LETTER 1 filename1.txt Mail Stop 4561 February 23, 2006 Mr. Mark A. Chancy Sr. Executive Vice President and Chief Financial Officer SunTrust Banks, Inc. 303 Peachtree Street, NE Atlanta, GA 30308 Re: SunTrust Banks, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 Forms 10-Q for Fiscal Quarters Ended March 31, 2005, June 30, 2005 and September 30, 2005 File No. 001-8918 Dear Mr. Chancy: We have reviewed your response letter dated February 6, 2006 and have considered the supplemental information provided by the company. We have the following additional comment. Form 10-K for the Fiscal Year Ended December 31, 2004 Exhibit 13.1 - 2004 Annual Report Note 17 - Derivatives and Off-Balance Sheet Arrangements, page 95 1. We note your comprehensive materiality analysis in response to comment 4 of our letter dated January 24, 2006. We believe you should record the cumulative adjustment of the identified hedge accounting misstatements in the 4th quarter of 2005. Please provide us with your proposed December 31, 2005 Form 10-K disclosure that includes the following: * a description of the misstatements; * your conclusion regarding materiality assuming no hedge accounting as a result of the errors; * quantify and describe the impact on previously report results, including trends and volatility; and * describe your plans to for these hedging relationships going forward. * * * Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file your response on EDGAR. Please understand that we may have additional comments after reviewing your response to our comment. You may contact Chris Harley, Staff Accountant, at (202) 551-3695 or me at (202) 551- 3449 if you have questions regarding this comment on the financial statements and related matters. Sincerely, Joyce A. Sweeney Accounting Branch Chief ?? ?? ?? ?? Mr. Mark Chancy Sr. Executive Vice President and Chief Financial Officer SunTrust Banks, Inc. February 23, 2006 Page 1 of 2