SEC Company Response from STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672) (SF) — Jul 8, 2015
STIFEL FINANCIAL CORP (SF, SFB, SF-PB, SF-PC, SF-PD) (CIK 0000720672)
Date: July 8, 2015 · CIK: 0000720672 · Accession: 0001193125-15-247923
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-09305
Referenced dates: June 11, 2015, June 26, 2015, May 22, 2015
Letter
Via EDGAR (Correspondence) United States Securities and Exchange Commission Division of Corporation Finance RE: Stifel Financial Corp. Form 10-K for the Fiscal Year Ended December 31, 2014 Filed March 2, 2015 File No. 001-09305
Dear Mr. Vaughn:
We are writing as a follow-up to our letter dated June 26, 2015 regarding our response to the following comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the Staff’s letter dated June 11, 2015.
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We have read your response to comment 5. You have proposed to expand your disclosure in future filings to state “Applying the two-class method of computing earnings per share would not differ materially from our computation of basic earnings per share.” It is not appropriate to have a stated accounting policy that does not comply with GAAP. Please revise your proposed disclosure accordingly.
As disclosed in our letter dated May 22, 2015, RSUs issued to our non-employee directors, which represent a small portion of our stock-based awards, contain non-forfeitable rights to dividends or dividend equivalents and are considered to be participating securities. The impact of applying the two-class method to the calculation of earnings per share as a result of these participating securities results in an immaterial difference when compared to the calculation using the treasury stock method. We will continue to analyze the impact that the participating securities have on our calculation of earnings per share under the two-class method on a quarterly basis.
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If you have any questions or comments regarding the above information, please do not hesitate to contact me at (314) 342-2228.
Sincerely,
/s/ James M. Zemlyak
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CORRESP 1 filename1.htm CORRESP Via EDGAR (Correspondence) July 8, 2015 Mr. Kevin W. Vaughn Branch Chief United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549 RE: Stifel Financial Corp. Form 10-K for the Fiscal Year Ended December 31, 2014 Filed March 2, 2015 File No. 001-09305 Dear Mr. Vaughn: We are writing as a follow-up to our letter dated June 26, 2015 regarding our response to the following comment of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the Staff’s letter dated June 11, 2015. • We have read your response to comment 5. You have proposed to expand your disclosure in future filings to state “Applying the two-class method of computing earnings per share would not differ materially from our computation of basic earnings per share.” It is not appropriate to have a stated accounting policy that does not comply with GAAP. Please revise your proposed disclosure accordingly. As disclosed in our letter dated May 22, 2015, RSUs issued to our non-employee directors, which represent a small portion of our stock-based awards, contain non-forfeitable rights to dividends or dividend equivalents and are considered to be participating securities. The impact of applying the two-class method to the calculation of earnings per share as a result of these participating securities results in an immaterial difference when compared to the calculation using the treasury stock method. We will continue to analyze the impact that the participating securities have on our calculation of earnings per share under the two-class method on a quarterly basis. **** If you have any questions or comments regarding the above information, please do not hesitate to contact me at (314) 342-2228. Sincerely, /s/ James M. Zemlyak James M. Zemlyak President and Chief Financial Officer (Principal Financial Officer) cc: Ronald J. Kruszewski, Chairman and Chief Executive Officer David M. Minnick, Senior Vice President and General Counsel Mark P. Fisher, Senior Vice President and General Counsel