SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

 September 2, 2011
 Via E-mail

Mr. James M. Zemlyak Chief Financial Officer Stifel Financial Corp. One Financial Plaza 501 North Broadway St. Louis, MO 63102   RE:  Stifel Financial Corp.
Form 10-K for the Fiscal Ye ar Ended Decem ber 31, 2010
  Filed February 28, 2011   Form 10-Q for the Period Ended June 30, 2011   Filed May 16, 2011   File No. 1-09305

Dear Mr. Zemlyak:
We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10-K for the Year Ended December 31, 2010

 General

 1. Please tell us how you determined you were not required to file financial statements of
Thomas Weisel Partners Group, Inc. for the interim period ended June 30, 2010.  Refer to
Rule 3-05 of Regulation S-X.
 Segment Analysis, page 40

 2. We note that you evaluate the performance of  your segments and allocate resources to
them based on various factors, including pros pects for growth and return on investment.

Mr. James M. Zemlyak
Stifel Financial Corp. September 2, 2011 Page 2
 Please revise in future periodic filings to include a discussion by segment of prospects for
growth, return on investment, and any othe r key performance indicators you use to
manage your business, or tell us how you de termined this disclosure would not be
material to investors.
 Form 10-Q for the Period Ended June 30, 2011

 Note 15 - Legal Proceedings, page 29

 3. For each of your legal contingencie s, if there is at least a r easonable possibility that a loss
exceeding amounts already recognized may have  been incurred, in your next periodic
filing, please either disclose an estimate (or, if  true, state that the estimate is immaterial in
lieu of providing quantified amounts) of the addi tional loss or range of loss, or state that
such an estimate cannot be made.  Please refer to ASC 450-20-50.

If you conclude that you cannot estimate the reasonably possible addi tional loss or range
of loss, please supplementally: (1) expl ain to us the procedures you undertake on a
quarterly basis to attempt to develop a range  of reasonably possibl e loss for disclosure
and (2) for each material matter, what specif ic factors are causing the inability to estimate
and when you expect those factor s to be alleviated.  We r ecognize that there are a number
of uncertainties and po tential outcomes associated with lo ss contingencies.  Nonetheless,
an effort should be made to develop estim ates for purposes of disclosure, including
determining which of the potential outcom es are reasonably possible and what the
reasonably possible range of losses would be  for those reasonably possible outcomes.
 You may provide your disclosures on an aggr egated basis.  Please include your proposed
disclosures in your response.
  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.     In responding to our comments, please provi de a written statement from the company
acknowledging that
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Mr. James M. Zemlyak
Stifel Financial Corp. September 2, 2011 Page 3

You may contact William Demarest, Staff Acco untant, at (202) 551-3432 or me at (202)
551-3694 with any questions.          S i n c e r e l y ,           /s/ Jonathan Wiggins          Jonathan Wiggins         S t a f f  A c c o u n t a n t