SEC Comment Letter for STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672) (SF) — Mar 16, 2007
STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672)
Date: March 16, 2007 · CIK: 0000720672 · Accession: 0000000000-07-013770
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 23, 2007
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 7010 March 16, 2007 David M. Minnick, Secretary Stifel Financial Corp. One Financial Plaza 501 North Broadway St. Louis, Missouri 63102-2102
Re: Stifel Financial Corp. Preliminary Schedule 14A Filed on March 7, 2007 File No. 0-09305
Dear Mr. Minnick:
We have limited our review of your filing to those issues we have addressed on our comments.
General
1. Please submit on EDGAR a letter executed by the company that contains the Tandy language.
2. We note your response to comment 3 in our letter dated February 23, 2007. However, we are referring to the Form 8-K for Item 5.02 filed on May 16, 2006, which was dated May 9, 2006. Please advise.
3. We note your response to comment 4 in our letter dated February 23, 2007. However, the facts in your situation fall squarely in the example set forth in Note A to Schedule 14A, in part because shareholders did not get to vote on the merger. Therefore, please revise to include all information required by Items 11, 13 and 14 of Schedule 14A.
4. We reissue comment 5 in our letter dated February 23, 2007. Please disclose whether or not you received any report or appraisal regarding the acquisition of Ryan Beck. If so, please provide the information required by Item 14(b)(6) of Schedule 14A. We note the disclosure in your press release that Citigroup Corporate and Investment Banking acted as exclusive financial advisor to Stifel Financial in connection with the transaction.
David M. Minnick Stifel Financial Corp. March 16, 2007 Page 2 Proposal 1, page 9
Background, page 9
5. We note your response to comment 12 in our letter dated February 23, 2007. However, we do not see your disclosure in the filing. Please clarify the relationship of the optionholders to the merger parties.
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. Please direct questions to Brigitte Lippmann at (202) 551-3713. You may also call the unders igned Branch Chief at (202) 551-3767, who supervised the review of your filing.
Sincerely,
Jennifer Hardy
Branch Chief
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
March 16, 2007
David M. Minnick, Secretary
Stifel Financial Corp.
One Financial Plaza
501 North Broadway
St. Louis, Missouri 63102-2102
Re: Stifel Financial Corp.
Preliminary Schedule 14A
Filed on March 7, 2007
File No. 0-09305
Dear Mr. Minnick:
We have limited our review of your filing to those issues we have addressed on our comments.
General
1. Please submit on EDGAR a letter executed by the company that contains the Tandy language.
2. We note your response to comment 3 in our letter dated February 23, 2007. However, we are
referring to the Form 8-K for Item 5.02 filed on May 16, 2006, which was dated May 9, 2006. Please advise.
3. We note your response to comment 4 in our letter dated February 23, 2007. However, the facts in your situation fall squarely in the example set forth in Note A to Schedule 14A, in part because shareholders did not get to vote on the merger. Therefore, please revise to include all information required by Items 11, 13 and 14 of Schedule 14A.
4. We reissue comment 5 in our letter dated February 23, 2007. Please disclose whether or not you received any report or appraisal regarding the acquisition of Ryan Beck. If so, please provide the information required by Item 14(b)(6) of Schedule 14A. We note the disclosure in your press release that Citigroup Corporate and Investment Banking acted as exclusive
financial advisor to Stifel Financial in connection with the transaction.
David M. Minnick
Stifel Financial Corp. March 16, 2007 Page 2
Proposal 1, page 9
Background, page 9
5. We note your response to comment 12 in our letter dated February 23, 2007. However, we do not see your disclosure in the filing. Please clarify the relationship of the optionholders to the merger parties.
As appropriate, please amend your filing and respond to these comments within 10 business
days or tell us when you will provide us with a response. Please direct questions to Brigitte Lippmann at (202) 551-3713. You may also call the unders igned Branch Chief at (202) 551-3767, who
supervised the review of your filing.
Sincerely,
Jennifer Hardy
Branch Chief
cc: Robert J. Endicott, Esq.
Bryan Cave LLP
One Metropolitan Square
211 North Broadway, Suite 3600
St. Louis, MO 63102-2750