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December 8, 2023
Benjamin Clouse
Chief Financial Officer
CrossFirst Bankshares, Inc.
11440 Tomahawk Creek Parkway
Leawood, KS 66211
Re:CrossFirst Bankshares, Inc.
Form 10-Q for Fiscal Quarter Ended September 30, 2023
File No. 001-39028
Dear Benjamin Clouse:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-Q for Fiscal Quarter Ended September 30, 2023
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Loan Portfolio, page 65
1.We note the tabular disclosure on page 65 detailing the composition of your gross loan
portfolio, which includes commercial real estate (“CRE”). Given the significance of CRE
in your total loan portfolio, please revise your disclosures, in future filings, to further
disaggregate the composition of your CRE loan portfolio by borrower type (e.g., by office,
hotel, multifamily, etc.), geographic concentrations and other characteristics (e.g., current
weighted average and/or range of loan-to-value ratios, occupancy rates, etc.) material to
an investor's understanding of your CRE loan portfolio. In addition, revise to describe the
specific details of any risk management policies, procedures or other actions undertaken
by management in response to the current environment.
Item 3. Quantitative and Qualitative Disclosures About Market Risk, page 72
2.We refer you to the discussion regarding internal policies for interest rate risk on page 52
of the Form 10-K for the fiscal year ended December 31, 2022. You disclose what appear

 FirstName LastNameBenjamin Clouse
 Comapany NameCrossFirst Bankshares, Inc.
 December 8, 2023 Page 2
 FirstName LastName
Benjamin Clouse
CrossFirst Bankshares, Inc.
December 8, 2023
Page 2
to be established limits for net interest income at risk for the subsequent one-year period
of, for example, 10% for a 200 basis point shift and 15% for a 300 basis point shift under
an instantaneous parallel shift of the yield curve. Based on the disclosure on page 72 of
the Form 10-Q for the quarter ended September 30, 2023, it appears that the company was
outside established policy limits. We also note the statement on page 72 that you are
monitoring interest rate sensitivity closely due to a significant amount of loans repricing
within the twelve-month period following September 2023, and $5.3 billion of interest-
bearing liabilities that mature or reprice over the same twelve-month period. You also
state in recent quarterly reports that you are reviewing additional options to manage the
statement of financial condition sensitivity based on the interest rate environment and
anticipated composition of assets and liabilities. Please revise future filings to provide a
materially complete description of how you seek to manage risks due to changes in
interest rates and other material impacts on your operational facts and circumstances,
including any management or corporate governance controls or procedures for identifying
and responding to rapid increases and decreases in interest rates due to or as a result of
exogenous or unknown factors. For example, please clarify the Board-approved limits
and, with a view to disclosure, advise us of the extent to which the ALCO has approved
risk profiles that do not conform to management and Board risk policies. Clarify the
extent to which such limits and other policies and controls have been changed due to the
economic and other developments referenced elsewhere.
            In closing, 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.
            Please contact Shannon Davis at 202-551-6687 or Amit Pande at 202-551-3423 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance