SecProbe.io

Mail Stop 4720
September 8 , 2016

Aaron P. Graft
President and Chief Executive Officer
Triumph Bancorp, Inc.
12700 Park Central Drive
Suite 1700
Dallas, TX 75251

Re: Triumph Bancorp, Inc.
  Registration Statement on Form S-3
Filed  August 16, 2016
  File No.  333-213169

Dear Mr. Graft :

We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information .  If you do not believe our com ments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, w e may have  additional comments.

Where You Can Find More Information, page 2

1. We note your Annual Report on Form 10 -K for the year ended December 31, 2015
incorporates the Part III information from your proxy statement.  Please add your proxy
statement f iled on April 1, 2016 to the list of documents incorporated by reference.
Please refer to Item 10(d) of Regulation S -K.

Description of Debt Securities, page 10

2. We note your disclosure on  pages 7 and 11  on you  disclose how you r debt securities may
be exc hangeable for “securities of an entity not affiliated with us” and “convertible into
other securities of ours or another issuer,” respectively .  To the extent you offer and sell
the underlying third party securities, please confirm that you will comply with the
registration and disclosure requirements of the Securities Act and any other applicable

Aaron P. Graft
Triumph Bancorp, Inc.
September 8, 2016
Page 2

 rules and regulations.  Please also confirm that yo u will include disclosure as necessary in
the applicable prospectus supplement or other offering materials, including, as necessary,
any required financial statement and non -financial statement disclosure about the issuer
of such securities.  For guidance,  please refer to the Morgan Stanley & Co., Inc. no -action
letter (June 24, 1996) and Securities Act Sections Compliance and Dis closure
Interpretation 203.03

Description of Purchase Contracts, page 29

3. We note that you may issue purchase contracts for the  purchase of certain reference
assets, including securities.  However, it is not clear how these contracts should be
characterized for purposes of the federal securities laws.  For example, the disclosure in
the filing indicates that contracts may be physi cally settled or cash settled and that the
amount of the payout may be linked to the value, performance or level of the reference
assets.  The disclosure in the filing also indicates that the reference assets may be
comprised of an index or indices of secu rities.  Based on this disclosure it appears that
these contracts may have characteristics associated with forwards, options and security -
based swaps.  Please provide us with your legal analysis as how these contracts should be
appropriately characterized under the federal securities laws.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act ru les require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement , please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effect ive, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Aaron P. Graft
Triumph Bancorp, Inc.
September 8, 2016
Page 3

 Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requ esting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Ple ase allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact  Eric Envall, Staff Attorney  at (202) 551 -3234  or me at  (202) 551 -3338
with any questions.

Sincerely,

 /s/ Dietrich A. King

 Dietrich A.  King
Assistant Director
Office of Financial Services

cc: Mark Veblen, Wachtell, Lipton, Rosen & Katz