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                           May 26, 2020

       Bruce K. Lee
       Chief Executive Officer
       Heartland Financial USA, Inc.
       1398 Central Avenue
       Dubuque, Iowa 52001

                                                        Re: Heartland Financial
USA, Inc.
                                                            Registration
Statement on Form S-4
                                                            Filed May 18, 2020
                                                            File No. 333-238459

       Dear Mr. Lee:

              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 Donald
Field at 202-551-3680 with any questions.




                           Sincerely,


                           Division of Corporation Finance

                           Office of Finance