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SEC Company Response from STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672) (SF) — Jan 4, 2013

STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672)
Date: Jan. 4, 2013 · CIK: 0000720672 · Accession: 0001193125-13-003698

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File numbers found in text: 333-185145

Date
January 4, 2013
Author
Assistant Director
Form
CORRESP
Company
STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672)

Letter

VIA EDGAR and FACSIMILE Division of Corporation Finance Re: Stifel Financial Corp. (the “Company”) Registration Statement on Form S-4 Filed January 4, 2013 File No. 333-185145

Dear Ms. Hayes:

Pursuant to Rule 461 of the General Rules and Regulations of the Securities Act of 1933, as amended, the undersigned registrant hereby requests that the effectiveness of the above-referenced registration statement be accelerated to January 7, 2013, at 3:00 pm, Eastern Time, or as soon thereafter as practicable.

In addition, the registrant hereby acknowledges that:

•

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please call Robert J. Endicott at (314) 259-2447 or Todd M. Kaye at (314) 259-2194 if you have any questions or comments. Thank you for your continued assistance.

Very truly yours,
STIFEL FINANCIAL CORP.

Show Raw Text
CORRESP
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filename1.htm

CORRESP

 January 4, 2013

 VIA EDGAR and FACSIMILE

 Ms. Suzanne Hayes

Assistant Director

 Division of Corporation
Finance

 U.S. Securities & Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

Re:
Stifel Financial Corp. (the “Company”)

Registration Statement on Form S-4

Filed January 4, 2013

File No. 333-185145

 Dear
Ms. Hayes:

 Pursuant to Rule 461 of the General Rules and Regulations of the Securities Act of 1933, as amended, the undersigned
registrant hereby requests that the effectiveness of the above-referenced registration statement be accelerated to January 7, 2013, at 3:00 pm, Eastern Time, or as soon thereafter as practicable.

In addition, the registrant hereby acknowledges that:

•

 should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

 the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from
its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

 the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

 Please call Robert J. Endicott at (314) 259-2447 or Todd M.
Kaye at (314) 259-2194 if you have any questions or comments. Thank you for your continued assistance.

Very truly yours,

STIFEL FINANCIAL CORP.

By:

/s/ James M. Zemlyak

Name:

James M. Zemlyak

Title:

Senior Vice President and Chief Financial Officer