special Counsel
 United States Securities and Exchange Commission
 Division of Corporation Finance
 100 F Street N.E.
 Washington, D.C. 20549

    Re:
    Seacoast Banking Corporation of Florida

    Registration Statement on Form S-4

    Filed December 15, 2015

    File No. 333-208546

Dear Ms. Martin:

On behalf of Seacoast Banking Corporation of Florida (“Seacoast”),
this letter responds to your letter, dated January 6, 2016 (the “Comment Letter”), regarding the above-referenced filing
(the “Registration Statement”).

Each response of Seacoast is set forth in ordinary type beneath
the corresponding comment of the Staff contained in the Comment Letter, which appears in bold type. For ease of reference, the
headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.

We have provided under separate cover for your convenience a
marked copy of Amendment No. 1 to the Registration Statement, which is being filed today by electronic submission.

Prospectus Cover Page

 1. Please disclose that Floridian may terminate the merger agreement if either (i) Seacoast’s common stock drops below
a certain floor price or (ii) Seacoast’s common stock underperforms the NASDAQ Bank Index by more than 20% and it does not
elect to increase the stock election consideration by a formula-based amount outlined in the merger agreement, each of which is
discussed in further detail on page 73, on the prospectus cover page.

We acknowledge the Staff’s comment and have
revised the disclosure on the prospectus cover page to include the suggested language.

The Merger Agreement, page 59

Representations and Warranties, page 70

 2. We note your disclosure that the representations and warranties contained in the merger agreement were made solely for the
benefit of the other party and should not be relied on by any other person. Please note that disclosure regarding an agreement’s
representations, warranties or covenants (whether through incorporation by reference or direct inclusion) constitutes disclosure
to investors, and you are required to consider whether additional disclosure is necessary in order to put the information contained
in, or otherwise incorporated into that publication, into context so that such information is not misleading. Please refer to Report
of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934 and Commission Statement on potential Exchange
Act Section 10(b) and Section 14(a) liability, Exchange Act Release No. 51283 (Mar. 1, 2005). Please revise this disclosure to
remove the implication that the merger agreement and summary do not constitute public disclosure under the federal securities laws
and to clarify that you will provide additional disclosure in your public reports to the extent that you are or become aware of
the existence of any material facts that are required to be disclosed under federal securities law and that might otherwise contradict
the representations and warranties contained in the agreements and will update such disclosure as required by federal securities
laws.

We acknowledge the Staff’s comment and have
revised the disclosure on page 70 of the Registration Statement related to the representations and warranties in the merger agreement
to remove the statements that implied that the representations and warranties contained in the merger agreement do not constitute
disclosure under the federal securities laws and to clarify that Seacoast will provide additional disclosure in its public reports
to the extent it becomes aware of the existence of any material facts that are required to be disclosed under federal securities
law and that might otherwise contradict the representations and warranties contained in the merger agreement and will update such
disclosure as required by federal securities laws. We note that Floridian does not file reports under the federal securities laws.

      Page 2

Part II, Item 21, Exhibits and Financial Statement Schedules

 3. Please file the employment agreement that you will enter into with Mr. Dargan as an exhibit to the registration statement.
Refer to Item 601(b)(10) of Regulation S-K for guidance.

We acknowledge the Staff’s comment and have
filed the employment agreement between Thomas H. Dargan and Seacoast as Exhibit 10.2 to the Registration Statement.

If you have any questions or comments or require further information
with respect to the foregoing, please do not hesitate to call the undersigned at (212) 504-6436 or my colleague, Andrew Alin, at
(212) 504-6889.

Sincerely,

/s/ William P. Mills

William P. Mills

Partner

      Page 3

Mail Stop 4720
January  6, 2016

Dennis S. Hudson, III
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, Florida 34994

Re: Seacoast Banking Corporation of Florida
  Registration Statement on Form S-4
Filed  December  15, 2015
  File No.  333-208546

Dear Mr. Hudson :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our com ments 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 registration statement and the information you
provide in response to these  comments, w e may have  additional comments.

Prospectus Cover Page

1. Please disclose that Floridian may terminate the merger agreement if either (i)  Seacoast’s
common stock drops below a certain floor price or (ii)  Seacoast’s common stock
underperforms the NASDAQ Ban k Index by more than 20% and it does not elect to
increase the stock election consideration by a formula -based amount outlined in the
merger agreement, each of which is discussed in further detail on page  73, on the
prospectus cover page.

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida
January  6, 2016
Page 2

 The Merger Agree ment, page  59

Representations and Warranties, page  70

2. We note your disclosure that the representations and warranties contained in the merger
agreement were made solely for the benefit of the other party and should not be relied on
by any other person.  Please note that disclosure regarding an agreement’s
representations, warranties or covenants (whether through incorporation by reference or
direct inclusion) constitutes disclosure to investors, and you are required to consider
whether additional disclosu re is necessary in order to put the information contained in, or
otherwise incorporated into that publication, into context so that such information is not
misleading.   Please refer to Report of Investigation Pursuant to Section 21(a) of the
Securities Exc hange Act of 1934 and Commission Statement on potential Exchange Act
Section 10(b) and Section 14(a) liability, Exchange Act Release No. 51283 (Mar. 1,
2005).   Please revise this disclosure to remove the implication that the merger agreement
and summary do  not constitute public disclosure under the federal securities laws and to
clarify that you will provide additional disclosure in your public reports to the extent that
you are or become aware of the existence of any material facts that are required to be
disclosed under federal securities law and that might otherwise contradict the
representations and warranties contained in the agreements and will update such
disclosure as required by federal securities laws.

Part II, Item  21, Exhibits and Financial Stat ement Schedules

3. Please file the employment agreement that you will enter into with Mr. Dargan as an
exhibit to the registration statement. Refer to Item 601(b)(10) of Regulation S -K for
guidance.

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 Act of 193 3 and
all applicable Securities  Act rules 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.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement , please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commiss ion from taking any action with respect
to the filing;

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida
January  6, 2016
Page 3

  the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of  the
registration statement.

Please contact William H. Dorton, Staff Attorney,  at (202) 551 -3107  or me at (202) 551 -
3391  with any other questions.

Sincerely,

/s/ Erin E. Martin

Erin E. Martin
Special Counsel
Office of Financial Services

CORRESP
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September 28, 2015

Via EDGAR Filing
and e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Kathryn McHale

    Re:
    Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form S-3 (File No. 333-206588), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), we hereby request that the Securities and
Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced Registration Statement
and declare the Registration Statement, as amended, effective under the Securities Act at 4 p.m., Eastern Time, on Tuesday, September
29, 2015, or as soon thereafter as practicable. We also request that the Commission specifically confirm such effective date and
time to us in writing.

In connection with
the Company’s request for acceleration of the effective date of the above-referenced Registration Statement, we hereby acknowledge
the following: (1) should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it
does not foreclose the Commission from taking any action with respect to the filing; (2) the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and (3) the Company may not assert staff comments and the declaration
of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

    Sincerely,

    SEACOAST BANKING CORPORATION OF FLORIDA

    By:
    /s/ David D. Houdeshell

    David D. Houdeshell

    Chief Risk Officer

CORRESP
1
filename1.htm

One Atlantic Center

1201 West Peachtree Street

Atlanta, GA 30309-3424

404-881-7000

Fax: 404-253-8340

www.alston.com

    Randolph A. Moore III
    Direct Dial: 404-881-7794
    Email: randy.moore@alston.com

September 25, 2015

Via EDGAR Filing
and e-mail

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Attention: Kathryn McHale

    Re:
    Seacoast Banking Corporation of Florida (the “Company”) Registration Statement on Form S-3 (File No. 333-206588), as amended (the “Registration Statement”)—Acceleration Request

Ladies and Gentlemen:

Pursuant to Rule 461
under the Securities Act of 1933, as amended (the “Securities Act”), on behalf of the Company, we hereby request
that the Securities and Exchange Commission (the “Commission”) accelerate the effective date of the above-referenced
Registration Statement and declare the Registration Statement, as amended, effective under the Securities Act at 4 p.m., Eastern
Time, on Tuesday, September 29, 2015, or as soon thereafter as practicable. We also request that the Commission specifically confirm
such effective date and time to us in writing.

In connection with
the Company’s request for acceleration of the effective date of the above-referenced Registration Statement, we, on behalf
of the Company, hereby acknowledge the following: (1) should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (2) the action
of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (3) the Company may not
assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

    Sincerely,

    ALSTON & BIRD LLP

    By:
    /s/ Randolph A. Moore

    Randolph A. Moore III, a partner

Atlanta
• Brussels • Charlotte • Dallas • Los Angeles • New York • Research Triangle • Silicon Valley
• Washington, D.C.

CORRESP
1
filename1.htm

September 23, 2015

VIA EDGAR AND OVERNIGHT DELIVERY

Ms. Kathryn McHale

Senior Staff Attorney

Office of Financial Services I

Division of Corporation Finance

Securities and Exchange Commission

100 F Street N.E., Mail Stop 4720

Washington, D.C. 20549

    Re:
    Seacoast Banking Corporation of Florida

    Registration Statement on Form S-3

    Filed on August 26, 2015

    File No. 333-206588

Dear Ms. McHale:

Seacoast Banking Corporation
of Florida (the “Company”) is hereby transmitting for filing pursuant to the Securities Act of 1933, as amended (the
“Securities Act”), Amendment No. 1 (“Amendment No. 1”) to the Registration Statement on Form
S-3 (File No. 333-206588) (the “Registration Statement”), filed by the Company August 26, 2015, and the Company’s
responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) contained in your letter to the Company dated September 4, 2015. For convenience of reference,
each Staff comment contained in your letter is reprinted below in bold and is followed by the corresponding response of the Company.

Selling Stockholder,
page 6

    1.
    Please tell us whether the selling stockholder is a broker-dealer or an affiliate of a broker-dealer. If you determine that the selling stockholder is a broker-dealer, please revise your disclosure to indicate that such selling stockholder is an underwriter, unless such selling stockholder received its securities as compensation for investment banking services. In addition, a selling stockholder who is an affiliate of a broker-dealer must be identified in the prospectus as an underwriter unless the prospectus states, if true, that:

    ·
    the selling stockholder purchased the shares being registered for resale in the ordinary course of business; and

    ·
    at the time of the purchase, the selling stockholder had no agreements or understandings, directly or indirectly, with any person to distribute the securities.

Please revise as appropriate.

Response:

The selling stockholder
identified in the Registration Statement is neither a broker-dealer nor an affiliate of a broker-dealer. Accordingly, the Company
does not believe that any revisions to the Registration Statement are necessary.

Exhibits

Exhibit 5.1

    2.
    You may limit reliance on your opinion with regard to purpose, but not person. Please revise the penultimate paragraph of the opinion.

Response:

The legal opinion attached
as Exhibit 5.1 to the Registration Statement has been revised to limit reliance on the opinion solely with regard to purpose. The
revised legal opinion is attached as Exhibit 5.1 to Amendment No. 1.

Thank you for your
prompt attention to Amendment No. 1 and the Company’s related responses. If you have any questions or comments regarding
the foregoing, or have additional questions or comments, please contact me at (772) 288-6086 or Randy Moore at (404) 881-7794.

    Very truly yours,

    /s/
    Dennis S. Hudson, III

    Dennis S. Hudson, III

    Chairman and Chief Executive Officer

    cc:
    Randolph A. Moore, III , Alston & Bird LLP

Mail Stop 4720

September 4, 2015

Via E -mail
Dennis S. Hudson, III
Chief Executive Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL  34994

Re: Seacoast Banking Corporation of Florida
Registration Statement on Form S -3
Filed August 26, 2015
  File No. 333-206588

Dear Mr. Hudson :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   If you do not  believe our com ments 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 registration statement and the information you
provide in response to these  comments, w e may have  additional comments.

Selling Stockholder, page 6

1. Please tell us whether the selling stockholder is a broker -dealer or an affiliate of a broker -
dealer.  If you determine that the selling stockholder is a broker -dealer, please revise your
disclosure to indicate that such selling stockholder is an underwriter, unless such selling
stockholder received its securities as compensation for investment banking services.  In
addition, a selling stockholder who is an affiliate of a broker -dealer must be identified in
the prospectus as an underwriter unless the prospectus states, if true, that:

 the selling stockholder purchased the shares being registered for resale in the ordinary
course of business; and

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida
September 4, 2015
Page 2

  at the time of the purchase, the selling stockhol der had no agreements or
understandings, directly or indirectly, with any person to distribute the securities.

Please revise as appropriate.

Exhibits

Exhibit 5.1

2. You may limit reliance on your opinion with regard to purpose, but not person.  Please
revise the penultimate paragraph of the opinion.

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 Act of 193 3 and
all applicable Securities  Act rules 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.

Notwithstanding our comments, in th e event you request acceleration of the effective date
of the pending registration statement , please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company fr om its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact t hat those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration s tatement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida
September 4, 2015
Page 3

 Please contact David Lin at (202) 551 -3552  or me at (202) 551 -3464  with any questions.

Sincerely,

 /s/ Kathryn McHale

Kathryn  McHale
Senior Staff Attorney
Office of Financial Services I

cc: Randolph A. Moore III, Esq.

January 30, 2013

Via Email
Mr. William R. Hahl
Executive Vice President and Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, Florida  34994

Re: Seacoast Banking Corporation  of Florida
 Form 10-K/A for the Year Ended December 31, 201 1
Filed March 26 , 2012
File No. 000-13660

Dear Mr. Hahl :

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 filing s 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 filing  to be certain that the filing s include  the
information the Securities Exchange Act of 1934 and all applicabl e rules require.

Sincerely,

 /s/ John P. Nolan

John P. Nolan
Senior Assistant Chief Accountant

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January 8, 2013

VIA EDGAR SUBMISSION AND OVERNIGHT DELIVERY

Mr. John P. Nolan

Senior Assistant Chief Accountant

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington D.C. 20549

 Re: Seacoast Banking Corporation of Florida

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

Filed March 26,
2012

Form 10-Q for the
Quarter Ended June 30, 2012

Filed August 8,
2012

File No. 000-13660

Dear Mr. Nolan:

This letter sets forth
the responses of Seacoast Banking Corporation of Florida (the “Company”) to the comments received from the staff of
the Division of Corporate Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
in your letter, dated September 26, 2012.  We apologize for the delay in responding to your correspondence,
but as you are aware we did not receive a copy of the comment letter until mid-December due to an incorrect email address used
by the Staff. The numbered paragraphs below correspond to the numbered paragraphs in your letter. To facilitate your review, we
have reproduced below the original text of the Staff’s comments, and have included the Company’s responses immediately
following such comments.

Please note that we
are filing this response letter via EDGAR submission and are also delivering a copy of the submission to your attention via overnight
delivery.

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

Item 7. Management’s Discussion
and Analysis of Financial Condition and Results of Operations

Allowance and Provision for Loan Losses,
page 6

 1. We note your disclosure on page 8 that you consider historical losses for the graded loan portfolio
based on historical migration of actual losses by grade and a range of losses over various periods. Please tell us and revise future
filings to disclose more specifically the historical periods specifically considered in your analysis. In your disclosure, include
additional granularity regarding any adjustments made to historical losses and, if applicable, discuss the specific facts and circumstances
that is the basis for such adjustments.

RESPONSE: For
the graded loans, historical losses are calculated using a loss migration over 4, 8, 12, 16, 20 and 24 quarter intervals. Minimum
and maximum average historical loss rates over one to five years are referenced in setting the loss factors by grade within the
graded loan portfolio.

    Mr. John P. Nolan
January 8, 2013
Page 2 of 6

Management uses historical
losses as the starting point in its analysis, and qualitative elements are also considered to capture trends within each portion
of the graded portfolio. The direction and expectations of past due loans, charge-offs, non-accruals, classified loans, the loan
portfolio mix, market conditions, and risk management controls are all considered in setting loss factors for the graded portfolio.

The loan loss migration
indicates that the minimum and maximum average loss rates and the median loss rates over the past several quarters have been declining.
The level of criticized and classified loans has also declined as a result of a combination of upgrades, loan payoff and loan sales,
which have reduced the overall  risk profile in the portfolio. Additionally, the risk profile has declined given the dramatic
shift in complexion of the portfolio, more specifically, as a result of an overall reduced level of commercial real estate loan
concentrations.

The Company will include
the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.

 2. We also note that you consider historical losses over the prior 12 months for non-graded loan
portfolios. Please tell us and revise future filings to disclose how you consider historical losses greater than 12 months when
determining the general allowance for these loan portfolios. Please be specific, especially in light of the significant charge-offs
and provisions for loan losses in prior periods.

RESPONSE: Residential
and consumer loans (installment, secured lines, and unsecured lines) are analyzed differently as risk ratings, or grades, are not
assigned to individual loans. Residential and consumer loan losses are tracked on a pool basis and monthly histories are averaged
for a rolling 12-month historical loss rate. Management believes the recent 12-month loss history is most appropriate as it best
represents the allowance for loan losses needed for the current mix of vintages of loans in the portfolio and not the vintages
that produced the significant losses in prior years. A prospective loss analysis forecasting credit trends provides opportunity
to incorporate views of various loan or property types, loan-to-value ratios, loan concentrations, and economic and environmental
factors. Management meets quarterly and, among other matters, discusses local, regional and national foreclosure and economic trends,
which supports its judgment related to this prospective analysis. The weighting between the components of historic losses and prospective
loss factors are determined by management based on performance expectations.

The Company will include
the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.

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

Part I. Financial Information

Item 1. Financial Statements

Notes to Condensed Consolidated Financial
Statements (Unaudited)

General

 3. Please revise future filings to address the disclosure requirements of ASC 855-10 concerning
subsequent events.

    Mr. John P. Nolan
January 8, 2013
Page 3 of 6

RESPONSE: There
were no subsequent events to be disclosed in the Company’s Form 10-Q for the fiscal period ended June 30, 2012 in accordance
with the requirements of ASC 855-10. However, to the extent applicable, the Company will disclose such subsequent events in future
filings with the Commission.

 4. Please consider revising future filings to group footnotes next to each other that include further
disclosure for similar financial statements items. For example, please consider grouping footnotes E and J next to each other,
which include additional disclosures for loans and impaired loans and the allowance for loan losses.

RESPONSE: The
Company will plan to group footnotes that include further disclosure for similar financial statement items next to each other in
its future filings, as suggested by the Staff.

Note D – Fair Value Instruments
Measured at Fair Value, page 10

 5. Please consider revising future filings to separately present, in a tabular format, assets and
liabilities measured at fair value using recurring fair value measurements and assets and liabilities measured at fair value using
nonrecurring fair value measurements.

RESPONSE: The
Company believes the tabular format in Note D with added disclosure for recurring fair value measurements as amended below in footnotes
3 and 4 addresses this comment.

Under ASC 820, fair
value measurements for items measured at fair value on a recurring and nonrecurring basis at June 30, 2012 and 2011 included:

(Dollars in thousands)

    Fair Value
Measurements
    Quoted

Prices in

Active

Identical

Assets
(Level 1)
    Significant

Other

Observable

Inputs
(Level 2)
    Significant

Unobservable

Inputs
(Level 3)

    June 30, 2012

    Available for sale securities (3)
    $ 562,691
    $ 1,714
    $ 560,977
    $ 0

    Loans available for sale (4)
      11,186
      0
      11,186
      0

    Loans (1)
      34,468
      0
      12,802
      21,666

    Other real estate owned (2)
      7,219
      0
      1,783
      5,436

June 30, 2011

    Available for sale securities (3)
    $ 611,231
    $ 4,224
    $ 607,007
    $ 0

    Loans available for sale (4)
      4,758
      0
      4,758
      0

    Loans (1)
      32,124
      0
      10,873
      21,251

    Other real estate owned (2)
      25,877
      0
      2,553
      23,324

____________

 (1) See Note E. Nonrecurring fair value adjustments to
loans identified as impaired reflect full or partial write-downs that are based on the loan’s observable market price or
current appraised value of the collateral in accordance with ASC 310.

 (2) Fair value is measured on a nonrecurring basis in
accordance with ASC 360.

 (3) See Note H for further detail of recurring fair value
basis of individual investment categories.

 (4) Recurring fair value basis determined using observable
market data.

The Company will include
the applicable information in the table above as requested in the Staff’s comments above in its future filings with the Commission.

    Mr. John P. Nolan
January 8, 2013
Page 4 of 6

 6. Please tell us and revise future filings to disclose a description of the valuation technique(s)
and the inputs used in the fair value measurement for recurring and nonrecurring fair value measurements categorized within Level
2 and Level 3 of the fair value hierarchy in accordance with ASC 820-10-50-2-bbb.

RESPONSE: The
fair value of impaired loans, which are not troubled debt restructurings (TDRs), is based on recent real estate appraisals less
estimated costs of sale. For residential real estate impaired loans, appraised values or internal evaluation are based on the comparative
sales approach. These impaired loans are considered a Level 2 in the fair value hierarchy. For commercial and commercial real estate
impaired loan, evaluators may use either a single valuation approach or a combination of approaches, such as comparative sales,
cost and/or income approach. A significant unobservable input in the income approach is the estimated capitalization rate for a
given piece of collateral. At June 30, 2012, the range of capitalization rates utilized to determine fair value of the underlying
collateral ranged from 8% to 9%. Adjustments to comparable sales may be made by an appraiser to reflect local market conditions
or other economic factors and may result in changes in the fair value of a given asset over time. As such, the fair value of these
impaired loans is considered a Level 3 in the fair value hierarchy.

Fair value of available
for sale securities are determined using valuation techniques for individual investments as disclosed in Note H.

The Company will include
the additional disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.

 7. Please revise future filings to include the disclosure requirements of ASC 820-10-50-2E for
each class of assets and liabilities not measured at fair value in the statement of financial position but for which the fair value
is disclosed.

RESPONSE: The
carrying value amount and fair values for other financial instruments that are not measured at fair value on a recurring basis
in the balance sheet at June 30, 2012 are as follows:

    June 30, 2012

    Carrying
    Fair Value Level

    (Dollars in thousands)
    Amount
    Level 1
    Level 2
    Level 3
    Total

    Assets:

    Securities held to maturity
    $ 17,122
    $ 0
    $ 17,799
    $ 0
    $ 17,799

    Loans, net
      1,196,719
      0
      1,204,843
      21,666
      1,226,509

    Loans held for sale
      11,186
      0
      11,186
      0
      11,186

    Liabilities:

    Deposits
      1,689,584
      0
      1,691,984
      0
      1,691,984

    Borrowings
      189,489
      0
      195,123
      0
      195,123

    Long-term debt
      53,610
      0
      0
      32,166
      32,166

The Company will include the additional
disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.

Item 2. Management’s Discussion
and Analysis of Financial Condition and Results of Operations

Allowance for Loan Losses, page 47

    Mr. John P. Nolan
January 8, 2013
Page 5 of 6

 8. We note your disclosure on pages 47-51 discussing the trends in the loan portfolio and allowance
for loan losses during 2012. Please tell us in detail and revise future filings to more comprehensively bridge the gap between
the changes in the credit quality of your loan portfolio and the amount of your provision for loan loss recorded during the period
and the amount of the allowance for loan losses at period end. Your analysis should quantify each component of your allowance for
loan losses (ASC 310-10, 450-20) and the applicable loan portfolio for each component and should explain how you determined that
each component was directionally consistent with the underlying credit quality of the applicable loan portfolio. Please be as specific
and detailed as necessary to provide an investor with a clear understanding of the observed changes in credit quality in each applicable
loan portfolio and how these changes, as well as any other key drivers, impacted each component of the allowance for loan losses.

RESPONSE: The
reduced level of impaired loans and lower classified loans (special mention and substandard grades) contributed to a lower risk
of loss and the lower allowance for loan losses as of June 30, 2012 compared to a year ago. The risk profile for the loan portfolio
has been reduced by strengthening credit management methodologies and implementing a low-risk “back-to-basics” strategic
plan for loan growth.

New loan production has shifted to adjustable
rate residential real estate loans, owner-occupied commercial real estate and small business loans for professionals and businesses,
and consumer lending. Strategies, processes and controls are in place to ensure that new loan production is well underwritten and
maintains a focus on smaller, more diversified and lower-risk lending.

Aided by initiatives embodied in new loan
programs and continued aggressive collection actions, the portfolio mix has changed dramatically and has become more diversified.
The improved mix is most evident by the significant reductions in the income producing commercial real estate and construction
and land development portfolios over the last several years, as demonstrated by the following table:

    (Dollars in thousands)
      6/30/2010
      6/30/2011
      6/30/2012

    Special Mention Loans
      53,126
      65,633
      40,990

    Substandard Loans
      6,306
      6,254
      22,993

    Total Criticized & Classified Loans
      59,432
      71,887
      63,983

    Special Mention Loans
      20.13 %
      26.90 %
      17.60 %

    Substandard Loans
      2.39 %
      2.56 %
      9.88 %

    Total Crit. & Classified Loans % Tier 1 & ALLL
      22.52 %
      29.46 %
      27.48 %

    Total Impaired Loans
      157,361
      106,403
      103,324

    Total Non-Performing Assets
      109,903
      72,042
      55,701

    Total Loans + OREO
      1,319,618
      1,214,822
      1,228,573

    NPA %
      8.33 %
      5.93 %
      4.53 %

    Mr. John P. Nolan
January 8, 2013
Page 6 of 6

The Company will include the additional
disclosure requested in the Staff’s comments above in its future filings with the Commission, as applicable.

In connection with these responses to the Staff’s comment
letter, the Company acknowledges 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 any 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.

We appreciate your consideration of this
matter. If you have any additional questions please do not hesitate to contact me at 772-221-2825.

Sincerely,

/s/ William R. Hahl

William R. Hahl

Executive Vice President and Chief Financial
Officer

Seacoast Banking Corporation of Florida

September 26, 2012

Via Email
Mr. William R. Hahl
Executive Vice President and Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, Florida  34994

Re: Seacoast Banking Corporation  of Florida
 Form 10-K/A for the Year Ended December 31, 201 1
Filed March 26 , 2012
Form 10 -Q for the Quarter  Ended June 30 , 2012
Filed August 8 , 2012
File No. 000-13660

Dear Mr. Hahl :

We have reviewed your filing s and have the following comments.  In some of our
comments, 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 s, by
providing the requested  information, or by advising us when you will provide the requested
response.   Where we have asked for revisions , please include a draft of your proposed
disclosures that clearly identifies new or revised disclosures.   If you do not believe our comments
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 s and the information you provide in
response to these  comments, we may have  additional c omments.

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

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Allowance and Provision for Loan Losses, page 6

1. We note your disclosure on page 8 that you consider historical losses for the graded loan
portfolio based on historical migration of actual losses by grade and a range of losses
over various periods.  Please tell us and revise future flings to disclose mor e specifically
the historical periods specifically considered in your analysis. In your disclosure, include

Mr. William R. Hahl
Seacoast Banking Corporation of Florida
September 26, 2012
Page 2

 additional granularity regarding any adjustments made to historical losses and, if
applicable, discuss the specific facts and circumstances that is the basis for such
adjustments.

2. We also note that you consider historical losses over the prior 12 months for non -graded
loan portfolios .  Please tell us and revise future filings to disclose how you consider
historical losses greater than 12 months when determining the general allowance for these
loan portfolios .  Please be specific, especially in light of the significant charge -offs and
provisions for loan losses in prior periods.

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

Part I.  Financial I nformation
Item 1.  Financial Statements
Notes to Condensed Consolidated Financial Statements (Unaudited)

General

3. Please revise future filings to address the disclosure requirements of ASC 855 -10
concerning subsequent events.

4. Please consider revising future filings to group footnotes next to each other that include
further disclosure for similar financial statements items.  For example, please consider
grouping footnotes E and J next to each other, which include additional disclosures for
loans and imp aired loans and the allowance for loan losses.

Note D – Fair Value Instruments Measured at Fair Value, page 10

5. Please consider revising future filings to separately present, in a tabular format, assets
and liabilities measured at fair value using recurri ng fair value measurements and assets
and liabilities measured at fair value using nonrecurring fair value measurements.

6. Please tell us and revise future filings to disclose a description of the valuation
technique(s) and the inputs used in the fair value  measurement  for recurring and
nonrecurring fair value measurements categorized within Level 2 and Level 3 of the fair
value hierarchy in accordance with ASC 820 -10-50-2-bbb.

7. Please revise future filings to include the disclosure requirements of ASC 820 -10-50-2E
for each class of assets and liabilities not measured at fair value in the statement of
financial position but for which the fair value is disclosed .

Mr. William R. Hahl
Seacoast Banking Corporation of Florida
September 26, 2012
Page 3

 Item 2.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Allowance for Loan Losses, page 47

8. We note your disclosure on pages 47 -51 discussing the trends in the loan portfolio and
allowance for loan losses during 2012.  Please tell us in detail and revise future filings to
more comprehensively bridge the gap be tween the changes in the credit quality of your
loan portfolio and the amount of your provision for loan loss recorded during the period
and the amount of the allowance for loan losses at period end.  Your analysis should
quantify each component of your al lowance for loan losses (ASC 310 -10, 450 -20) and
the applicable loan portfolio for each component and should explain how you determined
that each component was directionally consistent with the underlying credit quality of the
applicable loan portfolio.  P lease be as specific and detailed as necessary to provide an
investor with a clear understanding of the observed changes in credit quality in each
applicable loan portfolio and how these changes, as well as any other key drivers,
impacted each component of  the allowance for loan losses.

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 responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comments, 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.

Mr. William R. Hahl
Seacoast Banking Corporation of Florida
September 26, 2012
Page 4

 You may contact David Irving  at (202) 551 -3321  or John P. Nolan  at (202) 551 -3492  if
you have any questions.

Sincerely,

 /s/ John P. Nolan

John P. Nolan
Senior Assistant Chief Accountant

CORRESP
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corresp

Seacoast Banking Corporation of Florida

815 Colorado Avenue

Stuart, Florida 34994

July 20, 2010

VIA E-MAIL

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Seacoast Banking Corporation of Florida

Registration Statements on Form S-1

Filed July 20, 2010

File No. 333-167050 and 333-167051

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities
Act”), Seacoast Banking Corporation of Florida (the “Registrant”) hereby requests that
the effectiveness of the registration statement on Form S-1 (File No. 333-167050) and of the
registration statement on Form S-1 (File No. 333-167051) (together, the “Registration
Statements”) be accelerated so that they become effective at
4:30 p.m. (New York City time) on
July 22, 2010 or as soon thereafter as is practicable.

     The Registrant hereby confirms that it is aware of its obligations under the Securities Act
and the Securities Exchange Act of 1934, as amended, with respect to the registration of the
securities specified in the Registration Statements.

     The disclosure in the Registration Statements is the responsibility of the Registrant. The
Registrant represents to the United States Securities and Exchange Commission (“SEC”) that
should the SEC or its staff, acting pursuant to delegated authority, declare the Registration
Statements effective, it does not foreclose the SEC from taking any action with respect to the
Registration Statements and the Registrant represents that it will not assert this action as a
defense in any proceeding initiated by the SEC or any person under the federal securities laws of
the United States. The Registrant further acknowledges that the action of the SEC or its staff,
acting pursuant to delegated authority, in declaring the Registration Statements effective does not
relieve the Registrant from its full responsibility for the adequacy and accuracy of the
disclosures in the Registration Statements.

     Please confirm that the Registration Statements have been declared effective by telephoning
Chip MacDonald of Jones Day at (404) 581-8622.

     Thank you for your attention to this matter.

    Very truly yours,

SEACOAST BANKING CORPORATION OF FLORIDA

    By:
    /s/ Dennis S. Hudson, III

    Name:
    Dennis S. Hudson, III

    Title:
    Chairman and Chief Executive Officer

    cc:

    Chip MacDonald, Esq.

Jones Day

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

       DIVISION OF
CORPORATION FINANCE

                July 20, 2010
By U.S. Mail and facsimile to (772) 288-6012

William R. Hahl Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue Stuart, FL  34994
Re:  Seacoast Banking Corporation of Florida
 Form 10-K for the Fiscal Year Ended December 31, 2009  Form 10-Q for the Fiscal  Quarter Ended March 31, 2010
 File No. 000-13660
 Dear Mr. Hahl:
We have completed our review of your Fo rm 10-K and related filings and have no
further comments at this time.
Sincerely,

        Hugh West         B r a n c h  C h i e f

CORRESP
1
filename1.htm

corresp

SEACOAST BANKING CORPORATION OF FLORIDA

815 COLORADO AVENUE • STUART, FLORIDA 34994

TELEPHONE: (772) 288-6086 • FACSIMILE: (772) 288-6012

July 14, 2010

VIA FACSIMILE AND EDGAR

Mr. Michael R. Clampitt

Mr. Matt McNair

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Seacoast Banking Corporation of Florida

Registration Statement on Form S-1

Filed May 24, 2010

File No. 333-167050

Dear Mr. Clampitt and Mr. McNair:

     We have reviewed your letter dated June 14, 2010 by which the staff (the “Staff”) of
the Securities and Exchange Commission (the “SEC”) provided comments to the Registration
Statement (the “Registration Statement”) on Form S-1 (File No. 333-167050) filed by
Seacoast Banking Corporation of Florida (the “Company”) on May 24, 2010. This letter sets
forth the Company’s responses to the Staff’s comments.

General

    1.

    We note that you entered into two separate private placement transactions prior to filing the
above-noted registration statement; one in December 2009 and one in April 2010. We also note
that you did not file notices of sale on Form D to report these transactions even though it
appears that you may have relied on Regulation D to complete the transactions. Please tell us
how you determined that you were not required to file a Form D for each private placement. In
this regard, please tell us the number of purchasers in the offerings. Refer to Rule 503 of
Regulation D.

    RESPONSE: Although the Company filed a Current Report on Form 8-K in connection with each
of the December 2009 and April 2010 private placements, the Company inadvertently failed to
file notices of sale on Form D in connection with the private placements. One purchaser
participated in the December 2009 private placement; and purchasers represented by 16 separate investor groups participated in the April 2010 private placement. On June 15,
2010, the day after the Company became aware of this
oversight, the Company filed notices of sale on Form D to separately report each of the
private placements. In connection with any applicable future transactions, the Company will
promptly file all required notices of sales on Form D as required by Rule 503 of Regulation
D.

Mr. Clampitt and Mr. McNair

U.S. Securities and Exchange Commission

July 14, 2010

Page 2

Incorporation by Reference, page iv

    2.

    The Form 10-K/A which has been incorporated by reference does not contain financial
statements for your latest fiscal year. Please revise. Refer to Item 12(a)(1) of Form S-1.

    RESPONSE: On July 14, 2010, the Company filed a registration statement on
Form S-1/A in which it incorporated by reference both its Annual Report on Form 10-K, filed
with the SEC on March 23, 2010, and its Annual Report on Form 10-K/A, filed with the SEC on
May 18, 2010.

Prospectus Summary, page 1

    3.

    Please include in this section a brief summary of the offering and describe how the
securities were acquired by the selling shareholders, the market price of the common stock on
the date(s) of acquisition, the effective purchase price for the common stock (on an as
converted basis) and when the securities will be converted to common shares. Also disclose
the conversion price.

    RESPONSE: On July 14, 2010, the Company filed a registration statement on
Form S-1/A in which it included, in the Prospectus Summary section, (i) a brief summary of
the offering; (ii) a description of (A) how the securities were acquired by the selling
shareholders, (B) the market price of the common stock on the date(s) of acquisition, (C)
the effective purchase price for the common stock (on an as converted basis) and (D) when
the securities will be converted to common shares; and (iii) disclosure regarding the
conversion price.

Mr. Clampitt and Mr. McNair

U.S. Securities and Exchange Commission

July 14, 2010

Page 3

Risk Factors, page 6

    4.

    We note that at the annual meeting of shareholders to be held on June 22, 2010, you are
seeking approval to permit the board of directors to effect a reverse stock split of your
common stock at one of seven reverse split ratios. Please add a risk factor that describes
the affect such a reverse split will have on existing shareholders as well as the selling
shareholders at each of the proposed split ratios. Please also disclose whether all
outstanding shares will be subject to the reverse stock split, including common shares held or
to be acquired by CapGen Capital Group III LP.

    RESPONSE: On July 14, 2010, the Company filed a registration statement on
Form S-1/A in which it added a risk factor that describes the affect a reverse split will
have on existing shareholders as well as the selling shareholders at each of the proposed
split ratios. In the registration statement on Form S-1/A, the Company also disclosed that
all outstanding shares will be subject to the reverse stock split, including common shares
held or to be acquired by CapGen Capital Group III LP. All proposals considered at the
Company’s annual meeting were approved.

Recent Developments, page 9

    5.

    Upon completion of the annual meeting of shareholders to be held on June 22, 2010, please
revise to disclose whether or not shareholders approved proposals two, four and five of the
definitive proxy statement filed on May 20, 2010.

    RESPONSE: On June 22, 2010, the Company filed a registration statement on
Form S-1/A in which it disclosed that its shareholders have approved proposals two, four and
five of the definitive proxy statement filed on May 20, 2010.

    6.

    To the extent material, please revise to discuss the company’s performance since March 31,
2010. Include a discussion of whether non-performing loans have increased since the end of
the first quarter and, if so, the amount by which they have increased.

    RESPONSE: Based on preliminary, unaudited financial results for the three months ended June
30, 2010, the Company does not believe that its performance since March 31, 2010 has changed
materially, other than as a result of $23.0 million of loans sold by the Company in the most
recent period. No sales of loans were made in the first three months of 2010. The
Company’s nonperforming assets (loans and other real estate owned) were $115.0 million at
March 31, 2010, which decreased $5.0 million to $110.0 million at June 30, 2010, as a result
of the loan sales and additions to non-performing loans in the ordinary course of business.
The allowance for loan losses is estimated to be
approximately $40.0 million or 3.08% of loans at June 30, 2010, compared to $43 million or
3.18% of loans at March 31, 2010.

Mr. Clampitt and Mr. McNair

U.S. Securities and Exchange Commission

July 14, 2010

Page 4

         The Company’s loan sales in the most recent three months ended June 30, resulted in
approximately $10.0 million of loan charge-offs. Preliminary results of operations for the
second quarter include a provision for loan losses of approximately $16.8 million compared
to $2.1 million for the first quarter. The increase in the provision was necessary as a
result of the losses from the loan sales. Further, primarily as a result of the losses on
the loans sold, the Company’s preliminary net loss for the second quarter will be
approximately $13.8 million, an increase from the $1.5 million in the first quarter of 2010
when no loans were sold, but substantially less than in each of the second, third and fourth
quarters of 2009.

    7.

    Please identify the selling shareholders and provide all of the information required by Item
507 of Regulation S-K in your next pre-effective amendment. In addition, please advise the
staff of the company’s basis for determining that the transaction is appropriately
characterized as a transaction that is eligible to be made under Rule 415(a)(1)(i). In your
analysis, please address the following among any other relevant factors:

    •

    The number of shares being registered relative to the number of shares outstanding
held by non-affiliates;

    •

    How long the selling shareholders have held the shares;

    •

    The number of selling shareholders and the percentage of the overall offering made
by each shareholder;

    •

    Whether the selling shareholders were investors in the company’s common stock prior
to investing in the Series B Preferred Stock;

    •

    The relationship of each selling shareholder with the company, including an analysis
of whether the selling shareholder is an affiliate of the company;

    •

    Any relationships among the selling shareholders; and

    •

    Whether or not any of the selling shareholders is in the business of underwriting
securities.

Mr. Clampitt and Mr. McNair

U.S. Securities and Exchange Commission

July 14, 2010

Page 5

RESPONSE: On July 14, 2010, the Company filed a registration statement on
Form S-1/A in which it identified the selling shareholders and provided all of the
information required by Item 507 of Regulation S-K.

     We have reviewed the Staff’s historical guidance on PIPE transactions as articulated in
the Securities Act Rules Compliance and Disclosure Interpretations Question 612.09
(“C&DI 612.09”), which states, in pertinent part:

     “The question of whether an offering styled a secondary one is really on behalf
of the issuer is a difficult factual one, not merely a question of who receives the
proceeds. Consideration should be given to how long the selling shareholders have
held the shares, the circumstances under which they received them, their
relationship to the issuer, the amount of shares involved, whether the sellers are
in the business of underwriting securities, and finally, whether under all the
circumstances it appears that the seller is acting as a conduit for the issuer.”

     We understand that since late 2006, the Staff has raised concerns that following a PIPE
transaction, selling shareholders may be acting as underwriters and that the resale shelf
registration statement is an indirect primary offering where a significant percentage, such
as greater than one-third of the public float, is sought to be registered for
resale.1

     We have reviewed the factors in the Staff’s comment and other relevant factors,
including C&DI 612.09. The totality of the facts and circumstances in this case demonstrate
that the selling shareholders listed in the Registration Statement are not acting as
underwriters or conduits for the Company. Although 34,482,758 shares of common stock are
covered by the Registration Statement, or approximately 103.8% of the 33,208,778 shares of
common stock held by non-affiliates of the Company as of May 24, 2010 (the “Public
Float”), we respectfully submit that these facts are not determinative. The number and
percentage of shares results from the declining market prices for the Company’s shares, as
has been the case for many financial services companies. In order to maintain adequate
capital for bank regulatory purposes, the Company, as well as many others in its industry,
have had to sell more shares due to declining shares prices in the market and are outweighed
by the following:

    •

    none of the selling shareholders is a member of a “group” with any other
selling shareholder within the meaning of Section 13(d)(3) of the
Securities Exchange Act of 1934, as amended;

    1

    Charles J. Johnson, Jr. and Joseph McLaughlin,
Corporate Finance and the Securities Laws (4d), 2007 Supplement Section
7.10[D]. Aspen Publishers, 2007.

Mr. Clampitt and Mr. McNair

U.S. Securities and Exchange Commission

July 14, 2010

Page 6

    •

    the selling shareholders are not in the business of underwriting
securities, however, many are limited by the Investment Company Act of 1940
(the “ICA”) or their investment policies as to the amount of
“restricted securities” their funds can hold at any time, leading to a
desire to register such shares for resale;

    •

    many of the selling shareholders were or had been shareholders of the
Company over long periods of time;

    •

    for bank regulatory reasons, the offering was directed to existing
Company shareholders;

    •

    the April 2010 offering occurred to provide additional capital to the
Company and to its Bank subsidiary in a time when many community and
regional banks, especially in the Company’s primary market of Florida,
needed capital;

    •

    one selling shareholder is an affiliate of the Company, as a shareholder
and through service on the Company’s Board of Directors (the
“Board”). Such selling shareholder is a bank holding company which
“controls” the Company and its subsidiary bank (the “Bank”) and
therefore has obligations under the federal Bank Holding Company Act of
1956, as amended (the “BHC Act”) to serve as a “source of financial
strength” to the Bank. None of the other selling shareholders are
“affiliates” of the Company because, as an affiliate, they would become
subject to the BHC Act, which they cannot be;

    •

    the contractual and market-related circumstances under which the selling
shareholders purchased the registrable securities;

    •

    other than purchasers managed as part of the same fund complex, the
Company is unaware of any relationships among the selling shareholders; and

    •

    other policy considerations that, in the current environment, support
facilitating the registration of resales of shares purchased from community
and regional bank holding companies in private transactions.

Mr. Clampitt and Mr. McNair

U.S. Securities and Exchange Commission

July 14, 2010

Page 7

     Taken together, the totality of the facts and the circumstances surrounding the April
2010 offering demonstrate that the resales sought to be registered on the Registration
Statement are not an offering “by or on behalf of” the
Company under Rule 415(a)(4). The Company respectfully submits that the offering contemplated by the
Registration Statement is “solely by or on behalf of persons other than the registrant, a
subsidiary of the registrant or a person of which the registrant is a subsidiary” and
therefore is permitted by Rule 415(a)(1)(i).

     Set forth below, please find responses to the specific points raised by the Staff in
its comment letter.

    1.

    The number of shares being registered relative to the number of shares
outstanding held by non-affiliates.

     The amount of registrable securities registered under the Registration Statement
represents approximately 103.8% of the 33,208,778 shares of common stock held by
non-affiliates as of May 24, 2010. Despite representing a relatively large portion of the
Company’s public float, this is indicative of the greatly depressed market prices for common
stock of community and regional bank holding companies, especially in markets such as the
State of Florida, where the Company is located, and where the local economies have been most
affected by crises in the financial and real estate markets.

     In addition, regardless of the percentage of public float represented, we believe the
proper inquiry regarding whether the offering should be deemed to be a primary offering is
whether the Registration Statement contemplates the resale of securities acquired from the
Company by legitimate investors who assumed the market risk for their investment.

     We understand that for several years the Staff has become increasingly concerned about
public resales of securities purchased in “toxic” PIPE transactions. These transactions
typically include convertible securities whose conversion price floats relative to the
market price of the underlying stock. Public announcement of these transactions can put
downward pressure on the stock price, increasing the number of shares issuable to the new
investors and reducing the value of stock held by existing investors. To discourage these
toxic transactions and limit

CORRESP
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SEACOAST BANKING CORPORATION OF FLORIDA

815 COLORADO AVENUE • STUART, FLORIDA 34994

TELEPHONE: (772) 288-6086 • FACSIMILE: (772) 288-6012

July 14, 2010

VIA FACSIMILE AND EDGAR

Mr. Michael R. Clampitt

Mr. Matt McNair

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Seacoast Banking Corporation of Florida

Registration Statement on Form S-1

Filed May 24, 2010

File No. 333-167051

Dear Mr. Clampitt and Mr. McNair:

     We have reviewed your letter dated June 14, 2010 by which the staff (the “Staff”) of
the Securities and Exchange Commission (the “SEC”) provided comments to the Registration
Statement (the “Registration Statement”) on Form S-1 (File No. 333-167051) filed by Seacoast Banking Corporation
of Florida (the “Company”) on May 24, 2010. This letter sets forth the Company’s responses
to the Staff’s comments.

Incorporation by Reference, page iv

    1.

    The Form 10-K/A which has been incorporated by reference does not contain financial
statements for your latest fiscal year. Please revise. Refer to Item 12(a)(1) of Form S-1.

    RESPONSE: On July 14, 2010, the Company filed a registration statement on Form S-1/A in
which it incorporates by reference both its Annual Report on Form 10-K, filed with the SEC
on March 23, 2010, and its Annual Report on Form 10-K/A filed with the SEC on May 18, 2010.

Recent Developments, page 9

    2.

    To the extent material, please revise to discuss the company’s performance since March 31,
2010. Include a discussion of whether non-performing loans have
increased since the end of the first quarter and, if so, the amount by which they have
increased.

Mr. Clampitt and Mr. McNair

July 14, 2010

Page 2

    RESPONSE: Based on preliminary, unaudited financial results for the three months ended June
30, 2010, the Company does not believe that its performance since March 31, 2010 has changed
materially, other than as a result of $23.0 million of loans sold by the Company in the most
recent period. No sales of loans were made in the first three months of 2010. The
Company’s nonperforming assets (loans and other real estate owned) were $115.0 million at
March 31, 2010, which decreased $5.0 million to $110.0 million at June 30, 2010, as a result
of the loan sales and additions to non-performing loans in the ordinary course of business.
The allowance for loan losses is estimated to be approximately $40.0 million or 3.08% of
loans at June 30, 2010, compared to $43 million or 3.18% of loans at March 31, 2010.

         The Company’s loan sales in the most recent three months ended June 30, resulted in
approximately $10.0 million of loan charge-offs. Preliminary results of operations for the
second quarter include a provision for loan losses of approximately $16.8 million compared
to $2.1 million for the first quarter. The increase in the provision was necessary as a
result of the losses from the loan sales. Further, primarily as a result of the losses on
the loans sold, the Company’s preliminary net loss for the second quarter will be
approximately $13.8 million, an increase from the $1.5 million in the first quarter of 2010
when no loans were sold, but substantially less than in each of the second, third and fourth
quarters of 2009.

Selling Stockholders, page 21

    3.

    Please provide all of the information required by Item 507 of Regulation S-K in your next
pre-effective amendment.

    RESPONSE: On July 14, 2010, the Company filed a registration statement on Form S-1/A in
which it provided all of the information required by Item 507 of Regulation S-K.

    4.

    Please confirm that the selling shareholder is a reporting company under the Exchange Act, a
majority-owned subsidiary of a reporting company under the Exchange Act, or a registered
investment fund under the 1940 Act. If not, you must identify the natural person or persons
having voting and investment control over the securities held. Please revise accordingly.

    RESPONSE: On July 14, 2010, the Company filed a registration statement on Form S-1/A in
which it identified the natural person or persons having voting and investment control over
the securities held. We note that the selling shareholder is not a reporting company under
the Securities Exchange Act of 1934, as amended (the “Exchange Act”),
a majority-owned subsidiary of a reporting company under the Exchange Act, or a registered
investment fund under the 1940 Act.

Mr. Clampitt and Mr. McNair

July 14, 2010

Page 3

General

    5.

    We may have additional comments on this filing after reviewing your responses to our comment
letter on the registration statement on Form S-1 relating to the Series B preferred stock
conversion (File No. 333-167050).

    RESPONSE: In addition to this response letter and the amendment to the registration
statement on Form S-1 to which it relates (File No. 333-167051), the Company has provided a
separate response letter and amended its registration statement on Form S-1 relating to the
Series B preferred stock conversion (File No. 333-167050) in response to the SEC’s separate
comment letter received on June 14, 2010.

* * *

    Please contact me at (772) 287-4000 if you have any questions regarding our responses.

    Sincerely,

/s/ Dennis S. Hudson, III

    Dennis S. Hudson, III

Chief Executive Officer

cc: Ralph F. MacDonald III, Esq. (Jones Day)

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July 13, 2010

Mr. Hugh West

Branch Chief

United States Securities and Exchange Commission

Washington, D.C. 20549

    RE:

    Seacoast Banking Corporation of Florida

Form 10-K for the Fiscal Year Ended December 31, 2009

Form 10-Q for the Fiscal Year Ended March 31, 2010

File No. 000-13660

Dear Mr. West:

SEC Comment

Management’s Discussion and Analysis

Nonperforming Assets, page 9

    1.

    Please revise your future filings to quantify the types of concessions made (e.g. rate
reductions, payment extensions, forgiveness of principal, forbearance or other actions)
concerning troubled debt restructurings and discussion of your success with the different type
of concessions. Show us what your disclosure will look like in your response.

Response

Troubled debt restructurings (“TDRs”) at December 31, 2009 by type of concession change and
delinquency after restructuring included:

    TDRs 30 days and

    (In thousands)

    greater past due

    Rate reductions

    $
    16,854

    $
    0

    Maturity extended

    76,238

    12,613

    Forgiveness of principal

    2,688

    88

    Other

    275

    275

    $
    96,055

    $
    12,976

It is the Company’s policy to only enter into TDRs after a full underwriting of the loan customer
with current credit information. The Company’s experience with redefaults to date has been limited
for all type of concessions. However, given the continued economic stress it is probable that some
TDRs will likely redefault in the future. The Company will revise future filings to include this
information.

SEC Comment

    2.

    We note your disclosure on page 55 that you modify certain loans that are not considered
TDRs. Please describe the types of modifications performed and explain your rationale for not
classifying them as TDRs. In this regard, specifically tell us whether you have performed any
loan modifications that you consider to be short term in nature (and provide your definition
of short term) and therefore concluded that TDR classification was not required.

Response

Loans may be modified from time-to-time to retain borrowers that meet the Bank’s credit quality
goals. It is the Company’s policy to classify a loan renewal or modification as a TDR when the
customer is experiencing financial difficulties and a concession is granted that would not
otherwise be considered. This determination is made after full and complete current financial
information is obtained. Modifications that are not TDRs may include an interest rate reduction
that reflects a general decline in market interest rates, an extension of maturity or a minor
payment schedule adjustment that aligns with Company policy and reflects terms that are available
in the market at the time. Therefore, renewals and modifications that are in accordance with
current market conditions and loan policy requirements where no concession is granted are not
classified as TDRs. The Company will revise future filings to include this information.

SEC Comment

    3.

    Please tell us and revise your future filings to disclose whether you have performed any CRE
workouts whereby an existing loan was restructured into multiple new loans (i.e., A Note/B
Note structure). To the extent that you have performed these types of CRE workouts, please
provide us with and revise your future filings to disclose the following:

    •

    Quantify the amount of loans that have been restructured using this type of workout
strategy in each period presented;

    •

    Discuss the benefits of this workout strategy, including the impact on interest
income and credit classification;

2

    •

    Discuss the general terms of the new loans and how the A note and B note differ,
particularly whether the A note is underwritten in accordance with your customary
underwriting standards and at current market rates;

    •

    Clarify whether the B note is immediately charged-off upon restructuring. If not,
clarify whether you combine the restructured notes in your evaluation of whether the
notes should be returned to accrual status;

    •

    Confirm that the A note is classified as a TDR and explain your policy for removing
such loans from TDR classification; and

    •

    Clarify your policy for returning the A note to accrual status, including how you
consider the borrower’s payment performance prior to the restructuring.

Response

To date, the use of multiple note structures to resolve problem loans has not been material, but
use of this structure could increase in future periods. At December 31, 2009 the Company had only one
A/B note restructuring for a total of $14 million. The Company does not believe this to be
material to its TDR disclosures, but will provide in future filings the disclosures suggested if
this type of restructuring becomes material in the future.

SEC Comment

    4.

    Please tell us and consider revising your future filings to disclose, whether you have
noticed an increase in any loan categories such as commercial real estate or construction
loans that have been extended at maturity for which you have not considered the loans to be
impaired due to the existence of guarantees. If so, provide us with the following information
and consider enhancing your disclosure in future filings accordingly:

    •

    The types of extensions being made, whether loan terms are being adjusted from the
original terms, and whether you consider these types of loans as collateral-dependent;

    •

    To the extent you extend commercial loans at or near maturity at the existing loan
rate due to the existence of a guarantee, tell us how you consider whether it is a
troubled debt restructuring;

    •

    In detail, how you evaluate the financial wherewithal of the guarantor, addressing
the type of financial information reviewed, how current and objective the information
reviewed is, and how often the review is performed;

3

    •

    How many times you have sought performance under the guarantee discussing the
extent of the successes. As part of your response, discuss the decision making
process you go through in deciding whether to pursue the guarantor and whether there
are circumstances you would not seek to enforce the guarantee; and

    •

    Quantify the dollar amount of commercial loans in which your carrying value is in
excess of the appraised value but not considered impaired due to the existence of
guarantees.

Response

Upon maturity of our loans, each loan is evaluated based on current polices, credit quality
expectations, loan-to-value guidelines and offering of and capacity of guarantors, endorsers and
co-makers. The evaluation of the borrower and all parties to the transaction includes full and
appropriate financial disclosure and of all assets, and analysis of direct debts and all contingent
liabilities.

The Bank has not seen an increase in any loan category that has been extended at maturity, which
was considered not impaired due to the existence of guarantees. There were only two loans totaling
$1.69 million that were extended at maturity for which the carrying value of the loan was in excess
of the appraised value of the collateral, but where the loan was considered not impaired given the
existence of guarantor support.

If there is an increase in this type of extensions in the future, we will add the suggested
disclosures to our future filings.

SEC Comment

Notes to Consolidated Financial Statements

Note R — Fair Value, page 81

    5.

    Please address and disclose the following as it relates to your appraisal policies:

    •

    When the Company does not have a new appraisal on file, describe in more detail the
procedures performed by your Credit Officers and Special Assets Officers in
determining whether the assumptions reflected in these original appraisals are
reflective of current market conditions, particularly for those appraisals that are
more than a year old;

    •

    Describe the procedures performed at each balance sheet date to determine the fair
value of collateral-dependent impaired loans and OREO. Tell us how you define
collateral dependent loans. In determining the fair value address whether you make
adjustments to original appraisals to take into consideration current market
conditions. If so, describe the types of adjustments made. Alternatively, if you
perform an internal valuation to estimate fair value,

4

    please describe the valuation approaches used, the significant assumptions used in each
model, and if multiple valuation approaches are used, the relative weighting of each
model. Clarify whether you make any adjustments to current appraisals and if so,
describe the types of adjustments made and the reasons for such adjustments;

    •

    When you receive new appraisals, describe the type of appraisals received, such as
“retail value” or “as is value”;

    •

    Address how partially charged-off loans measured for impairment based on the
collateral value are classified and accounted for subsequent to receiving an updated
appraisal. For example, disclose whether the loans are returned to performing status
or whether they remain as nonperforming;

    •

    Address the typical timing surrounding the recognition of a loan as nonaccrual and
recording of any provision or charge-off;

    •

    Address the procedures performed between receipt of updated appraisals to ensure
impairment of loans measured for impairment based on collateral value are measured
appropriately; and

    •

    Address how you determine the amount to charge-off.

Response

All impaired loans are reviewed quarterly to determine if valuation adjustments are necessary based
on known changes in the market and/or the project assumptions. When necessary, the “As Is”
appraised value may be adjusted based on more recent appraisal assumptions received by the Company
on other similar properties, the tax assessed market value, comparative sales and/or an internal
valuation. If an updated assessment is deemed necessary and an internal valuation cannot be made,
an external “As Is” appraisal will be obtained. If the “As Is” appraisal does not appropriately
reflect the current fair market value, in the Company’s opinion, a specific reserve is established
and/or the loan is written down to the current fair market value.

Collateral dependant, impaired loans are solely dependant on the liquidation of the collateral for
repayment. All OREO / REPO loans are reviewed quarterly to determine if valuation adjustments are
necessary based on known changes in the market and/or project assumptions. When necessary, the “As
Is” appraisal is adjusted based on more recent appraisal assumptions received by the Company on
other similar properties, the tax assessment market value, comparative sales and/or an internal
valuation is performed. If an updated assessment is deemed necessary, and an internal valuation
cannot be made, an external appraisal will be requested. Upon receipt
of the “As Is” appraisal a charge-off is
recognized for the difference between the loan amount and
its current fair market value.

5

“As Is” values are used to measure fair market value on impaired loans, OREO and REPOs.

Any loan that is partially charged-off remains in nonperforming status until it is paid off
regardless of current valuation of the loan.

In accordance with regulatory reporting requirements, loans are placed on non-accrual following the
Retail Classification of Loan interagency guidance. Typically loans 90 days or more past due are
reviewed for impairment, and bank regulatory if deemed impaired, are placed on non-accrual. Once
impaired, the current fair market value of the collateral is assessed and a specific reserve and/or
charge-off taken. Quarterly thereafter, the loans carrying value is analyzed and any changes are
appropriately made as described above.

Upon receipt of an appraisal, an appraisal review is performed and a specific reserve or charge-off
is processed, if warranted.

The Company acknowledges 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.

Please feel free to contact me if you have any further comments or questions.

Very Truly Yours,

/s/
William R.
Hahl

William R. Hahl

Executive Vice President/

Chief Financial Officer

6

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July 9, 2010

Mr. Hugh West

Branch Chief

United States Securities and Exchange Commission

Washington, D.C. 20549

    RE:

    Seacoast Banking Corporation of Florida

Form 10-K for the Fiscal Year Ended December 31, 2009

Form 10-Q for the Fiscal Year Ended March 31, 2010

File No. 000-13660

Dear Mr. West:

     We are in receipt of your comments related to the above filings and are in the process of
researching and drafting our response to them. However, due to vacation schedules and staff
involved with quarter-end responsibilities, we will need additional time to gather appropriate
information and prepare our response. We estimate we will have our response completed by no later
than July 31, 2010.

Please feel free to contact me if you have any further comments or questions.

Very Truly Yours,

    /s/ William R. Hahl

    William R. Hahl

    Executive Vice President/

Chief Financial Officer

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

       DIVISION OF
CORPORATION FINANCE

                June 15, 2010
By U.S. Mail and facsimile to (772) 288-6012

William R. Hahl Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue Stuart, FL  34994
Re:  Seacoast Banking Corporation of Florida
 Form 10-K for the Fiscal Year Ended December 31, 2009  Form 10-Q for the Fiscal  Quarter Ended March 31, 2010
 File No. 000-13660
 Dear Mr. Hahl:
We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us w ith information so we may better understand
your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings,
or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circumst ances or do not believe future revisions are
appropriate, please tell us why in your response.
 After reviewing the information you provi de in response to these comments,
including the draft of your pr oposed disclosures, we may ha ve additional comments.

* *  *  *  *

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida June 15, 2010 Page 2 of 5  Form 10-K for the Fiscal Year Ended December 31, 2009

 Management’s Discussion and Analysis

 Nonperforming Assets, page 9

 1. Please revise your future filings to quantif y the types of concessions made (e.g. rate
reductions, payment extensions, forgivene ss of principal, forbearance or other
actions) concerning troubled de bt restructurings and discus sion of your success with
the different types of concessions.  Show us what your disclosure will look like in
your response.

2. We note your disclosure on page 55 that you modify certain loans that are not
considered TDRs.  Please desc ribe the types of modifica tions performed and explain
your rationale for not classifying them as TD Rs.  In this regard, specifically tell us
whether you have performed any loan modifi cations that you consider to be short
term in nature (and provide your definition of short term) and therefore concluded
that TDR classificati on was not required.

3. Please tell us and revise your future filings to disclose whether you have performed
any CRE workouts whereby an existing loan was restructured into multiple new loans
(i.e., A Note/B Note structure).  To the ex tent that you have performed these types of
CRE workouts, please provide us with and re vise your future filings to disclose the
following:

• Quantify the amount of loans that have been restructured using this type of
workout strategy in each period presented;
• Discuss the benefits of this workout strategy, including the impact on interest
income and credit classification;
• Discuss the general term s of the new loans and how the A note and B note
differ, particularly  whether the A no te is underwritten in accordance with
your customary underwriting standards and at current market rates;
• Clarify whether the B note is immediat ely charged-off upon restructuring.  If
not, clarify whether you combine the rest ructured notes in your evaluation of
whether the notes should be returned to accrual status;
• Confirm that the A note is classified as a TDR and explain your policy for
removing such loans from TDR classification; and
• Clarify your policy for returning the A note to accrual status, including how
you consider the borrower’s payment perfor mance prior to the restructuring.

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida June 15, 2010 Page 3 of 5  4. Please tell us and consider revising your future filings to disclose, whether you have
noticed an increase in any loan categories such as co mmercial real estate or
construction loans that have been exte nded at maturity for which you have not
considered the loans to be impaired due to the existence of guaran tees.  If so, provide
us with the following information and consid er enhancing your disclosure in future
filings accordingly:

• The types of extensions being made, wh ether loan terms are being adjusted
from the original terms, and whether you consider these types of loans as
collateral-dependent;
• To the extent you extend commercial loans at or near maturity at the existing
loan rate due to the exis tence of a guarantee, tell us  how you consider whether
it is a troubled debt restructuring;
• In detail, how you evaluate the financ ial wherewithal of the guarantor,
addressing the type of financial in formation reviewed, how current and
objective the information reviewed is, a nd how often the review is performed;
• How many times you have sought performa nce under the guarantee discussing
the extent of the successes.  As part  of your response, discuss the decision
making process you go through in deciding whether to pursue the guarantor and whether there are circumstances you would not seek to enforce the
guarantee; and
• Quantify the dollar amount of commercial loans in which your carrying value is in excess of the appraised value bu t not considered impaired due to the
existence of guarantees.
 Notes to Consolidated Financial Statements

 Note R - Fair Value, page 81

 5. Please address and disclose the following as  it relates to your appraisal policies:

• When the Company does not have a new appraisal on file, describe in more
detail the procedures performed by your Credit Officers and Special Assets Officers in determining whether the assu mptions reflected in these original
appraisals are reflective of current ma rket conditions, particularly for those
appraisals that are more than a year old;
• Describe the procedures performed at each  balance sheet date to determine the
fair value of collateral-dependent impa ired loans and OREO.  Tell us how you
define collateral dependent loans.  In determining the fair value address
whether you make adjustments to original appraisals to take into consideration
current market conditions.  If so, desc ribe the types of adjustments made.
Alternatively, if you perform an internal  valuation to  estimate fair value,
please describe the valuation approaches used, the significant assumptions

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida June 15, 2010 Page 4 of 5
used in each model, and if multiple va luation approaches are used, the relative
weighting of each model. Clarify whether you make any adjustments to current appraisals and if so, describe the types of adjustments made and the
reasons for such adjustments.
• When you receive new appraisals, describe  the type of appraisals received,
such as “retail valu e” or “as is value”;
• Address how partially charged-off loans measured for impairment based on
the collateral value are classified and accounted for subsequent to receiving an
updated appraisal.  For example, disclo se whether the loan s are returned to
performing status or whether they remain as nonperforming;
• Address the typical timing surrounding th e recognition of a loan as nonaccrual
and recording of any provision or charge-off;
• Address the procedures performed betw een receipt of updated appraisals to
ensure impairment of loans measured for impairment based on collateral value
are measured appropriately; and
• Address how you determine the amount to charge-off.
 Show us what your disclosure wi ll look like in yo ur 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 in cludes 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 re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
             In responding to our commen ts, 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida
June 15, 2010 Page 5 of 5   You may contact David Irving, Staff A ccountant, at (202) 551-3321, or me at
(202) 551-3872 if you have any questions regarding our comments.
Sincerely,

        Hugh West         B r a n c h  C h i e f

UNITED STATES
SECURITIES  AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE

June 14, 2010

Via U.S. Mail and Facsimile

Dennis S. Hudson, III
Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, FL 34994
Re: Seacoast Banking Corporation of Florida
  Registration Statement on Form S-1
Filed May 24, 2010
  File No. 333-167051

Dear Mr. Hudson:
 We have limited our review of your regi stration statement to those issues we
have addressed in our comments.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
 Please respond to this letter by am ending your registration statement and
providing the requested information.  Wher e you do not believe our comments 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 registration statement and the
information you provide in response to th ese comments, we may have additional
comments.

Form S-1 filed May 24, 2010

 Incorporation by Reference, page iv

1. The Form 10-K/A which has been inco rporated by referenc e does not contain
financial statements for your latest fiscal  year.  Please revise.  Refer to Item
12(a)(1) of Form S-1.

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida
June 14, 2010 Page 2  Recent Developments, page 9

2. To the extent material, please revise to discuss the company’s performance
since March 31, 2010.  Include a discussion of whether non-performing loans have increased since the end of the first quarter and, if so, the amount by
which they have increased.

Selling Stockholder, page 21

3. Please provide all of the information required by Item 507 of Regulation S-K
in your next pre-effective amendment.

4. Please confirm that the selling share holder is a reporting company under the
Exchange Act, a majority-owned subsidiary of a reporting company under the Exchange Act, or a regist ered investment fund under the 1940 Act.  If not,
you must identify the natura l person or persons havi ng voting and investment
control over the securi ties held.  Please revise accordingly.
 General

5. We may have additional comments on this filing after reviewing your
responses to our comment letter on th e registration statement on Form S-1
relating to the Series B preferred stock conversion (File No. 333-167050).

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain th at the filing includes the information the
Securities Act of 1933 and all applicable Securities Act rules require.  Since the
company and its management are in possessi on of all facts relating to a company’s
disclosure, they are responsible for the accur acy and adequacy of the disclosures they
have made.
Notwithstanding our comments, in the ev ent you request acceleration of the
effective date of the pending registration st atement please provide a written statement
from the company acknowledging that:

• should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does no t foreclose the Commission from taking
any action with respect to the filing;

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida June 14, 2010 Page 3
• the action of the Commission or the st aff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the company from
its full responsibility for the adequacy and accuracy of the disclosure in the
filing; and

• the company may not assert staff comments and the declaration of
effectiveness as a defense in any pr oceeding initiated by the Commission or
any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 rega rding requests for acceleration.  We
will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that  those requesting accel eration are aware of
their respective res ponsibilities under the Securities Act of 1933 and the Securities
Exchange Act of 1934 as they relate to th e proposed public offering of the securities
specified in the above regist ration statement.  Please allow adequate time for us to
review any amendment prior to the requested effective date of the registration
statement.
 Please contact Matt McNair, Staff Atto rney, at (202) 551-3583 or me at
(202) 551-3434 with any questions.
Sincerely,

Michael R. Clampitt Senior Attorney
 cc: Ralph F. MacDonald III, Esq.
      Jones Day

CORRESP
1
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Corresp

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Justin Dobbie

              Re:

    Seacoast Banking Corporation of Florida

Registration Statement on Form S-1

File No. 333-160133

Request for Acceleration of Effectiveness

August 12, 2009

Ladies and Gentlemen:

     In accordance with Rule 461 of the Rules and Regulations of the Securities and Exchange
Commission promulgated under the Securities Act of 1933, as amended, we, as Representative of the
several Underwriters, hereby join Seacoast Banking Corporation of Florida (the “Company”) in
requesting that the Company’s above-referenced Registration Statement on Form S-1, as amended, be
accelerated so that it will become effective on November 12, 2008, at 4:30 p.m., or as soon
thereafter as practicable.

    Sincerely,

Sandler O’Neill & Partners, L.P.

As representatives of the several Underwriters

SANDLER O’NEILL & PARTNERS, L.P.

    By:
                                                      Sandler O’Neill & Partners Corp.,
the sole general partner

    By:
                       /s/ Robert A. Kleinert

    Name:
    Robert A. Kleinert

    Title:
    An Officer of the Corporation

CORRESP
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corresp

Seacoast Banking Corporation of Florida

815 Colorado Avenue

Stuart, Florida 34994

August
12, 2009

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Seacoast Banking Corporation of Florida

Registration Statement on Form S-1

Filed August 12, 2009

File No. 333-160133

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities
Act”), Seacoast Banking Corporation of Florida (the “Registrant”) hereby requests that
the effectiveness of the registration statement on Form S-1 (File No. 333-160133) (the
“Registration Statement”) be accelerated so that it
becomes effective at 5:00 p.m.
(New York City time) on August 12, 2009 or as soon thereafter as is practicable.

     The Registrant hereby confirms that it is aware of its obligations under the Securities Act
and the Securities Exchange Act of 1934, as amended, with respect to the registration of the
securities specified in the Registration Statement.

     The disclosure in the Registration Statement is the responsibility of the Registrant. The
Registrant represents to the United States Securities and Exchange Commission (“SEC”) that
should the SEC or its staff, acting pursuant to delegated authority, declare the Registration
Statement effective, it does not foreclose the SEC from taking any action with respect to the
Registration Statement and the Registrant represents that it will not assert this action as a
defense in any proceeding initiated by the SEC or any person under the federal securities laws of
the United States. The Registrant further acknowledges that the action of the SEC or its staff,
acting pursuant to delegated authority, in declaring the Registration Statement effective does not
relieve the Registrant from its full responsibility for the adequacy and accuracy of the
disclosures in the Registration Statement.

     Please confirm that the Registration Statement has been declared effective by telephoning Chip
MacDonald of Jones Day at (404) 581-8622.

*     *     *

     Thank you for your attention to this matter.

    Very truly yours,

SEACOAST BANKING CORPORATION OF FLORIDA

    By:
    /s/ Dennis S. Hudson, III

    Name:
    Dennis S. Hudson, III

    Title:
    Chairman and Chief Executive Officer

    cc:

    Chip MacDonald, Esq.

Jones Day

CORRESP
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Corresp

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Justin Dobbie

              Re:

    Seacoast Banking Corporation of Florida

Registration Statement on Form S-1

File No. 333-160133

Request for Acceleration of Effectiveness

August 12, 2009

Ladies and Gentlemen:

     In accordance with Rule 461 of the Rules and Regulations of the Securities and Exchange
Commission promulgated under the Securities Act of 1933, as amended, we, as Representative of the
several Underwriters, hereby join Seacoast Banking Corporation of Florida (the “Company”) in
requesting that the Company’s above-referenced Registration Statement on Form S-1, as amended, be
accelerated so that it will become effective on August 12, 2009, at 5:00 p.m., or as soon
thereafter as practicable.

    Sincerely,

Sandler O’Neill & Partners, L.P.

As representatives of the several Underwriters

SANDLER O’NEILL & PARTNERS, L.P.

    By:
                                                      Sandler O’Neill & Partners Corp.,
the sole general partner

    By:
                       /s/ Robert A. Kleinert

    Name:
    Robert A. Kleinert

    Title:
    An Officer of the Corporation

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

       DIVISION OF
CORPORATION FINANCE
Mail Stop 4720
        August 6, 2009
By U.S. Mail and Facsimile to: (404) 581-8330

Dennis S. Hudson, III Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, Florida 34994

Re: Seacoast Banking Corporation of Florida
 Form 10-K for the Fiscal Year Ended December 31, 2008
 File No. 000-13660

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

Sincerely,

Kathryn McHale Staff Attorney
cc: Ralph F. MacDonald III, Esq.
Jones Day (By facsimile )

CORRESP
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Corresp

SEACOAST BANKING CORPORATION OF FLORIDA

815 COLORADO AVENUE • STUART, FLORIDA 34994

TELEPHONE: (772) 288-6086 • FACSIMILE: (772) 288-6012

July 31, 2009

Ms. Kathryn McHale and Mr. Justin Dobbie

Division of Corporate Finance

U.S. Securities and Exchange Commission

Mail Stop 4720

100 F Street, N.E.

Washington, DC 20549

    Re:

    Seacoast Banking Corporation of Florida

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

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

File Number: 000-13660

Dear Ms. McHale and Mr. Dobbie:

     We have reviewed your comments dated July 29, 2009 on the above filings and provide our
responses to your comments below.

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

Exhibit 13

Reports of Independent Public Accountants, pages 57 and 58

    1.

    We note your response to comment number six of our letter dated July 17, 2009. The staff
reiterates its previous comment. Please provide a Form 10-K/A to file both the signed report
of the independent public accountants as well as the signed attestation report on the
company’s internal control over financial reporting.

     RESPONSE: We have filed a Form 10-K/A to file both the signed report of the independent
public accountants as well as the signed attestation report on our internal control over financial
reporting.

Ms. McHale and Mr. Dobbie

July 31, 2009

Page 2

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

Item 11. Executive Compensation, page 39

Key Manager Incentive Plan, page 19 of Definitive Proxy Statement on Schedule 14A

    2.

    We note your response to comments 10 and 11 in our letter dated July 17, 2009 but we are
unable to concur with your conclusions given the disclosure in your proxy statement;
therefore, we reissue both comments. You disclose in your proxy statement that an EPS target
was set for 2008, but was not achieved and therefore no cash incentive payments were made to
named executive officers. As such, please provide us with proposed revised disclosure of your
Grants of Plan-Based Awards table to include the estimated threshold, target and maximum
payouts to named executive officers for 2008 and confirm that you will include similar
disclosure, as appropriate, in future filings. Refer to Item 402(d)(2)(iii) of Regulation
S-K. Please also file the Key Manager Incentive Plan as an exhibit to the Form 10-K or tell
us why you are not required to do so. Refer to Item 601(b)(10)(iii)(A) of Regulation S-K.

     RESPONSE: In 2008 the Company’s Salary and Benefits Committee never adopted a Key Manager Incentive
Plan for 2008, therefore none has been or will be filed as an exhibit to the Company’s Form 10-K/A.
We have included the following statement under Item 11 of the 10-K/A to clarify this:

     The Company did not adopt a Key Manager Incentive Plan for 2008 due to the budget estimates
presented early in 2008. Therefore no awards could be or were made in 2008 under a Key Manager
Incentive Plan.

     We will include disclosure similar to those requested, as appropriate in future filings. We
have included the Key Manager Incentive Plans for 2006 and 2007 as Exhibits 10.29 and 10.30 to the
Form 10-K/A filed in response to comment 1 above.

*               *               *

     At the request of the staff, we acknowledge that:

    •

    We are responsible for the adequacy and accuracy of the disclosure in the
above-referenced filings;

    •

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

Ms. McHale and Mr. Dobbie

July 31, 2009

Page 3

    •

    We 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.

     Please contact me at (772) 287-4000 if you have any questions regarding our responses.

Sincerely,

/s/ Dennis S. Hudson, III

Dennis S. Hudson, III

Chief Executive Officer

cc: Ralph F. MacDonald III, Esq. (Jones Day)

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

       DIVISION OF
CORPORATION FINANCE
Mail Stop 4720
July 29, 2009

By U.S. Mail and Facsimile to: (404) 581-8330

Dennis S. Hudson, III Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, Florida 34994

Re: Seacoast Banking Corporation of Florida
 Form 10-K for the Fiscal Year Ended December 31, 2008
Form 10-K/A for the Fiscal Year Ended December 31, 2008
 File No. 000-13660

Dear Mr. Hudson:

We have reviewed your response filed with the Commission on July 23, 2009 and
have the following comments.  Where in dicated, we think you should revise your
documents in response to these comments.  If you disagree, we will consider your
explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explanat ion.  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 raise additional comments.
  We welcome any questions you may have  about our comments or any other
aspect of our review.  Feel fr ee to call us at the telephone numbe rs listed at the end of this
letter.
Form 10-K for the Fiscal Year Ended December 31, 2008

Exhibit 13
 Reports of Independent Public  Accountants, pages 57 and 58

 1. We note your response to comment number six of our letter dated July 17, 2009.
The staff reiterates its previous comment .  Please provide a Form 10-K/A to file
both the signed report of the independent  public accountants as well as the signed
attestation report on the company’s inte rnal control over financial reporting.

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida July 29, 2009 Page 2

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

Item 11.  Executive Compensation, page 39
 Key Manager Incentive Plan, page 19 of  Definitive Proxy Statement on Schedule 14A

 2. We note your response to comments 10 a nd 11 in our letter dated July 17, 2009
but we are unable to concur with your conclusions given the disclosure in your
proxy statement; therefore, we reissue bot h comments.  You disclose in your
proxy statement that an EPS target wa s set for 2008, but was not achieved and
therefore no cash incentive payments were made to named executive officers.  As such, please provide us with proposed revi sed disclosure of your Grants of Plan-
Based Awards table to include the estimated threshold, target and maximum payouts to named executive officers for 2008 and confirm that you will include similar disclosure, as appropriate, in future  filings.  Refer to Item 402(d)(2)(iii) of
Regulation S-K.  Please also file the Key Manager Incentiv e Plan as an exhibit to
the Form 10-K or tell us why you are not  required to do so.  Refer to Item
601(b)(10)(iii)(A) of  Regulation S-K.

Closing Comments

 Please respond to these comments within 10 business days or tell us when you
will provide us with a response.  Please furnish a cover letter with your response that keys your responses to our comments and provides any requested information.  Detailed
cover letters greatly facilitate  our review.  Please understand that we may have additional
comments after reviewing your re sponses to our comments.
  You may contact Chris Harley at (202) 551-3695 or John Nolan, Senior Assistant Chief Accountant, at (202) 551-3492 if you have questions regarding comments on the financial statements and related matters.  Please contact Justin Dobbie at (202) 551-3469
or me at (202) 551-3464 with any other questions.
Sincerely,

Kathryn McHale Staff Attorney
cc: Ralph F. MacDonald III, Esq.
Jones Day
(By facsimile)

CORRESP
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Correspondence

July 23, 2009

Ms. Kathryn McHale and Mr. Justin Dobbie

Division of Corporate Finance

U.S. Securities and Exchange Commission

Mail Stop 4720

100 F Street, N.E.

Washington, DC 20549

    Re:

     Seacoast Banking Corporation of Florida

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

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

Form 10-Q/A for Fiscal Quarter Ended March 31, 2009

Form 8-K filed on March 11, 2009

Form 8-K filed on April 29, 2009

Form 8-K filed on May 22, 2009

File Number: 000-13660

Dear Ms. McHale and Mr. Dobbie:

We have reviewed your comments dated July 17, 2009 on the above filings and provide our responses to your comments
below.

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

Exhibit 13

Management’s Discussion and Analysis

Allowance and Provision for Loan Losses, page 13

    1.

    Please revise the presentation of loan categories in Tables 12 and 13 (pages 48 and 49) in future filings to be
consistent with the loan categories in Table 9 (page 47).

RESPONSE: We recently expanded the detail about our loan portfolio that is included in table 9 and other tables
to allow investors to make their own assessment about the risk associated with the loan portfolio. We will revise the
loan categories in Table 9, 12 and 13 to be consistent in compliance with Industry Guides in our future filings.

1

Ms. McHale and Mr. Dobbie

July 23, 2009

Page 2

Fair Value of Securities, pages 17-18

    2.

    We note your use of pricing models (independent and third party) to value financial instruments. Please tell us
and revise your future filings to disclose the following:

    •

    the number of prices you generally obtain per instrument, and if you obtained multiple prices, how you
determine the ultimate fair value used in your financial statements;

RESPONSE: Generally we obtain one price for each security. Prices obtained from pricing services are usually not
adjusted; however, for two securities (both super-senior AAA private label securities) we noted that the pricing
provided by the pricing services was not consistent with other observed prices in the market during the fourth quarter
of 2008 for similar securities. Using observable market inputs, which included interest rate and yield curves,
volatilities, prepay speeds, loss severities and default rates at year end, we validated the observed prices using a
discounted cash flow model and used the observed prices for similar securities to determine the fair value of these two
securities.

    •

    whether, and if so, why, you adjust prices obtained from the pricing service; and

RESPONSE: Please see response above.

    •

    if true, please include an affirmative statement that based on your internal review procedures, the
fair values provided by the pricing services are consistent with the principles of SFAS 157.

RESPONSE: We confirm our belief that, based on our internal review procedures, the fair values provided by the
pricing services allowed us to conclude that the fair values provided by the pricing services are consistent with the
principles of SFAS 157. We will include such a statement in our future filings.

Goodwill Impairment, page 19

    3.

    In the interest of providing readers with a better insight into management judgments in accounting for goodwill,
please tell us and disclose the following in future filings:

    •

    the reporting unit at which you test goodwill for impairment and your basis for that determination;

2

Ms. McHale and Mr. Dobbie

July 23, 2009

Page 3

RESPONSE: As disclosed in Note A to our audited consolidated financial statements, we are a single segment bank
holding company with one operating subsidiary bank. With the assistance of an independent third party, our management
reviews the results and assumptions utilized in the third party’s analysis which use discounted cash flows and change
in control valuation methods. Determining the fair value using discounted cash flow analysis requires assumptions
regarding short- and long-term net cash flow growth rates, as well as discount rates. As part of the analysis, the
independent third party considers the makeup of assets and liabilities (including both loan and deposit compositions),
scarcity value, capital ratios, market share, credit quality (asset quality), control premiums, the type of financial
institution, the overall size, the various markets we serve as well as profitability ratios.

Growth Assumptions

Multi-year financial forecasts were developed considering key business drivers such as new business initiatives,
market share, anticipated loan and deposit growth, interest rates, historical performance, and industry and economic
trends, among other considerations. Average assets were grown 0.0% in 2009, 5.0% in 2010 and 8.0% thereafter.
Earnings per share of $0.00 in 2009 and $0.71 for 2010 were used with ROAA of 0.75% in 2011 and 1.00% thereafter.

Discount Rate Assumptions

Discount rates are estimated based on the Capital Asset Pricing Model, which considers the risk-free interest
rate, market risk premium, and beta. For the 2008 annual goodwill impairment evaluation, the discount rate used to
develop the estimated fair value was 16%.

Change in Control Assumptions

A total of 14 bank acquisition transactions since December 2004 were used, excluding mergers of equals.
Comparable target financial performance measures were considered in selecting the deals to be examined. The
transactions’ multiples were examined as announced and then adjusted using the price performance of the Keefe Regional
Bank Index since announcement of the transaction.

Market Capitalization

The market capitalization is analyzed in relation to numerous market and historical factors, including current
economic and market conditions, recent, historical, and implied stock price volatility, marketplace dynamics such as
the level of short selling, company-specific growth opportunities, and an implied control premium. In the current
unprecedented market environment, the size of the implied control premium can vary significantly based on the economic
and market conditions which may cause increased volatility in a company’s stock price, resulting in a temporary decline
in market capitalization; therefore, current market capitalization may not be an accurate indication of a market
participant’s estimate of entity-specific value measured over a more reasonable period of time.

3

Ms. McHale and Mr. Dobbie

July 23, 2009

Page 4

Fair Value Results (per share)

    Discounted Cash Flow:

    $
    10.61

    Comparable Transactions Analysis:

    $
    12.17

    Market Capitalization:

    $
    6.60

    •

    a list in tabular form for each reporting unit identifying the reporting unit’s fair value, carrying
amount and goodwill;

RESPONSE: We have only one reporting unit. The Company’s shareholder equity represents carrying value. Goodwill
is disclosed in the balance sheet filed with the SEC. Please see response above for fair value of the Company.

    •

    the reporting units that required the second step of impairment testing;

RESPONSE: The second step of impairment testing was not required.

    •

    specific techniques and their assumptions used to determine fair value of the reporting unit;

RESPONSE: Not applicable as we were not required to perform a second step evaluation.

    •

    the type of report issued by the valuation firm and how management used this information to arrive at
the fair values ultimately used, including discussions of any adjustments made to the fair values
discussed in the report obtained; and

RESPONSE: Please see the response above. No formal report was issued. Management utilized discounted cash flow
and change in control valuations obtained from an independent third party in its assessment of impairment. There were
no adjustments made to the fair values.

    •

    whether management performed any ‘reasonableness’ test or valuation procedures on the fair values
assumed for the reporting units. For example, tell us whether management reconciled the fair values of
the reporting units to the market capitalization of the company, and if so, the results of such testing.

RESPONSE: As a “reasonableness” test, management reviewed its change in market capitalization compared to the KBW
Bank ETF index and determined that the decline in our market capitalization was consistent with the decline in the
index. This “reasonableness” test was performed each quarter beginning June 30, 2008 and for the year ended December
31, 2008.

4

Ms. McHale and Mr. Dobbie

July 23, 2009

Page 5

We will include the above-described disclosure relating to our methodology for and our results of testing goodwill
for impairment in our future filings.

Capital Resources, page 34

    4.

    We note your presentation of the tangible common equity ratio. This financial measure appears to be non-GAAP as
defined by Item 10(e) of Regulation S-K as it is not required by GAAP, Commission Rules, or banking regulatory
requirements. To the extent you plan to provide this non-GAAP measure in the future, please:

    •

    Clearly label the financial measure as non-GAAP each time it is presented;

RESPONSE: We will include the following disclosure in future filings:

This document contains financial information determined by methods other than those prescribed
by accounting principles generally accepted in the United States of America (“GAAP”). Seacoast’s
management uses these “non-GAAP” financial measures in its analysis of the Corporation’s performance.
Seacoast’s management believes that these non-GAAP financial measures provide a greater
understanding of ongoing operations and enhance comparability. These non-GAAP financial measures
include the tangible common equity ratio. Seacoast’s management uses this measure to assess the
quality of capital and believes that investors may find it useful in their analysis of the
Corporation. This capital measure is not necessarily comparable to similar capital measures that may
be presented by other companies.

    •

    State that in light of diversity in presentation in the marketplace, the methodology for determining
this measure may differ among companies; and

RESPONSE: Please see the response above.

    •

    Provide the required disclosures of Item 10(e) and ensure to disclose, in sufficient detail, the
reasons why you believe this presentation provides useful information to investors and specify how
management uses this measure.

RESPONSE: Please see the response above.

5

Ms. McHale and Mr. Dobbie

July 23, 2009

Page 6

Table 9 — Loans Outstanding, page 47

    5.

    Please expand your table in future filings to include information for the last five years pursuant to General
Instruction 3(b) of Guide III.

RESPONSE: We will revise our future filings to include the information for the last five years pursuant to General
Instructions 3(b) of Guide III.

Reports of Independent Public Accountants, pages 57 and 58

    6.

    Please file the signed report of the independent public accountants. In addition, please file the signed
attestation report on the company’s internal control over financial reporting.

RESPONSE: The conformed signature of KPMG LLP was inadvertently dropped in the EDGAR version of our Annual Report
on Form 10-K. At the time of the filing of the Form 10-K, we were in possession of a signed copy of the Reports of
Independent Registered Public Accounting Firm of KPMG LLP. We are attaching the signed reports to this letter. We
respectfully advise the staff that we will include in all relevant future filings the conformed signature of our
independent registered public accounting firm on the reports and consents of such firm.

Financial Statements

Note D — Securities, pages 70-72

    7.

    We note the significant unrealized losses related to your private collateralized mortgage obligations. Please
provide us a detailed analysis of the securities’ impairment as of December 31, 2008 and March 31, 2009 that
identifies all available evidence, explains the relative significance of each piece of evidence, and identifies
the primary evidence on which you rely to support a realizable value equal to or greater than the carrying value
of the investment. Specifically tell us if you considered all available evidence, including information received
after year end, affecting the projected cash flows as of the period end. In addition, disclose the current and
initial (upon initial investment) credit ratings of the private collateralized mortgage obligations and correlate
any deterioration to your analysis above.

6

Ms. McHale and Mr. Dobbie

July 23, 2009

Page 7

RESPONSE: The private label securities consist entirely of super senior AAA investments (these securities have not
been subject to deterioration and are still rated AAA) with collateral that consists of prime residential mortgages
originated between the years of 2003 and 2005. These investments are reviewed quarterly for other than temporary
impairment by considering the following primary factors: percent decline in fair value, rating downgrades,
subordination, duration, amortized loan-to-value, and the ability of the issuers to pay all amounts due in accordance
with the contractual terms. All private label bonds were analyzed and all were determined not to be
other-than-temporarily impaired. Information considered after year-end did not affect the projected cash flow as of
year-end. These bonds are all super senior Tranche SMMEA qualified
and are collateralized by one to
four family fixed and adjustable rate mortgage loans. The bonds’ collateral had no cumulative losses, and delinquency,
foreclosure and bankruptcy rates are low.

    8.

    We note that the company is a member of the Federal Home Loan Bank of Atlanta and at December 31, 2008 holds
approximately $12.8m in FHLB stock. Refer to the guidance of paragraph 12.21-12.25 of the AICPA Guide for
Depository and Lending Institutions and paragraph 8(i) of SOP 01-06. Please tell us and revise future filings to
more clearly discuss your accounting for these securities, including your impairment policy. In addition, present
a balanced discussion to state why, if true, that the company believes that its investment in FHLB Atlanta stock
is not other than temporarily impaired. For example, please discuss how you considered the fact that the FHLB
Atlanta will not pay a dividend for the fourth quarter of 2008 and will only repurchase 50% of each members excess
activity based stock outstanding as of March 16, 2009, but not to exceed the amount of such member’s excess
activity based stock on the date of repurchase.

RESPONSE: We hold stock in the FHLB of Atlanta totaling $7.3 million as of December 31, 2008. We account for the
stock based on the industry guidance in SOP 01-6, “Accounting by Certain Entities (Including Entities With Trade
Receivables) That Lend to or Finance the Activities of Others,” which requires the investment to be carried at cost and
evaluated for impairment based on the ultimate recoverability of the par value. We evaluated our holdings in FHLB
stock at December 31, 2008 and believed our holdings in the stock were ultimately recoverable at par. We do not have
operational or liquidity needs that would require a redemption of the stock in the foreseeable future and, therefore,
determined that the stock was not other-than-temporarily impaired. We will include this discussion in future filings.

Note R — Fair Value

Fair Value Instruments Measured at Fair Value, pages 89-91

    9.

    For fair value measurements using significant unobservable inputs (Level 3), expand the disclosure in future
filings to provide a reconciliation of the beginning and ending balances as required by paragraph 32(c) and (d) of
SFAS 157.

7

Ms. McHale and Mr. Dobbie

July 23, 2009

Page 8

RESPONSE: All of our level 3 fair val

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

      DIVISION OF
CORPORATION FINANCE
Mail Stop 4720
July 17, 2009

By U.S. Mail and Facsimile to: (404) 581-8330; (212) 755-7306

Dennis S. Hudson, III Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, Florida 34994
Re: Seacoast Banking Corporation of Florida
  Registration Statement on Form S-1
Filed June 22, 2009
  File No. 333-160133

Dear Mr. Hudson:

We have limited our review of your fili ng to the resolution of the outstanding
comments on your Form 10-K for the fiscal year ended December 31, 2008 and related
documents.  All comments will need to be fu lly resolved before we act on a request for
acceleration of the effectiveness of the registration statement.

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 Act of 1933 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 the event the company requests accelerat ion of the effective date of the pending
registration statement, it should furnish a letter, at the time  of such request,
acknowledging that:
• should the Commission or the staff, acti ng pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

• the action of the Commission or the staff,  acting pursuant to delegated authority,

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida July 17, 2009 Page 2

in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy  and accuracy of the disclosure in the filing; and

• the company may not assert staff comment s and the declaration of effectiveness
as a defense in any proceeding initiat ed by the Commission or any person under
the federal securities laws of the United States.
  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with your filing.
We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acce leration of the effective date.
We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please provide this request at least two business days in
advance of the requested effective date.
 Please contact me at (202) 551-3469 with any questions.
     S i n c e r e l y ,

 Justin Dobbie
Attorney Advisor
cc: Ralph F. MacDonald III, Esq.
John T. Owen, Esq. Jones Day
(By facsimile)

DIVISION OF
CORPORATION FINANCE   UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

April 22, 2009

Dennis S. Hudson, III Chairman & Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, FL  34994

Re: Seacoast Banking Corporation of Florida
 Amendment No. 1 to Preliminar y Proxy Statement on Schedule 14A
Filed April 20, 2009
 File No. 000-13660

Dear Mr. Hudson:

We have completed our limited review of your Preliminary Proxy Statement on Schedule
14A and related filings and have no further comments at this time.

Sincerely,

Kathryn McHale Staff Attorney

DIVISION OF
CORPORATION FINANCE   UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

April 17, 2009

Dennis S. Hudson, III Chairman & Chief Executive Officer Seacoast Banking Corporation of Florida 815 Colorado Avenue Stuart, FL  34994

Re: Seacoast Banking Corporation of Florida
 Preliminary Proxy Statement on Schedule 14A
Filed April 15, 2009
 File No. 000-13660

Dear Mr. Hudson:

We have limited our review of your filing to  those issues we have addressed in our
comments.  Where indicated, we think you should revise 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 detailed as necess ary in your explanation.
In some of our comments, we may ask you to pr ovide us with information so we may better
understand your disclosure.  After reviewing th is 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 requir ements 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 th is letter.

Preliminary Proxy Statement on Schedule 14A

 1. Please disclose any transactions under consid eration that would involve the issuance of
shares of common stock.  In addition, describe the intended use of proceeds from any such transaction.

2. Please clarify the table on page 46 to indica te whether it takes into consideration the
additional 400,000 shares that would be rese rved for issuance under the Employee Stock
Purchase Plan if proposal 5 is approved.

Dennis S. Hudson, III
Seacoast Banking Corporation of Florida April 17, 2009 Page 2  Closing Comments

As appropriate, please amend your filing and respond to these comments.  You may wish
to provide us with marked copies of the amen dment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters gr eatly facilitate our review.  Please understand
that we may have additional comments after reviewing your amendment and responses to our
comments.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.
In connection with responding to our comment s, 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 sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
Please contact Michael Seaman at (202) 551-3366 or me at (202) 551-3464 with any
questions.
Sincerely,

Kathryn McHale Staff Attorney

October 2, 2007

Mr. William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue Stuart, FL 34994
Re:
      Form 10-K for the Fiscal Year Ended December 31, 2006       File No. 000-13660  Dear Mr. Hahl:

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

Donald Walker
       Senior Assistant Chief
Accountant

CORRESP
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SEC Comment Letter Response

September 10, 2007

Mr. Donald Walker

Senior Assistant Chief Accountant

United States Securities and Exchange Commission

Washington, D.C.  20549

RE:

Seacoast Banking Corporation of Florida

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

Filed March 15, 2007

File No. 000-13660

Dear Mr. Walker:

SEC Comment

Allowance and Provision for Loan Losses, pages 18-20

1.

Please tell us how you adjust from your expected loss model to determine the incurred losses pursuant to SFAS 5.  We note that the company discloses that commercial and commercial real estate loans are assigned internal risk ratings reflecting the probability of the borrower defaulting on any obligation and the probable loss in the event of default.

Response

Each quarter the loan portfolio is segmented by loan type.  All commercial and commercial real estate loans are assigned internal risk ratings (graded loan portfolio) that are consistent with OCC regulatory definitions. All other loan types (using call report code) are grouped by similar risk characteristics and assigned loan grades for evaluation and analysis under SFAS No. 5.  Individual loan relationships in the graded loan portfolio which are graded as substandard, doubtful or loss are evaluated for impairment on an individual basis under SFAS No. 114.

In assigning the loan grades each quarter, all known current material factors that may affect the collectibility of the loan are considered.  Loan loss migration is updated quarterly for each loan type and each loan grade to reflect charge-offs for the quarter and historical loss factors are adjusted as necessary.

The actual historical loan loss factors are assigned by loan type and grade and are adjusted each quarter for increases/decreases in concentrations, portfolio growth, criticized loan growth, movement in delinquencies, internal control ratings, staff turnover and changes in current market conditions/environment to determine the estimate of incurred losses.  We do not include any amounts for future events that could impact expected losses.

SEC Comment

2.

Your disclosure in Note A.  Significant Accounting Policies states that the allowance consists of formula-based components, allowance for impaired loans and allowance related to additional factors.  Please tell us and disclose in future filings the amount of each of these components.

Response

Please see Note F on page 72 of the Annual Report where it is disclosed that the valuation allowance related to impaired loans total $1,192,000 and is included in the allowance for loan losses which totals $14,915,000; therefore, the amount of the allowance based on formula based components and additional factors totals $13,723,000.  All additional factors are formula based.  Our future disclosures will clarify the various components of the allowance.

The Company acknowledges 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.

Please feel free to contact me if you have any further comments or questions.

Very Truly Yours,

William R. Hahl

Executive Vice President/

Chief Financial Officer

Mail Stop 4561

         August 16, 2007

Mr. William R. Hahl
Chief Financial Officer
Seacoast Banking Corporation of Florida
815 Colorado Avenue
Stuart, FL 34994

RE: Seacoast Banking Corporation of Florida
Form 10-K for the Fiscal Ye ar Ended December 31, 2006
Filed March 15, 2007
File No. 000-13660

Dear Mr. Hahl:

We have reviewed your filing and have the following comments.  We have
limited our review to only your financial stat ements and related disclosures and do not
intend to expand our review to other portions of your documents.  Please provide a
written response to our comments.  Please be as detailed as necessary in your
explanation.  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
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.

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

Allowance and Provision for Loan Losses, pages 18-20

1. Please tell us how you adjust from your  expected loss model to determine the
incurred losses pursuant to SFAS 5.  We  note that the company discloses that
commercial and commercial real estate lo ans are assigned internal risk ratings
reflecting the probability of the borrower defaulting on any obligation and the
probable loss in the event of default.

Mr. William R.Hahl
Seacoast Banking Corporation of Florida
August 16, 2007 Page 2

2. Your disclosure in Note A. Significa nt Accounting Policies states that the
allowance consists of formula-based co mponents, allowance for impaired loans
and allowance related to addi tional factors.  Please tell us and disclose in future
filings the amount of each of these components.

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested inform ation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your responses to our comments.

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 all information required under the Securities Exchange Act of 1934 and that 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.

You may contact Chris Harley, Staff Accountant, at (202) 551-3695 or me at
(202) 551-3490 if you have questions.

        S i n c e r e l y ,

                    D o n a l d  W a l k e r
         Senior Assistant Chief Accountant

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

Mail Stop 6010
October 14, 2005

Mr. William R. Hahl
Chief Financial Officer
SeaCoast Banking Corporation of Florida, Inc.
815 Colorado Avenue
Stuart, FL  34994

      Re:	SeaCoast Banking Corporation of Florida, Inc.
		Form 10-K for the year ended December 31, 2004
      Filed March 17, 2005
		File No. 0-13660

Dear Mr. Hahl:

	We have completed our review of your Form 10-K and related
filings and do not, at this time, have any further comments.

							Sincerely,

							Martin F. James
							Senior Assistant Chief
Accountant

</TEXT>
</DOCUMENT>

CORRESP
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filename1.htm

S.E.C. Comment Letter

Alston&Bird LLP

One Atlantic Center

1201 West Peachtree Street

Atlanta, Georgia 30309-3424

404-881-7000

Fax: 404-881-7777

www.alston. com

    Sherri MacLeay DiMarco

    Direct Dial: 404-881-7976

    E-mail: sdimarco@alston.com

September 27, 2005

Mr. Patrick Enunwaonye

Division of Corporate Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 200549

    Re:

    Seacoast Banking Corporation of Florida

Form 10-K for the Fiscal Year Ended December 31, 2004, filed March 17,

2005

Form 10-Q for the Fiscal Quarter Ended March 31, 2005

Form 10-Q for the Fiscal Quarter Ended June 30, 2005

File Number 000-13660

Dear Mr. Enunwaonye:

     Seacoast Banking Corporation of Florida (“Seacoast” or the “Company”) has
filed today with the Securities and Exchange Commission (“Commission”) a Form 10-K/A for
the Fiscal Year Ended December 31, 2004 (“10-K/A”) reflecting the comments included in your
September 15, 2005 letter. Enclosed for your convenience are (i) two clean copies of the 10-K/A,
and (ii) two copies of the 10-K/A that have been marked to show changes from the Form 10-K as filed
with the Commission on March 17, 2005.

     Set forth below is the Company’s response to the above-referenced comment letter, from the
Commission’s staff (the “Staff”) with regard to the Company’s Form 10-K. The Company has
provided the following response, which is numbered to correspond to the Staff’s comment. The
Company hereby acknowledges that: (i) the Company is responsible for the adequacy and accuracy of
the disclosure in the above referenced filings; (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 filings; 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.

    Bank of America Plaza

101 South Tryon Street, Suite 4000

Charlotte, NC 28280-4000

704-444-1000

Fax: 704-444-1111

    90 Park Avenue

New York, NY 10016

22-210-9400

Fax: 212-210-9444

    3201 Beechleaf Court, Suite 600

Raleigh, NC 27604-1062

919-862-2200

Fax: 919-862-2260

    601 Pennsylvania Avenue, N.W.

North Building, 10th Floor

Washington, DC 20004-2601

Fax: 202-756-333

Mr. Patrick Enunwaonye

September 27, 2005

Page 2

1. Comment.

Section 302 Certifications – Exhibits 31.1 and 31.2

    1.

    We see that the language in Item 4 to your Section 302 certifications is not
exactly as prescribed in the regulation. The required certification must be in the
exact form prescribed; and the wording of the required certification may not be
changed in any respect. Accordingly, please file an amendment to your Form 10-K
that includes the entire filing together with the certifications of each of your
current CEO and CFO in the form currently set forth in Item 601(b)(31) of
Regulation S-K.

     Response.

    The Section 302 certification for each of the CEO and CFO have been revised so that they are
in exactly the form set forth in Item 601(b)(31) and they are being filed as part of a
10-K/A.

     If you have any questions regarding our response to the Staff’s comments, please do not
hesitate to call me at the number above.

    Sincerely,

    /s/ Sherri MacLeay DiMarco

    Sherri MacLeay DiMarco

SMD

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

Mail Stop 6010

      September 15, 2005

Mr. William R. Hahl
Chief Financial Officer
SeaCoast Banking Corporation of Florida
815 Colorado Avenue.
Stuart, FL 34994

	RE:	SeaCoast Banking Corporation of Florida, Inc.
      Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 12, 2005
      Form 10-Q for Fiscal Quarter Ended March 31, 2005
      Form 10-Q for Fiscal Quarter Ended June 30, 2005
      File No. 000-13660

Dear Mr. Hahl:

      We have reviewed your filings and have the following
comment.
We have limited our review of your filings to the issue we have
addressed in our comment. Where indicated, we think you should
revise
your documents in response to this comment. If you disagree, we
will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.

	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 comment or on 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 year ended December 31, 2004

Section 302 Certifications - Exhibits 31.1 and 31.2

1. We see that the language in Item 4 to your Section 302
certifications is not exactly as prescribed in the regulation.
The
required certification must be in the exact form prescribed; and,
the
wording of the required certification may not be changed in any
respect.  Accordingly, please file an amendment to your Form 10-K
that includes the entire filing together with the certifications
of
each of your current CEO and CFO in the form currently set forth
in
Item 601(b)(31) of Regulation S-K.

      As appropriate, please respond to the comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response. Detailed cover
letters greatly facilitate our review.  Please file your cover
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.

      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 comment on your filing.

      You may contact Patrick Enunwaonye, Staff Accountant, at
(202)
551-3645 or me, at (202) 551-3605 if you have questions regarding
comment on the financial statements and related matters.  In this
regard, do not hesitate to contact Brian Cascio, Accounting Branch
Chief, at (202) 551-3676 with any other concerns.

								Sincerely,

								Gary Todd
								Review Accountant
??

??

??

??

Mr. William R. Hahl
SeaCoast Banking Corporation of Florida
September 15, 2005
Page 1

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