September 5, 2019

Craig Miller
Executive Vice President and General Counsel
Banner Corporation
10 South First Avenue
Walla Walla, WA 99632

       Re: Banner Corporation
           Registration Statement on Form S-4
           Filed August 28, 2019
           File No. 333-233497

Dear Mr. Miller:

       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 David Lin, Staff Attorney, at (202) 551-3552 with any
questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Financial
Services