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April 10, 2024
Ram Shankar
Chief Financial Officer
UMB Financial Corporation
1010 Grand Boulevard
Kansas City, MO 64106
Re:UMB Financial Corporation
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-38481
Dear Ram Shankar:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            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 Fiscal Year Ended December 31, 2023
General
1.We note your presentation of average total tangible shareholder’s equity excluding AOCI
and operating return on average tangible equity excluding AOCI as non-GAAP financial
measures presented in Exhibit 99.1 to your Form 8-K filed January 30, 2024. These
measures represent individually tailored accounting measures given that the adjustment to
exclude AOCI has the effect of changing the recognition and measurement principles
required to be applied in accordance with GAAP. Therefore, please remove the
presentation of these non-GAAP measures from your future filings. Refer to Question
100.04 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations
on Non-GAAP Financial Measures and Rule 100(b) of Regulation G.
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Loans and Loans Held For Sale, page 40
2.We note disclosure that your commercial real estate (“CRE”) loan portfolio has increased
$1.3 billion, or 16.8%, during fiscal year ended December 31, 2023 and that this portfolio,

 FirstName LastNameRam Shankar
 Comapany NameUMB Financial Corporation
 April 10, 2024 Page 2
 FirstName LastName
Ram Shankar
UMB Financial Corporation
April 10, 2024
Page 2
in general, may be more adversely impacted by conditions in the real estate market or the
economy. We also note disclosure in Exhibit 99.2 of your Form 8-K filed on January 30,
2024 that provides detailed disclosures of your CRE loan portfolio. Please revise your
future periodic filings, beginning with your Form 10-Q for the fiscal quarter ended March
31, 2024, to further disaggregate the composition of your CRE loan portfolio to address
material geographic and other concentrations to the extent material to an investor’s
understanding of your CRE loan portfolio. In this regard, provide quantitative and
qualitative disclosure regarding current weighted average and/or range of loan-to-value
ratios and occupancy rates and disclose the extent of your exposure by borrower type,
such as office, retail, hotel and multifamily.
3.In addition, we note your disclosure on page 13 that failures in your risk management
policies, procedures, and controls could adversely affect your ability to manage your CRE
loan portfolio going forward and could result in an increased rate of delinquencies in, and
increased losses from, this portfolio. Please revise your future filings to describe the
specific details of any risk management policies, procedures or other actions undertaken
by management in response to the current environment.
            In closing, 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 Shannon Davis at 202-551-6687 or John Spitz at 202-551-3484 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance