[SunTrust Letterhead]
September 20, 2010
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 4561
100 F Street, N.E.
Washington, D.C. 20549
Attention: David Irving
| Re: | SunTrust Banks, Inc. (File No. 001-08918) |
| Form 10-K for the Fiscal Year Ended December 31, 2009 |
| Form 10-Q for the Fiscal Quarter Ended March 31, 2010 |
Mr. Irving:
This letter supplements the Company’s prior submissions to the Securities and Exchange Commission staff (the “Staff”) dated May 5, 2010; June 24, 2010; July 21, 2010; and August 6, 2010. Based on the views expressed by the Staff related to the Company’s Student Loan Securitization Trust, namely that the Company possesses the power to direct the activities of the trust that most significantly impact the trust’s economics, we have elected to consolidate the trust as of September 30, 2010 based on the carrying value of the assets and liabilities held in the trust.
Please feel free to call the undersigned at (404) 813-1281 or Tom Panther at (404) 588-8585 with any questions concerning our responses to the Staff’s comments.
| Very truly yours, |
/s/ Mark A. Chancy |
| Mark A. Chancy |
Corporate Executive Vice President and Chief Financial Officer |
| cc: | Mr. M. Doug Ivester |
Audit Committee Chairman
Mr. James M. Wells III
Chairman and Chief Executive Officer
Mr. Raymond D. Fortin
Corporate Executive Vice President and
General Counsel
Mr. Thomas E. Panther
Controller and Chief Accounting Officer
Mr. David W. Leeds
Ernst & Young LLP, Coordinating Partner
