United States securities and exchange commission logo December 29, 2021 Brian Hunt Senior Vice President and General Counsel FIRST MERCHANTS CORP 200 East Jackson Street Muncie, Indiana 47305 Re: FIRST MERCHANTS CORP Registration Statement on Form S-4 Filed December 23, 2021 File No. 333-261869 Dear Mr. Hunt: 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 at 202-551-3454 with any questions. Sincerely, Division of Corporation Finance Office of Finance