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CORRESP
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corresp

September 29, 2011

VIA EDGAR

Mr. Jonathan Wiggins

Staff Accountant

Division of Corporation
Finance

United States Securities
and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE:      Stifel
Financial Corp.

Form 10-K for the year ended December 31, 2010

Filed on February 28, 2011

Form 10-Q for the period ended June 30, 2011

Filed August 9, 2011

File No. 001-09305

Dear Mr. Wiggins:

This letter sets forth the responses of Stifel
Financial Corp. (the "Company") to the comments by the staff (the "Staff") of
the Securities and Exchange Commission (the "Commission") contained in the
Staff's letter dated September 23, 2011. For your convenience, the text of the
Staff's comments is set forth in italics below, followed in each case by our
response.

Form 10-Q for the period ended June 30, 2011

Note 15 - Legal Proceedings, page 29

1.   Comment:
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 have a
material effect on your company's consolidated financial condition. Please tell
us, and revise your disclosure as appropriate, whether such losses 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
disclosures in your response.

Response:

We have reviewed our disclosure regarding the
aggregate range of possible losses in excess of the accrued liability (if any).
We advise the Staff that we made the determination that the reasonably possible
range of losses in excess of amounts already recognized as of June 30, 2011 (our
most recent Quarterly report on Form 10-Q) was immaterial. In response to the
Staff's comment, in future filings, beginning with our Quarterly Report on Form
10-Q for the period ended September 30, 2011, if the facts continue to support
our conclusion that the reasonably possible range of losses in excess of amounts
already recognized are immaterial, we will include the following disclosure as
it relates to our legal contingencies:

We have established reserves for potential
losses that are probable and reasonably estimable that may result from pending
and potential legal actions, investigations and regulatory proceedings. In many
cases, however, it is inherently difficult to determine whether any loss is
probable or even possible or to estimate the amount or range of any potential
loss, particularly where proceedings may be in relatively early stages or where
plaintiffs are seeking substantial or indeterminate damages. Matters frequently
need to be more developed before a loss or range of loss can reasonably be
estimated.

For matters where a reserve has not been
established and for which we believe a loss is reasonably possible, as well as
for matters where a reserve has been recorded but for which an exposure to loss
in excess of the amount accrued is reasonably possible, based on currently
available information, we believe that such losses will not have a material
effect on our consolidated financial
statements.

We will
continue to consider the guidance in ASC 450-20-50, based on the facts known at
the time of our future filings, as it relates to legal contingencies, and will
adjust our disclosures as may be required under the guidance.

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If you have any questions or comments regarding
the above information, do not hesitate to contact the undersigned at (314)
342-2228.

Sincerely,

/s/ James M. Zemlyak

James M. Zemlyak

Senior Vice President,
Chief Financial Officer, and Treasurer

(Principal Financial
Officer)

cc:        Ronald J.
Kruszewski, Chairman, President and Chief Executive Officer

            David M.
Minnick, Senior Vice President and General Counsel

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