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                                                           November 14, 2024

John V. Moran, IV
Chief Financial Officer
Old National Bancorp
One Main Street
Evansville, IN 47708

        Re: Old National Bancorp
            Form 10-K for the Fiscal Year Ended December 31, 2023
            Response dated September 26, 2024
            File No. 001-15817
Dear John V. Moran, IV:

        We have reviewed your September 26, 2024 response to our comment letter
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 the
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.
Unless we note otherwise, any references to prior comments are to comments in
our
September 13, 2024 letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Financial Condition
Loan Portfolio
Commercial and Commercial Real Estate Loans, page 50

1.     We note your response to prior comment 2. Please confirm that in future
filings you
       will provide additional disclosure to explain the circumstances which
must be met in
       order to approve a commercial loan that exceeds the 80% LTV threshold.
We note
       that you provide a discussion of the process for approving exceptions in
your
       discussion of your process for approving consumer loans.
 November 14, 2024
Page 2

       Please contact Shannon Davis at 202-551-6687 or Michael Volley at
202-551-3437 if
you have questions regarding comments on the financial statements and related
matters. Please contact Robert Arzonetti at 202-551-8819 or Christian Windsor
at 202-551-
3419 with any other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Finance
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