SecProbe.io

May 8, 2019
Ronald J. Kruszewski
Chief Executive Officer
Stifel Financial Corp.
501 North Broadway
St. Louis, Missouri 63102-2188
Re:Stifel Financial Corp.
Form 10-K for the fiscal year ended December 31, 2018
Filed February 20, 2019
File No. 001-09305
Dear Mr. Kruszewski:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations - Global Wealth Management, page 39
1.We note that revenues generated from asset management and service fees were  25.2% of
total revenues in 2018 and that your revenue growth for the year was attributable to
growth in asset management and service fees.  Given the significance of this revenue
stream, please revise future filings to provide a rollforward of assets under management
(AUM) showing the beginning balance, gross inflows, gross outflows and market
appreciation/depreciation to arrive at an ending AUM balance.   Additionally, to the
extent fee levels vary significantly by AUM product type (fixed income, equities, etc.),
please disaggregate the AUM rollforward by the different products.

 FirstName LastNameRonald J.  Kruszewski
 Comapany NameStifel Financial Corp.
 May 8, 2019 Page 2
 FirstName LastName
Ronald J.  Kruszewski
Stifel Financial Corp.
May 8, 2019
Page 2
Notes to the Consolidated Financial Statements
Consolidation Policies, page 80
2.In your consolidation policy you reference ASU 2010-10; Consolidation, Amendments for
Certain Investment Funds with regard to entities eligible for the deferral and in Note 28.
Variable Interest Entities on page 130, you state that for certain other entities you review
other relevant accounting guidance, which states that the general partner in a limited
partnership is presumed to control the limited partnership.  Tell us and revise your
disclosures accordingly, as to how these provisions comply with ASC 810 and the
issuance of ASU 2015-02; Amendments to the Consolidation Analysis.
            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.
            You may contact Michelle Miller at 202-551-3368 or John Nolan at 202-551-3492 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services