September 24, 2024

Michele M. Kawiecki
Chief Financial Officer
First Merchants Corporation
200 East Jackson Street
Muncie, Indiana 47305

       Re: First Merchants Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2023
           File No. 001-41342
Dear Michele M. Kawiecki:

       We have reviewed your filing and have the following comment.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2023
Item 1C. Cybersecurity, page 30

1.     We note your Chief Information Security Officer (CISO) is responsible
for assessing and
       managing risks from cybersecurity threats, and we note the Information
Security
       Committee (ISC) assists executive management and the Board of Directors
in their
       oversight of responsibilities related to information security. You also
state that the ISC
       reviews and recommends security-related policies and standards, among
other activities
       related to cyber risks. We also note that you describe the relevant
expertise of your CISO
       but not of the other members of the ISC. Please revise future filings to
discuss the relevant
       expertise of such members of senior management as required by Item
106(c)(2)(i) of
       Regulation S-K.
 September 24, 2024
Page 2

        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 Irene Paik at 202-551-6553 or James Lopez at 202-551-3536
with any
other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences