July 8, 2014

Mr. Gus Rodriguez

Accounting Branch Manager

United States Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

Form 10-K for Fiscal Period Ended December 31, 2013

Filed February 21, 2014

Form 10-Q for Fiscal Quarter Ended March 31, 2014

Filed April 30, 2014

Dear Mr. Rodriguez:

This letter sets forth each comment of the Staff in the comment letter and, following each comment, sets forth the Company’s response.

Form 10-Q for Fiscal Quarter Ended March 31, 2014

Note 13 - Segments, page 49

As of December 31, 2013, the Company’s reporting segments reflected the way the Company managed and assessed the performance of the business. The Company had four reportable operating segments, which consisted of: Western Alliance Bank (WAB), Bank of Nevada (BON), Torrey Pines Bank (TPB), and Other (Western Alliance Bancorporation (WAL), Western Alliance Equipment Finance, Shine Investment Advisory Services Inc. until October 31, 2012, and the discontinued operations portion of the credit card services division). Management determined the operating segments using a combination of factors, primarily driven by legal entity as the above reportable segments

On December 31, 2013, the Company consolidated its three bank subsidiaries (WAB, BON, and TPB) into one bank/legal entity, with WAB as the surviving bank/legal entity. Our former bank subsidiaries, BON and TPB, now operate as divisions of WAB, along with Alliance Bank of Arizona and First Independent Bank of Nevada. As a result of the consolidation of our banking subsidiaries on December 31, 2013, the Company's reportable segments in 2014 were changed to reflect how our Chief Operating Decision Maker (CODM) now assesses financial performance. Historically, our CODM assessed financial performance based on the Company’s legal structure. The reporting segments in 2014 were determined to consist of Arizona, Nevada, California, Specialty Finance, and Corporate & Other. The Company's new reportable segments are aggregated primarily based on geographic location, services offered, and markets served since the former primary driver of legal entity segregation no longer exists. The Arizona, Nevada, and California segments provide full service banking and related services to their respective markets. The Company's Specialty Finance segment provides banking services to niche markets. These Specialty Finance businesses are broader in geographic scope and are managed centrally. Corporate & Other consists of corporate-related items, income, and expense items not allocated to our other reportable segments and inter-segment eliminations.

As part of the consolidation of our three banking subsidiaries, various other management reporting changes occurred effective as of January 1, 2014, including:

All of the above mentioned changes were made as of the end of 2013 and were not retrospective, as the Company’s decision to consolidate its bank subsidiaries and reorganize its internal reporting structure was made in the fourth quarter of 2013. The Company's bank merger application was submitted to the Federal Deposit Insurance Corporation (FDIC) and state regulators on October 18, 2013 (an amended application was filed on November 22, 2013) with approval from the FDIC on December 19, 2013. All necessary steps to realign our segments, including those outlined above, were undertaken during the fourth quarter of 2013 and would not permit recreation of historical information under the new segmentation methodology prior to December 31, 2013 without substantial time and cost. For example, significant loan activity (i.e., repayments and draws during 2013) would have to be evaluated and allocated to the new segments, past invoices would have to be examined and reallocated to the appropriate cost center, expenses that were previously allocated among the three banks for Regulation W purposes would have to be reversed and the new expense allocation methodology would have to be applied to the new segments. In addition to the 129 employees

In response to the first three bullet points of the Staff's comment, we will revise future filings to disclose the following:

recasting this information. Also, given the incomparability of the reporting segments between periods, the Company determined that disclosure of the reportable segment information for the period ended [..., 2013], as previously reported under the old basis, would not be beneficial to the reader as it does not assist the reader in better understanding the Company’s performance, assessing its prospects for future net cash flows or making more informed judgments about the Company as a whole, which are the primary objectives of ASC 280-10.

The Company assigns capital to all asset categories based on the general requirements for regulatory capital purposes as well as historical loan loss performance. The capital allocations range from 0% on Cash & Due From Banks to as high as 12% on Construction & Land Development Loans. The majority of the loan categories range from a 4% to 8% allocation. We also assign capital to liabilities, which range from 2% to 4%. These ranges are used to account for variable operational and liquidity risk in our deposit businesses. DDA Accounts have less of a risk weighting at 2%, while all Brokered Deposits are 4% weighted. Any excess capital above the allocated capital is assigned to the Corporate & Other segment. In future filings, the Company will report the ranges of its capital allocations used during the period.

All loans and deposits are credited to the reportable segments that originate and/or service our customers. All investment securities and outstanding borrowings (excluding customer related deposits) and the majority of the Company’s cash are assigned to the Corporate & Other segment. After capital is allocated to the reportable segments, a balance sheet mismatch does occur, representing excess funds provided (used) by region. The Company utilizes this metric to show which segments are a net “provider” of funds (deposits/borrowings in excess of lending/investing) versus segments that are a net “consumer” or “user” of funds (lending/investing in excess of deposits/borrowings). A segment which is a “user” of funds is then charged for the use of funds while a “provider” of funds is credited through funds transfer pricing which is determined based on the average life of the assets or liabilities in the portfolio. In future filings, the Company will state liquidity is transferred between “users” and “providers” based on the current funds transfer pricing methodology and will highlight how management views this metric.

As specifically requested by the Staff, the Company acknowledges that:

If you require any additional information on these issues, or if the Company can provide you with any other information that will facilitate your continued review of this filing, please advise us at your earliest convenience. You may reach me at (602) 952-5476. We would also be pleased to set up a conference call to further discuss or clarify any of the above matters.