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CONFIDENTIAL TREATMENT REQUESTED

 Via EDGAR (Correspondence)

FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO RULE 83

May 6, 2016

 Mr. Gus Rodriguez

Accounting Branch Chief

 Office of Financial Services

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

RE:
Stifel Financial Corp.

 Form 8-K

Filed February 23, 2016

Form 10-K for the Fiscal Year Ended December 31, 2015

Filed March 1, 2016

File No. 001-09305

 Dear
Mr. Rodriguez:

 This letter, together with our revised disclosures included in Appendix No. 1, sets forth Stifel Financial Corp.’s (the
“Company,” “we,” “us” or similar terms) responses to the comments by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the Staff’s letter dated
April 11, 2016.

 We note for the information of the Staff that, concurrent with the submission of this response letter, confidential treatment of a
portion of the response to comment 7 included in this response letter is being requested under the Commission’s rules pursuant to the accompanying confidential treatment request. Accordingly, this response letter is being filed via hand
delivery and not via EDGAR. A redacted copy has been filed via EDGAR.

 In accordance with Rule 83, this Letter has also been clearly marked with the
legend “FOIA Confidential Treatment Requested Pursuant to Rule 83” and each page is marked for the record with the identifying numbers and code “SF001” through “SF008.” We have filed a separate letter with the Office of
Freedom of Information and Privacy Act (the “FOIA Office”) in connection with the confidential treatment request, pursuant to Rule 83 of the Commission’s Rules on Information and Requests.

For your convenience, the text of the Staff’s comments is set forth in italics below, followed in each case by our response.

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 FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO RULE 83

 Form 8-K filed February 23, 2016

Exhibit 99.1

1.
We note that you present a full GAAP to non-GAAP net income from continuing operations for the three months and year-ended December 31, 2015. We are concerned that the presentation of a full non-GAAP income
statement attaches undue prominence to the non-GAAP information and may give the impression that the non-GAAP income statement represents a comprehensive basis of accounting. Please confirm to us that you will not present non-GAAP consolidated
income statements in future filings. Please refer to Regulation G and Item 10(e) of Regulation S-K. For more guidance, refer to Question 102.10 of the Non-GAAP Compliance and Disclosure Interpretations.

Response:

 The Company
acknowledges the Staff’s comment and respectfully advises the Staff that it considered Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations in preparing its disclosure. The Company believes its current
presentation is in compliance with current SEC guidance. The Company notes as an initial matter that the response to Question 102.10 states that it is “generally” not appropriate to provide such information; however it does not prohibit
such information.

 The Company advises the Staff that the format of its reconciliation was not intended to attach undue prominence to the
non-GAAP information but was intended to present the required reconciliation between non-GAAP measures and their most directly comparable GAAP financial measures. Given our recent acquisitions, the Company believes this presentation format provides
investors with a transparent, easy-to-follow means of assessing the financial performance of the combined company.

 In the Form 8-K, the
Company took a number of steps so as not to attach undue prominence to the non-GAAP information. First, the GAAP reported statements of operations were presented before the GAAP to non-GAAP reconciliation, as was the Company’s narrative
discussion of its GAAP financial results. Additionally, the table showing the GAAP to non-GAAP reconciliation was in a section titled “Non-GAAP Financial Measures,” as to make it clear that such information was secondary to the GAAP
information. Finally, the introductory paragraph to the table that reconciles our GAAP to non-GAAP results cautions the reader on the limitations of the non-GAAP data and explicitly states the following language in its explanation of the use of
non-GAAP financial measures “Reference to these non-GAAP measures should not be considered as a substitute for results that are presented in a manner consistent with GAAP.”

Beginning with our first quarter 2016 earnings release, we will revise the lead-in paragraph as follows to further avoid attaching undue
prominence to the non-GAAP information: “The non-GAAP financial information should be considered in addition to, not as a substitute for or as being superior to, operating income, cash flows, or other measures of financial performance prepared
in accordance with GAAP.”

 Given our recent acquisitions and the impact of the related purchase accounting adjustments, we believe
that the disclosures included in the Company’s reconciliation aid users of the Company’s financial statements in understanding the effect of the acquisitions and related integration projects on the Company’s financial results. The
Company believes that it is beneficial to have all the components of non-GAAP results in one summary schedule so as to allow users to easily identify the impact of non-GAAP items on its results of operations and to compare such results to the
Company’s publicly issued guidance. Further, the same non-GAAP information is also provided to

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 FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO RULE 83

the Company’s executive management and Board of Directors so they may use it to assess the Company’s consolidated year-over-year performance. Finally, the Company believes that
presenting separate reconciliations, or excluding line items from the current format, may make the analysis more cumbersome for investors. For example, if we no longer prepared the reconciliation in this format, users would likely attempt to compile
it themselves, which we believe would lead to additional confusion and diversity in practice and reduced transparency.

 As a result, we
believe that providing this comprehensive reconciliation is responsive to the needs of the Company’s financial statement users, fulfills the requirements in Regulation G and Item 10(e)(1)(i) of Regulation S-K and is not prohibited by
Question 102.10.

2.
Please tell us what non-GAAP adjustments are being made, as you disclose that the adjustments “primarily exclude acquisition related expenses which management believes are duplicative and will be eliminated,
stock-based compensation and other expenses in which managements’ view are not representative of on-going businesses”. Please provide us proposed revised disclosure that clarifies each adjustment made to arrive at your non-GAAP net income
measure and how each adjustment contributes to the usefulness of the non-GAAP measure.

 Response:

Please be advised that the Company intends to include the following table and disclosure, to the extent applicable, starting with the second
quarter 2016 earnings release to clarify the non-GAAP adjustments and how each adjustment contributes to the usefulness of the non-GAAP measure. The proposed revised disclosure follows:

Three months
ended June 30,
2016

Six months
ended June 30,
2016

 Non-GAAP net income

$

$

 Compensation and benefits:

 Stock-based compensation expense

 Duplicative expenses

 Non-compensation operating expenses:

 Acquisition-related expenses

 Duplicative expenses

 Amortization of intangible assets

 Total adjustments

 GAAP net income

$

$

 Stock-based compensation expense – Upon the closing of the [Company X] acquisition, certain employees were
granted Company restricted stock units as retention awards. There are no continuing service requirements associated with these restricted stock units, and accordingly, they were expensed at date of grant. The Company views the expensing of
restricted stock units related to the acquisition and not representative of the costs of running the Company’s on-going business.

Acquisition-related expenses – Primarily related to charges attributable to integration-related activities, professional fees and legal
costs. These costs were directly related to the acquisition and are not representative of the costs of running the Company’s on-going business.

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 FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO RULE 83

 Duplicative expenses – Expenses related to items that will run-off as we integrate the
acquired business into the Company. These expenses included salaries and benefits, rent, licenses and subscriptions. Management considers these a cost of the acquisition and not representative of the costs of running the Company’s on-going
business, therefore, the duplicative costs are included as adjustments to arrive at non-GAAP net income.

 Amortization of intangible assets
– Amortization of intangible assets acquired.

 The Company believes that the charges described above exist as a result of the
consummation of the acquisitions and, therefore, would not recur as part of the future costs to operate the acquired businesses.

3.
You disclose that your adjustments are mainly to remove certain acquisition related expenses. Please tell us why you exclude these acquisition related expenses due to them “not being representative of on-going
businesses.” In this regard, we note that you have completed 10 acquisitions in the past three years and you disclose in your 2015 Form 10-K that acquisitions of businesses has, and will continue to be, a key strategy to achieve growth. Please
tell us whether there were similar charges or gains within the prior two years and how you determined that you are not reasonably likely to have similar charges or gains within two years. Please refer to Regulation G and Item 10(e) of
Regulation S-K.

 Response:

In executing our growth strategy, we take advantage of the consolidation among mid-tier firms, which we believe provides us opportunities in
our global wealth and institutional group segments. We do not create specific growth or business plans for any particular type of acquisition, or focus on specific firms or geographic expansion, nor do we establish quantitative goals, such as
intended numbers of new hires or new office openings. Our corporate strategy has, for several years now, been to be in a position to take advantage of opportunities as they arise, while maintaining sufficient levels of capital. Over the last several
years, we believe we have demonstrated an ability to identify, effect, and integrate attractive acquisition opportunities. We believe the current environment and market dislocation will continue to provide us with the ability to thoughtfully
consider acquisitions on an opportunistic basis.

 While we have completed a number of strategic acquisitions over the past several years,
each acquisition is unique. The Company believes that duplicative costs and stock-based compensation costs directly related to retention, which have historically been described as acquisition-related expenses, were incurred as a direct result of the
consummation of a specific acquisition and, in each case, those expenses will not recur as part of the future costs to operate the acquired businesses. Given our recent acquisitions and the impact of the purchase accounting adjustments, we believe
that the manner in which we present acquisition-related expenses aids users of the Company’s financial statements in better understanding the effect of each particular acquisition and integration on the financial results of the Company’s
on-going operations. Further, the same non-GAAP information is also provided to the Company’s executive management and Board of Directors so that they may use it to assess the Company’s consolidated year-over-year performance.

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 FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO RULE 83

 Form 10-K for the Fiscal Year Ended December 31, 2015

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Year Ended December 31, 2015 Compared with Year Ended December 31, 2014, page 53

4.
You disclose on page 54 that you had an increase in strategic advisory fees of 8.9% in 2015, but you disclose reasons why your investment banking revenues decreased in 2015. Since the advisory fees represent a
significant line of business, please revise to discuss and analyze the reasons for the increase in your strategic advisory fees.

Response:

 Please be
advised that the Company will revise its disclosure in its amended Form 10-K to address the Staff’s comment. Appendix No. 1 sets forth the disclosures the Company intends to file on Amendment No. 1 to our Annual Report on Form 10-K.

5.
You disclose on page 54 that you had a decrease in compensation and benefits expense in 2015, but you disclose reasons why your compensation and benefit expenses increased in 2015. Since compensation and benefit
expenses are material expenses, please revise to discuss and analyze the reasons for the decrease in your compensation and benefits expenses.

Response:

 Please be
advised that the Company will revise its disclosure in its amended Form 10-K to address the Staff’s comment. Appendix No. 1 sets forth the disclosures the Company intends to file on Amendment No. 1 to our Annual Report on Form 10-K.

 Consolidated Financial Statements, pages 77 – 78

6.
Please amend your Form 10-K to remove the unaudited reference to your Consolidated Statements of Operations, Consolidated Statements of Comprehensive Income and Notes to Consolidated Financial Statements. Refer to
Item 8 of Form 10-K. In addition, refer to the second paragraph under Basis of Presentation in Note 1 – Nature of Operations and Basis of Presentation. Please tell us what information you have omitted that you normally include in your
annual consolidated financial statements and why you believe this omission is appropriate.

 Response:

Please be advised that the Company will remove the unaudited reference to our Consolidated Statement of Operations, Consolidated Statements of
Comprehensive Income, and Notes to the Consolidated Financial Statements. The Company will also revise its disclosure in Note 1 – Basis of Presentation. Appendix No. 1 sets forth the disclosures the Company intends to file on Amendment
No. 1 to our Annual Report on Form 10-K.

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 FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO RULE 83

 Notes to Consolidated Financial Statements

Note 3 – Acquisitions, page 92

7.
Please provide us revised proposed disclosure that states the total amount of consideration paid for the Barclays’ Wealth and Investment Management, Americas and the Sterne Agee Group, Inc. acquisitions.
Disclose how the acquisitions were funded (e.g. cash, debt or equity). Please include the allocation of the purchase price to the assets acquired and liabilities assumed for each acquisition. In addition, for the Barclays’ acquisition, we note
you determined that the acquisition was not considered to be material. Please provide us your significance test under Rule 3-05 of Regulations S-X.

[Confidential Treatment requested for this response.]

Please be advised that the Company concluded that the Barclays’ Wealth and Investment Management, Americas (“Barclays”)
business was not significant and did not qualify as a material acquisition. Therefore, we did not include the allocation of the purchase price to the assets acquired and liabilities assumed for the acquisition.

Please be advised that the Company concluded that the Sterne Agee Group, Inc. business was not significant and did not qualify as a material
acquisition. Therefore, we did not include the total amount of consideration paid, how the acq