SecProbe.io

December 13, 2016
Mail Stop 4720

Via E -mail
Ms. Nancy B. Davis
Chief Financial Officer
Stock Yards Bancorp, Inc.
1040 East Main Street
Louisville, Kentucky 40206

Re: Stock Yards  Bancorp, Inc .
 Form 10-K for the Fiscal Year Ended December 31, 2015
 Filed March 4, 2016
   File No. 001-13661

Dear Ms. Davis :

We have review ed your filing  and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments appl y to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

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

Item 7.   Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 15

Provision for Loan Losses, page 22

1. We note that per page 31, non -performing loans includes troubled debt restructurings
(TDRs), including accruing TDRs.  On page 22 you state that the decrease in non -
performing loans during 2015 was due to a decrease in loans classified as TDRs.  On
page 22, you state that TDRs, which are currently accruing interest, decreased from $6.4
million at December 31, 2014 to $1.1 mil lion at December 31, 2015, reflecting the
migration of one lending relationship to performing status.  Lastly, we note your
disclosure on page 49, that if a loan is restructured at a market rate for a new loan with
comparable risk, no principal forgiveness  has been granted, and the loan is not impaired
based on the terms specified by the restructuring agreement, it shall be removed from

Nancy B. Davis
Stock Yards Bancorp, Inc.
December 13, 2016
Page 2

 restructured status generally after six months of performance.  Please respond to the
following:
 Quantify all loans that h ave been removed from TDR designation for the years ended
December 31, 2015, 2014, 2013 and the nine months ended September 30, 2016.
 Describe the factors leading to the removal of the TDR designation for these loans
during the applicable periods.
 Tell us how much of the decrease in non -performing loans during 2015 was due to
removal of the TDR designation, versus pay -off or charge -off of the TDR loan.
 Explain in further detail why the return of TDRs that were accruing interest to
performing status reduces the level of non -performing loans in your portfolio.
 Clarify if all of your TDRs are accruing interest for all periods presented.  In this
regard, we note that the disclosed amount of TDRs accruing interest as of December
31, 2015 and 2014 agrees to the to tal amount of TDRs included in non -performing
loans for those periods.

Non-Interest Income and Non -Interest Expenses, page 23

2. We note that most recurring fees, which generally comprise over 95% of your investment
management and trust (“IM&T”) revenue, an d nearly 14% of your total revenue, are
earned for managing accounts based on a percentage of market value on a monthly basis.
Please address the following:
 Disclose, if true, in future filings that these recurring fees are based upon the value of
your as sets under management (AUM).
 Tell us if you have the right under any of your contracts to earn performance fees on
your AUM. If so, revise future filings to disaggregate these fees from your investment
management fees and disclose your policy for recogni zing revenue from performance
fees.
 Provide a roll -forward of your AUM by investment strategy (i.e. equities, fixed
income, cash and other assets) that separately presents gross client inflows, gross
client outflows, market appreciation/(depreciation), and  foreign currency translation
adjustments (if applicable).
 Disclose the fee arrangement (e.g. 1% of AUM) earned for managing accounts
separately by type of investment strategy.

Allowance for Loan Losses, page 32

3. We note during the second quarter of 2015,  you extended the historical period used to
capture Bancorp’s historical loss ratios from 12 quarters to 24 quarters.   Please address
the following:

Nancy B. Davis
Stock Yards Bancorp, Inc.
December 13, 2016
Page 3

  Tells us, and discuss in future filings, the specific portfolio segments and classes of
loans which were impacted by this change.
 Tell us how you adjusted the qualitative factors discussed on page 49 as a result of
your change in the historical look -back  period.
 Quantify the impact of this change in methodology for the periods presented.  In this
regard, it appears you did not record any provision for loan losses (or reversals of the
provision for loan losses) for the first three quarters of 2015.  In li ght of the stated
purpose for the change in methodology, please tell us in more detail why there did not
appear to be a bigger impact on your allowance for loan losses.

Income Taxes, page 51

4. We note your disclosure that in 2014, the amortization method f or investments in new
markets and historic tax credit partnerships was changed from the effective yield method
to the cost method, which matches the amortization period with the time frame over
which the credits are realized and amortization expense is rec orded as other non -interest
expense.  Please respond to the following:
 Tell us the basis for your change in accounting principle  for the investments in new
markets and historic tax credit partnerships .
 Tell us whether you reflected this change in accountin g principle retrospectively as
required by ASC 250 -10-45-5.  If not, please provide your analysis as to why it was
impracticable to do so.
 Tell us whether you obtained a preferability letter from your Independent Registered
Public Accounting Firm.  If so, please tell us why this was not filed as required by
Item 601 of Regulation S -K.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Yolanda Trotter, Staff Accountant , at (202) 551 -3472  or me at (202)
551-3512  with any questions.

Sincerely,

 /s/ Stephanie L. Sullivan

Stephanie L. Sullivan
Senior Assistant Chief Accountant
Office of Financial Services