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October 15, 2007

December 19, 2007

John Cash

Accounting Branch Chief

Division of Corporation Finance

U. S. Securities and Exchange Commission

Washington, D.C. 20549-7010

RE:     Stifel Financial Corp. File # 1-9305

            Form 10-K for the fiscal year ended December
31, 2006

            Form 10-Q for the period ended September 30,
2007

Dear Mr. Cash:

            On behalf of Stifel Financial Corp. ("the
Company") we are responding to the comments of the staff of the Securities
and Exchange Commission in your letter dated December 6, 2007 to James M. Zemlyak,
Senior Vice President, Chief Financial Officer, Treasurer , and Director of the
Company, with respect to the Company's Form 10-K and Form 10-Q referred to
above.

            In response to your letter, set forth below are
your comments in italics followed by the Company's responses to your comments.

Form 10-K for the fiscal year ended December 31, 2006

Management's Discussion and Analysis, page 21

1.         We
have reviewed your response to our prior comment one and note the revisions you
have made to your disclosure in your Form 10-Q for the period ended September
30, 2007. Please further revise your future filings to more specifically
explain and quantify the impact of the cited pricing pressures and the
realization of your expected merger benefits and synergies. There is a concern
that readers may not fully understand the specific business, economic, and
competitive factors that have precipitated these pricing pressures nor the
extent of the impact on the corresponding revenue and expense accounts. Please
supplementally provide us with a responsive disclosure.

Company
Response:

We note your comment that some readers may not fully grasp
the effect of the pricing pressures we describe in our risk factor on page 11 of
our Form 10-K for the year ended December 31, 2006 on our revenues and expenses.
However, to date, these pricing pressures have not had a significant impact on
our results of operations and we believe that it would not be possible to
accurately quantify any potential impact that these pricing pressures may have,
and in any event may, under certain circumstances, represent confidential
pricing information. To address the Staff's comment and concern however, we will
include in the Executive

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Summary in our future filings further discussion in
substantially the following form:

The Company is subject to increased
pricing pressures, principally in the Equity Capital Markets segment.
Institutional clients seek to decrease the cost of trade execution by
unbundling payments for trade execution from payments for research products and
services, both of which we provide. As a result of the Company's focus on
providing trade executions and highly regarded research products and services
on a bundled basis, neither revenues from institutional clients nor profit
margins on those revenues have decreased as a result of these pricing pressures.

We further note your comment to further explain and quantify
the expected merger benefits and synergies. To address the Staff's comment, we
will further expand the Executive Summary in our future filings to include discussion in substantially
the following form (additional language shown in italics):

The Company's overall financial results continue to be highly
and directly correlated to the direction and activity levels of the United
States equity markets and the increased activity from the successful
integration of the LM Capital Markets business acquired on December 1, 2005,
the Ryan Beck acquisition on February 28, 2007, the First Service acquisition
on April 2, 2007, and the Company's continued expansion of the Private Client
Group ("PCG"), including the Miller Johnson Steichen and Kinnard
("MJSK") purchase on December 5, 2006. The latter three acquisitions have
contributed the following amounts of net revenues for the nine-month period
ended September 30, 2007: Ryan Beck -$134.4 million; First Service - $2.9
million; and MJSK - $11.8 million. As a result of these latter three acquisitions, the
Company added 1,043 employees and 51 private client group offices.

The Company's quarterly and year to date results have also been
impacted by the increased operating costs resulting from the integration of
Ryan Beck which was acquired on February 28, 2007. As a result of the Ryan
Beck acquisition, occupancy and equipment rental, communications and office
supplies, and other operating expenses increased $6.2 million, $4.1 million,
and $3.2 million, respectively, for the nine months ended September 30, 2007.
However, as the Ryan Beck Private Client offices have converted to Stifel
Nicolaus, the Company has realized cost savings in commissions and floor
brokerage fees through the elimination of clearing fees that Ryan Beck paid to a
third party clearing agency, as the Company is able to more efficiently
self-clear those transactions. These commissions and floor brokerage cost
savings have been partially offset by increased administrative and operational
costs for additional personnel added to handle the increased volume of
transactions. The Company has realized some synergies through reduced overhead
costs as a percentage of net revenues through the third quarter and anticipates
realizing further future overhead synergies after the conversion of back office
and operations personnel is completed in the fourth quarter. For the nine

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 months ended September 30, 2007 and 2006, total non-interest expenses in the
Company's "Other" segment as a percentage of net revenues was 17.3%
and 20.2%, respectively. In addition, for the nine months ended September 30,
2007, the Company has incurred acquisition related expenses associated with the
Ryan Beck acquisition consisting of: 1) $22.7 million of employee compensation
and benefits costs, including $1.0 million for Ryan Beck positions that will be
eliminated by year-end, principally for the amendment and acceleration of
vesting of the Ryan Beck deferred compensation plan; and 2) $6.5 million in
other operating expenses. See further discussion of these acquisition related
charges in the Results of Operations for Other Segment - Nine Months. The
Company does not anticipate significant conversion or acquisition related
charges in the future related to the Ryan Beck acquisition.

Core
Earnings, page 30

2.         We have
reviewed your response to our prior comment two. We continue to be concerned
about your exclusion of your acquisition-related charges. Your current
disclosures may confuse investors about the level of compensation that will be
required on an ongoing basis to generate the levels of revenue you have
realized as a result of your acquisitions. We note your disclosure in your risk
factors (page 10) regarding the intense competition for personnel in your
industry and the fact that the cost of retaining skilled professionals has
intensified. We also note your disclosure that the success of your acquisitions
depends on your ability to retain key personnel from Ryan Beck and Legg Mason.
We are therefore concerned that your current discussion and presentation of
Core Earnings may cause investors to expect that the same revenue amounts can
be generated in the future even though employees will be paid significantly
less compensation. This outcome appears highly speculative and the concern is
heightened by the inclusion of nonrecurring income, the apparent recurrence of
these compensation charges, and the discussion of future acquisitions on pages
10-11. As a result, we believe that this presentation and discussion should be
omitted from future filings.

Company
Response:

The Company will
remove this presentation and discussion from future filings.

Consolidated
Statement of Cash Flows, page 53

3.         We have
reviewed your response to our prior comment seven. Please provide us with a
substantive analysis regarding how you considered the AICPA Technical Practice
Aid, "Presentation of Cash Overdrafts on Statement of Cash Flows" and
SFAS 95 in determining that is was appropriate to classify your book overdrafts
as an operating activity. In addition, please tell us whether any of your
outstanding checks and electronic payments that have not yet been presented for
payment at the bank were transacted on bank accounts that were included in your
cash balance as of December 31, 2006.

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Company
Response:

As discussed in our November 13, 2007 response, drafts
payable represent outstanding checks and electronic transfers that have not yet
been presented for payment at the bank. Specifically, these are drafts utilized
in our normal brokerage operations to pay clients money from their brokerage
accounts. The drafts are written out of a zero balance account ("ZBA
account") and are funded by transfers from the Company's operating account
as they are presented for payment at the bank. At the end of any given day, the
balance in this drafts account is zero, so there are no bank overdrafts, only
book overdrafts. The Company's operating cash account that funds this ZBA
account has a positive balance.

The Company considered the AICPA Technical Practice Aid,
"Presentation of Cash Overdrafts on Statement of Cash Flows" and the
inquiry and reply discussed therein with regard to the bank account in an
overdraft position. The AICPA reply referenced SFAS 95 "Statement of Cash Flows"
and stated that the net change in overdrafts during the period is a
financing activity. We believe that this is different from our situation, in
that the example was a bank overdraft and did not discuss the treatment of a
book overdraft. In the Company's situation, when the draft payable check or
electronic transfer is issued to the client, the Company debits "payable
to customers" (an operating activity) and credits "drafts payable."
At the time of the issuance of the draft, the Company has no financing activity
with the bank as the bank has not extended credit as would be the case if the
bank account were overdrawn. Paragraph 18 of SFAS 95 indicates that financing
activities include obtaining resources from owners and providing them with a
return on, and a return of, their investment; borrowing money and repaying
amounts borrowed, or otherwise settling the obligation; and obtaining and
paying for other resources obtained from creditors on long-term credit. The
Company's drafts payable transactions do not represent any of those activities
and occur within the day-to-day operations of our broker-dealer business as
agent for our clients. Since these drafts payable transactions relate to other
operating activities, specifically "payable to customers", we believe
the proper presentation of this transaction is as an operating activity.

Note A.
Summary of Significant Accounting and Reporting Policies, page 55

4.         We
have reviewed your response to our prior comment eleven. Given the importance
of revenue recognition to a user's understanding of your results, we continue
to believe that your revenue recognition practices may be clarified in future
filings, either in the Business section or in the accounting policies footnote.
Please consider clarifying the following issues in your future disclosures:

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?    There have been no significant
expenses recognized for incomplete transactions;

?    Your revenue derived from
contractual obligations is regarded when payments are earned and contractually
due;

?    You do not have any incentive
income subject to repayment;

?    You account for proprietary
research reports as a cost of doing business; and

?    You do not offer discounts on
your commission rates.

Company
Response:

The Company will expand its disclosures in future filings to
address the issues above. The following revenue recognition policy disclosures will
be revised as follows with the new language in italics.

Investment Banking

Investment banking revenues include advisory fees,
management fees, underwriting fees, net of reimbursable expenses, and sales
credits earned in connection with the distribution of the underwritten
securities. Investment banking management fees are recorded on offering date,
sales concessions on trade date, and underwriting fees at the time the
underwriting is completed and the income is determinable. Revenues derived
from contractual arrangements, typically advisory fees, are recorded when
payments are earned and contractually due. Expenses associated with investment banking transactions are deferred until the
related revenue is recognized or the engagement is otherwise concluded. For
the periods presented, there were no significant expenses recognized for
incomplete transactions. (if true). The Company has not recognized any incentive
income that is subject to contingent repayments (if true).

Security
Transactions

Customer security transactions are recorded on a settlement
date basis, with related commission revenues and expenses recorded on a trade
date basis. Commission revenues are recorded at the amount charged to the
customer, which, in certain cases, may include varying discounts. Principal
securities transactions are recorded on a trade date basis. The Company
distributes its proprietary equity research products to its client base
of institutional investors at no charge. These proprietary equity research
products are accounted for as a cost of doing business.

Item 9A.
Controls and Procedures, page 82

5.         We have
reviewed your response to our prior comment 14. Your disclosure in your Form
10-Q for the period ended September 30, 2007 still does not comply with the
requirements of Exchange Act Rule 13a-15(e). In particular, you have incorrectly
defined disclosure controls and procedures. We remind you that disclosure
controls and procedures are meant to ensure that information you are required
to disclosure in reports filed under the Exchange Act is recorded, processed,
summarized and reported as and when required and are meant to ensure
that material information

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             required to be in this report is made known to
management and others, as appropriate, to allow timely decisions regarding
required disclosures. If you continue to choose to define disclosure controls
and procedures, please ensure that you fully define the term and that your
officers' conclusion on the effectiveness of disclosure controls and procedures
covers all parts of the definition. Alternatively, in future filings you may simply
conclude that your disclosure controls and procedures are effective or
ineffective, whichever the case may be, without providing any part of the
definition.

Company
Response:

The Company will modify its
disclosure in future filings to fully define disclosure controls and procedures
in accordance Exchange Act Rule 13a-15(e) as follows:

Under rules promulgated by the SEC,
disclosure controls and procedures are defined as those controls and other
procedures of an issuer that are designed to ensure that information required
to be disclosed by the issuer in the reports that it files or submits under the
Securities Exchange Act of 1934 is recorded, processed, summarized and
reported, within the time periods specified in the Commission's rules and forms
and that such information is accumulated and communicated to the issuer's
management, including its Chief Executive Officer and Chief Financial Officer,
as appropriate, to allow for timely decisions regarding required disclosure.

If you have any additional
questions on the above information, please feel free to contact me at
314-342-2000.

Sincerely,

Stifel Financial Corp.

/s/ James M. Zemlyak

James M. Zemlyak

Senior Vice President, Chief Financial Officer,

Treasurer, and
Director

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