UPLOAD: SEC-generated letter

September 12, 2005



Mail Stop 4561


Mr. Thomas E. Hoaglin
Chairman, President, Chief Executive Officer, and Director
Huntington Bancshares Incorporated
41 S. High Street
Columbus, Ohio 43287

Re: Huntington Bancshares Incorporated
Form 10-K for Fiscal Year Ended December 31, 2004
Form 10-Q for Fiscal Quarter Ended March 31, 2005
Form 10-Q for Fiscal Quarter Ended June 30, 2005
File No. 0-2525

Dear Mr. Hoaglin:

We have reviewed your filing and have the following
comments.
Please be as detailed as necessary in your explanation. In some
of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure. After
reviewing this information, we may or may not raise additional
comments.

Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your 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, December 31, 2004:

Business Risks - (4) Operation Risks, page 14

1. We note your disclosure on page 14 that you agreed to take
certain
corrective actions within a 180 day period as a result of
regulatory,
supervisory and examination activities. Please tell us:
* the status of your corrective actions;



* whether there has been any change in your expectations regarding
potential loss of GLB Procedures and Powers;
* known impacts as a result of any non compliance; and
* the impact, if any, on your determination of the allowance and
provision for loan and lease losses.

Consolidated Financial Statements

Consolidated Statements of Cash Flow, page 99

2. In light of the large increase in trading account securities in
fiscal year 2004, please:
* identify the source of these trading account securities i.e.,
purchases, transfers from other categories of investments, etc.;
* if applicable, tell us how you determined that transfers into or
from the trading account were rare; and
* if applicable, quantify the unrealized holding gain or loss
recognized in net income for each period presented for any
securities
transferred into the trading category.
In preparing your response, please consider paragraph 15 of SFAS
No.
115.

Note 1. Significant Accounting Policies - Securities, page 100

3. We note that your investment securities are stated at fair
value
at both December 31, 2004 and 2003. We also note your footnote
disclosure on page 100 that investment securities include
securities
designated as available for sale, non-marketable equity
securities,
and securities held to maturity. Please confirm that you do not
hold
investment securities held to maturity and revise disclosures in
future filings to properly reflect the specific components of your
investment securities.
Note 6. Allowances For Credit Losses, page 112

4. Total impaired loans totaled $81,171 million, $54,853 million
and
$94,550 million for the three years ended December 31, 2004. The
totals of impaired loans to which specific reserves were not
assigned
at each respective year end were $29,296 million, $0 and $2,972
million, respectively. Please tell us how you determined that
there
was no need to assign a specific reserve to a significant portion
of
your total impaired loan balance in the current year, unlike
preceding years.

5. Please tell us why your middle market commercial and industry
loans and leases had almost no charge offs in 2004.


As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Detailed letters greatly facilitate our review. Please understand
that 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 filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

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

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

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

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

In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

You may contact Benjamin Phippen, Staff Accountant at (202)
551-
3697 or me at (202) 551-3490 if you have any questions.


Sincerely,



Donald A. Walker
Senior Assistant Chief Accountant

Thomas E. Hoaglin
Huntington Bancshares Incorporated
September 9, 2005
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