SEC Comment Letter for STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672) (SF) — Sep 23, 2011
STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672)
Date: Sept. 23, 2011 · CIK: 0000720672 · Accession: 0000000000-11-056852
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 14, 2011, September 2, 2011
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE September 23, 2011 Via E-mail Mr. James M. Zemlyak Chief Financial Officer Sifel Financial Corp. One Financial Plaza 501 North Broadway St. Louis, MO 63102 RE: Stifel Financial Corp. Forms 10-K and 10-Q for the Fiscal Year/Period Ended December 31, 2010 and June 30, 2011 Filed February 28, 2011 and August 9, 2011 File No. 1-09305
Dear Mr. Zemlyak: We have reviewed your response letter dated September 14, 2011 and have the following additional comment. In our comment, we ask yo u to provide us with information so we may better understand your disclosure. After reviewi ng this information, we may or may not raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requir ements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of th is letter.
Form 10-Q for the period ended June 30, 2011
Note 15 – Legal Proceedings, page 29
1. We note your response to comment 3 from our letter dated September 2, 2011. In your proposed disclosure, you state that you believe such losses will not ha ve a material effect on your company’s consolidated financial condition. Please tell us, and revise your disclosure as appropriate, whether such losse s will have a material effect on your other financial statements, including your results of operations. If material , please revise in future periodic filings to disclose an estimate of the additional loss or range of loss. Please include your proposed di sclosures in your response.
Mr. James M. Zemlyak Stifel Financial Corp. September 23, 2011 Page 2 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
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
September 23, 2011
Via E-mail
Mr. James M. Zemlyak Chief Financial Officer Sifel Financial Corp. One Financial Plaza 501 North Broadway St. Louis, MO 63102 RE: Stifel Financial Corp.
Forms 10-K and 10-Q for the Fiscal Year/Period Ended December 31, 2010
and June 30, 2011
Filed February 28, 2011 and August 9, 2011 File No. 1-09305
Dear Mr. Zemlyak: We have reviewed your response letter dated September 14, 2011 and have the following
additional comment. In our comment, we ask yo u to provide us with information so we may
better understand your disclosure. After reviewi ng this information, we may or may not raise
additional comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing. We look forward to working with you in these respects. We welcome any questions
you may have about our comment or on any other aspect of our review. Feel free to call us at the
telephone numbers listed at the end of th is letter.
Form 10-Q for the period ended June 30, 2011
Note 15 – Legal Proceedings, page 29
1. We note your response to comment 3 from our letter dated September 2, 2011. In your
proposed disclosure, you state that you believe such losses will not ha ve a material effect
on your company’s consolidated financial condition. Please tell us, and revise your
disclosure as appropriate, whether such losse s will have a material effect on your other
financial statements, including your results of operations. If material , please revise in
future periodic filings to disclose an estimate of the additional loss or range of loss. Please include your proposed di sclosures in your response.
Mr. James M. Zemlyak
Stifel Financial Corp. September 23, 2011 Page 2
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