SecProbe.io

United States securities and exchange commission logo
March 5, 2024
Kent G. Townsend
Chief Financial Officer
Capitol Federal Financial, Inc.
700 South Kansas Avenue
Topeka, Kansas 66603
Re:Capitol Federal Financial, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2023
File No. 001-34814
Dear Kent G. Townsend:
            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-K filed for the Fiscal Year Ended September 30, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Average Balance Sheets, page 42
1.We note your presentation of various Non-GAAP financial measures on page 43, and
elsewhere, excluding the impact of the securities and leverage strategies. Please address
the following:
•For each Non-GAAP measure presented, revise your disclosures to include a more
fulsome discussion of what each measure represents, how it is defined, how it is used
and why it is meaningful to investors.
•Tell us and revise your disclosures to disaggregate and explain each of the individual
adjustments comprising the securities and leverage strategies. Your response and
revised disclosure should include a reconciliation and calculation of each component
to these measures (e.g., numerator and denominator) to the nearest GAAP financial
measure and identify the financial statement line items and amounts excluded for
each period.
•Tell us if you intend to continue using and disclosing these Non-GAAP measures in
your future filings.
•Provide us with an analysis explaining how you considered the nature of the Non-

 FirstName LastNameKent G. Townsend
 Comapany NameCapitol Federal Financial, Inc.
 March 5, 2024 Page 2
 FirstName LastName
Kent G. Townsend
Capitol Federal Financial, Inc.
March 5, 2024
Page 2
GAAP adjustments relating to your leverage strategy, and whether it results in
individually tailored accounting. Refer to Question 100.04 of the Division of
Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP
Financial Measures.
Comparison of Operating Results for the Years Ended September 2023 and 2022, page 44
2.Please revise your disclosures, in future filings, to provide a more specific definition and
thorough discussion of the “leverage strategy” including the factors considered when
utilizing the strategy. If material, your disclosure should discuss and identify the specific
types of assets and liabilities utilized in exercising the strategy in each period presented
and the specific impact the strategy had on these identified assets and liabilities as well as
any related impact on revenues, expenses and capital ratios. In addition, expand your
liquidity and capital resources discussion for additional details, thresholds for suspension,
quantification and information on your leverage strategy.
            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 Marc Thomas at 202-551-3452 or Robert Klein at 202-551-3847 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance