SecProbe.io

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 SOUTHERN MISSOURI BANCORP, INC. 2991 Oak Grove Road Poplar Bluff, MO 63901 ​ April 21, 2025 ​ Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549 RE: Southern Missouri Bancorp, Inc. Request for Acceleration of Effectiveness of Registration Statement on Form S-3 (File No. 333-285876) Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Southern Missouri Bancorp, Inc. hereby requests acceleration of the effective date of the above-referenced registration statement to April 24, 2025 at 5:00 p.m., Eastern Daylight Time, or as soon thereafter as is practicable. ​ Sincerely, SOUTHERN MISSOURI BANCORP, INC. By: /s/Stefan Chkautovich ​ ​ ​ ​ ​ ​ Name: Stefan Chkautovich Title: Executive Vice President and Chief Financial Officer (Principal Financial Officer)

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 26, 2025

Stefan Chkautovich
Chief Financial Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, MO 63901

 Re: Southern Missouri Bancorp, Inc.
 Registration Statement on Form S-3
 Filed March 18, 2025
 File No. 333-285876
Dear Stefan Chkautovich:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Aisha Adegbuyi at 202-551-8754 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Martin L. Meyrowitz, Esq.
</TEXT>
</DOCUMENT>

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November 3, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Southern Missouri Bancorp, Inc.

    Request for Acceleration of Effectiveness
of Registration Statement on Form S-4

    (SEC File No. 333-268110)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities
Act of 1933, as amended, Southern Missouri Bancorp, Inc. (the “Company”) hereby requests acceleration of the effective
date of the above-referenced Registration Statement on Monday, November 7, 2022, at 4:30 p.m., Eastern Time, or as soon thereafter
as is practicable.

The Company requests that it be notified of the
effectiveness of the Registration Statement by telephone call to Marty Meyrowitz of Silver Freedman Taff & Tiernan LLP, the registrant’s
legal counsel, at (202) 295-4527.

    Very truly yours,

    Southern Missouri Bancorp, Inc.

    /s/ Greg A. Steffens

    Greg A. Steffens

    Chairman and Chief Executive Officer

United States securities and exchange commission logo
November 3, 2022
Greg A. Steffens
Chief Executive Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, MO 63901
Re:Southern Missouri Bancorp, Inc.
Registration Statement on Form S-4
Filed November 2, 2022
File No. 333-268110
Dear Greg A. Steffens:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Sonia Bednarowski at 202-551-3666 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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​

​

​

January 4, 2022

​

​

VIA EDGAR

​

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C.  20549

Re:Southern Missouri Bancorp, Inc.

Request for Acceleration of Effectiveness of Registration Statement on Form S-4

(SEC File No. 333-261450)

 ​

Ladies and Gentlemen:

​

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Southern Missouri Bancorp, Inc. (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement on Thursday, January 6, 2022, at 10:00 a.m., Eastern Time, or as soon thereafter as is practicable.

​

The Company requests that it be notified of the effectiveness of the Registration Statement by telephone call to Martin Meyrowitz of Silver Freedman Taff & Tiernan, LLP, the registrant’s legal counsel, at (202) 295-4527.

​

 ​

​

​

Very truly yours,

​

Southern Missouri Bancorp, Inc.

​

​

/s/ Greg Steffens​ ​​ ​​ ​

Greg Steffens

President and Chief Executive Officer

​

United States securities and exchange commission logo
December 6, 2021
Greg A. Steffens
President and Chief Executive Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, MO 63901
Re:Southern Missouri Bancorp, Inc.
Registration Statement on Form S-4
Filed December 1, 2021
File No. 333-261450
Dear Mr. Steffens:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Eric Envall at (202) 551-3234 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

February 6, 2020
Matthew T. Funke
Chief Financial Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, Missouri 63901
Re:Southern Missouri Bancorp, Inc.
Form 10-K for Fiscal Year Ended June 30, 2019
Filed September 13, 2019
File No. 000-23406
Dear Mr. Funke:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Finance

January 30, 2020
Matthew T. Funke
Chief Financial Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, Missouri 63901
Re:Southern Missouri Bancorp, Inc.
Form 10-K for Fiscal Year Ended June 30, 2019
Filed September 13, 2019
File No. 000-23406
Dear Mr. Funke:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended June 30, 2019
Report of Independent Registered Public Accounting Firm, page 68
1.Please amend your Form 10-K to:

•Revise the accountants' reports on the audit of the financial statements and the audit
of internal control over financial reporting to include the signature of the independent
registered public accounting firm.  Refer to Rule 2-02 of Regulation S-X for
guidance.
•Revise the consent included as Exhibit 23 to include the signature of the independent
registered public accounting firm.
•Include updated certifications as Exhibits 31 and 32.
            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.

 FirstName LastNameMatthew T.  Funke
 Comapany NameSouthern Missouri Bancorp, Inc.
 January 30, 2020 Page 2
 FirstName LastName
Matthew T.  Funke
Southern Missouri Bancorp, Inc.
January 30, 2020
Page 2
            You may contact John Spitz, Staff Accountant, at (202) 551-3484 or Michael Volley,
Staff Accountant, at (202) 551-3437 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

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SOUTHERN MISSOURI BANCORP, INC.

2991 Oak Grove Road

Poplar Bluff, Missouri 63901

September 7, 2018

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:       Southern Missouri Bancorp, Inc.

Request for Acceleration of Effectiveness of

Registration Statement on Form S-4 (File No. 333-226378)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the above-referenced registration statement to Tuesday, September 11, 2018, at 10:00 a.m., Eastern Time, or as soon thereafter as is practicable.

Sincerely,

SOUTHERN MISSOURI BANCORP, INC.

By:

/s/ Matthew T. Funke

Name:

Matthew T. Funke

Title:

Executive Vice President and Chief Financial Officer

August 3, 2018
Matthew Funke
Executive Vice President and Chief Financial Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, MO 63901
Re:Southern Missouri Bancorp, Inc.
Registration Statement on Form S-4
Filed July 27, 2018
File No. 333-226378
Dear Mr. Funke:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Jessica Livingston at 202-551-3448 with any questions.
Division of Corporation Finance
Office of Financial Services

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SOUTHERN MISSOURI BANCORP, INC.

2991 Oak Grove Road

Poplar Bluff, Missouri 63901

December 5, 2017

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Southern Missouri Bancorp, Inc.

Request for Acceleration of Effectiveness of

Registration Statement on Form S-4 (File No. 333-221641)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the above-referenced registration statement to Friday, December 8, 2017, at 10:00 a.m., Eastern Time, or as soon thereafter as is practicable.

Sincerely,

SOUTHERN MISSOURI BANCORP, INC.

By:

/s/ Matthew T. Funke

Name:

Matthew T. Funke

Title:

Executive Vice President and Chief Financial Officer

Mail Stop 4720

November 27, 2017

Matthew T. Funke
Executive Vice President and Chief Financial Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, MO 63901

Re: Southern Missouri Bancorp, Inc.
  Registration Statement on Form S-4
Filed  November 17, 2017
  File No.  333-221641

Dear Mr. Funke :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Christopher Dunham, Staff Attorney, at (202) 551 -3783  with any
questions .

Sincerely,

 /s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Services

cc: Martin  L. M eyrowitz , P.C.

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SOUTHERN MISSOURI BANCORP, INC.

2992 Oak Grove Road

Poplar Bluff, Missouri 63901

May 5, 2017

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

RE:

Southern Missouri Bancorp, Inc. ("we or the "Company")

Request for Acceleration of Effectiveness of

Registration Statement on Form 5-4 (File No. 333-217454)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the above-referenced registration statement to Monday, May 8, 2017 at 10:30 a.m., Eastern Time, or as soon thereafter as is practicable.

Sincerely,

SOUTHERN MISSOURI BANCORP, INC.

By:

/s/ Matthew T. Funke

Name:

Matthew T. Funke

Title:

Chief Financial Officer

Mail Stop 4720

May 4, 2017

Via E -mail
Matthew T. Funke
Executive Vice President and Chief Financial Officer
Southern Missouri Bancorp, Inc.
2991 Oak Grove Road
Poplar Bluff, MO 63901

Re: Southern Missouri Bancorp, Inc.
  Registration Statement on Form S -4
Filed April 25, 2017
  File No. 333-217454

Dear Mr. Funke :

This is to advise you that we have not reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  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.

Pleas e contact David Lin at (202) 551 -3552 with any question s.

Sincerely,

/s/ Era Anagnosti

Era Anagnosti
Legal Branch Chief
Office of Financial Services

cc: Martin L. Meyrowitz, P.C.

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

June 6, 2011
Mail Stop 4720  By U.S. Mail and facsimile to 202-337-5502

Greg A. Steffens
President and Chief Executive Officer Southern Missouri Bancorp, Inc. 531 Vine Street Poplar Bluff, Missouri  63901
 Re: Southern Missouri Bancorp, Inc.
Registration Statement on Form S-1
  Filed May 10, 2011   File No. 333-174113

 Dear Mr. Steffens:
We have reviewed your registration statement 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 this letter within ten business days by amending your registration
statement and providing the requested information, including a draft of your proposed disclosures to be made in future filings clearly identifying new and deleted disclosure
, or by
advising us when you will provide the requested response.   If you do not believe our comments
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, we may have additional comments.     General

1. In the next amendment fill-in, as far as practicable, all blanks.

2. Because you may use proceeds to redeem TARP CPP preferred stock, Include a pro
forma illustration of the impact on EPS and the capitalization table from the

Southern Missouri Bancorp, Inc. - Form S-1
Mr. Greg A. Steffens
June 6, 2011 Page 2

dividends or other payments on the preferred versus dilution from issuing more common.
 Cover Page

3. Quantify on the cover sheet the percentage of shares offered to total outstanding
shares.

4. Revise the cover page to briefly describe the underwriting arrangements, i.e., a firm
commitment.
 Use of Proceeds, page 6 and 24

5. Clarify in the Use of Proceeds disclosure the percentage and dollar amount of
proceeds to be contributed to the bank and update, as far as practicable, the specific anticipated uses of the proceeds retained by the company.

Prospectus Summary
Recent Acquisitions, page 1

6. Revise both acquisition summaries to indicate the profit/loss recognized and indicate
whether or not the purchases were dilutive or accretive to earnings.

7. Revise the summary to disclose if officers and directors are committed to purchase
shares in the offering and, if so, indicate the amount. In addition, disclose the shares being reserved, their current holdings, their percentage of total and the percentage they will hold after the offering assuming any commitments.
  March 31, 2011 Form 10-Q

 General

8. We note your effective income tax rate in creased to 33% from 20% for the nine
months ended March 31, 2011 as compared to the nine months ended March 31,
2010.  Considering this significant change, please revise future filings, including
future interim filings, to disclose th e information required by ASC 740-10-50 and
highlight material changes in income tax items in your MD&A.

9. We note your disclosure on page 12 that you may be required from time to time to
modify or extend the terms of your speculative construction and land development loans and your disclosure on page 33 that you had no troubled debt restructurings as of March 31, 2011.  Please tell us in detail and revise future filings to disclose the

Southern Missouri Bancorp, Inc. - Form S-1
Mr. Greg A. Steffens
June 6, 2011 Page 3

amount of modifications performed during th e periods presented.  Also disclose how
you concluded that your modifications s hould not be accounted for as TDRs.
Specifically, explain the key factors you considered to determine if the modification represented a concession and whether the borrower was experiencing financial difficulties.
 Note 2: Fair Value Measurements, page 6

10. Please revise future filings to disclose the total gains and losses for each major
category of asset or liability measured at fair value on a nonrecurring basis during the periods presented.  Refer to ASC 820-10-50-5a and 820-10-55-64.
 Impaired Loans (Collateral Dependent), page 7

11. Please revise your future filings to disc lose how often you obtain updated appraisals
for your impaired collateral dependent loans and if this policy varies by loan type.  Describe in more detail the types of adjustments you make to appraised values, including those made as a result of outdated appraisals.  Discuss how you consider the potential for outdated appraisal values in your determination of the allowance for loan losses.  Also, quantify the amount of collateral dependent loans for which you are using an appraisal performed within the past 12 months to serve as the primary basis of your valuation.

12. You disclose that you may
 apply selling discounts to the underlying collateral value
to determine fair value for collateral dependent loans.  We note that the guidance in ASC 310-10-35-23 indicates that the fair value of collateral shall be adjusted to consider estimated costs to sell.  Please tell us if you have measured impairment on any collateral dependent loans without estimating costs to sell.  If so, please tell us how your measurement is consistent with the above guidance and estimate the total amount of costs to sell.  If not, please revise your disclosure in future filings accordingly.
 Note 3: Securities, page 9

13. We note your disclosure regarding your other-than-temporary impairment policies
related to your pooled trust preferred securities.  Please provide us your analysis of the present value of cash flows expected to be collected for the Trapeza CDO XIII, Ltd., class B and Preferred Term Securities XXIV, Ltd., class B1 securities and address the following:
 • Deferrals and defaults:

a. Please tell us in detail how you develop your estimate of future deferrals and defaults.

Southern Missouri Bancorp, Inc. - Form S-1
Mr. Greg A. Steffens
June 6, 2011 Page 4

b. You disclose that you assume future additional default rates are 36 basis points for all of
your securities and that you use the actual collateral attributes, including various performance indicators (profitability, capital ratios, asset quality, etc.) as an input in your cash flow analysis.  Please clearly explain how you use the actual collateral attributes in your cash flow analysis.  If you use the actual collateral attributes in determining future additional defaults, please explain to us how your consideration resulted in using the same estimate of future defaults (36 basis poi nts) for your different securities considering
the different credit characteristics of the collateral underlying each security.

c. Please tell us how you developed your recovery rate of 34% on issuers currently
deferring interest.  Specifically, explain if you used the credit characteristics of bank currently deferring interest.
 • Prepayments:  You disclose that your cash flow estimates assume that institutions in excess of $15 billion (or likely to grow to that size) will prepay their obligations by 2013, due to the capital treatment under the regulatory reform bill recently passed.  Please provide us your analysis which supports this assumption specifically discussing how you determined that $15 billion was an appropriate criterion.  For the 2 securities identified above:

a. Please provide us a sensitivity analysis of the impact on your credit OTTI cash flow
analysis if you changed your prepayment assumption to produce a significantly lower number of banks prepaying their obligations and having them prepay no sooner than 2013.
b. Please provide us a listing of the banks serving as collateral detailing the asset size of
each bank and identifying which banks met your criteria to prepay and in what year you assumed the banks would prepay their obligation.
c. Please tell us if you are aware of any individual bank in a pooled trust preferred security
that has prepaid their obligation and the facts and circumstances surrounding the prepayment (was the bank acquired, etc.).  If you are not aware of any, please tell us how this fact impacted your prepayment assumption.
d. Please explain to us the redemption provisions (time-based, other special redemption
provisions, etc.) of these securities that impact the ability of an individual bank to prepay their obligation and explain how you considered the provisions in your prepayment assumption.

Southern Missouri Bancorp, Inc. - Form S-1
Mr. Greg A. Steffens
June 6, 2011 Page 5

e. Please tell us if these securities have capital replacement covenants and any other
covenants restricting or impacting redemption or prepayment, explain the terms of the covenants and tell us how you considered the covenants in your prepayment assumption.
f. Please tell us if banks that were currently deferring interest payments were assumed to
prepay their obligations.  If so, explain your rationale.
 • Principal In Kind (PIK):  Please tell us in detail and revise future filings to discuss all the facts and circumstances related to your securities receiving PIK.  Specifically discuss:

a. The relevant provisions in your securities that allow them to receive PIK.

b. The reason why your securities are receiving PIK.

c. The risk to security holders.

d. How PIK impacts the different tranches of your securities and how it impacts the tranche
that you own.
e. When you expect your securities to begin paying cash interest.

f. How the fact that your securities were receivi ng PIK was incorporated in your analysis of
the present value of cash flows expected to be collected.
 Note 4: Loans, page 11

14. Please revise future filings to discuss how your accounting for loans acquired with
deteriorated credit quality impacts your credit metrics and trends.  Specifically identify the credit metrics and trends most impacted and discuss the comparability between periods and with other institutions.  Also discuss how you classify these loans as non-accrual, impaired, loans > 90 days and accruing, or as a trouble debt restructuring.  For example, discuss if these loans are considered impaired and on non-accrual status immediately after acquisition and the reasons for your determination.
 15. Please revise future filings to clearly state if purchased impaired loans are included in
the credit quality disclosures (non-accrual, impaired, nonperforming, classified loans, etc.).  If they are included, please quantify the amount.

16. Please revise future filings to disclose how you determine it is appropriate to continue
to accrue interest on loans past due 90 days or more.

Southern Missouri Bancorp, Inc. - Form S-1
Mr. Greg A. Steffens
June 6, 2011 Page 6

17. Please revise future filings to disclose how you determine that the uncollectability of
a loan balance is confirmed.

18. You disclose that loans are collectively evaluated for impairment based on your
historical loss experience.  Please revise future filings to specify, by portfolio segment, how many years of historical losses (i.e. charge-offs) you use to measure impairment.  Also, identify any changes to look-back periods that were implemented during the periods presented, discuss the reasons for any changes and quantify the impact on your allowance for loan losses.

19. You disclose on page 15 that your allowance for loan losses is based on historical
loss experience adjusted for changes in trends, conditions and other relevant factors that affect repayment of the loans.  Please revise future filings to:

a. Present additional granularity regarding any adjustments made to historical
losses;

b. Discuss adjustments made by portfolio segment for each period presented and
discuss the specific facts and circumstances for the adjustments; and

c. Discuss the amount of the allowance for loan losses that is attributable to these
adjustments as of each period end presented and provide a discussion of the facts and circumstances related to any trends in this amount.

20. Please revise future filings to disclose your policy for placing loans on nonaccrual
status.  Refer to ASC 310-10-50-6(a).

21. Please revise future filings to disclose your policy for recording payments received on
nonaccrual loans.  Refer to ASC 310-10-50-6(b).

22. Please revise future filings to disclosure your policy for resuming the accrual of
interest on nonaccrual loans.  Refer to ASC 310-10-50-6(c).
 23. Please revise future filings to disclose your policy for determining past due or
delinquency status.  Refer to ASC 310-10-50-6(e) for guidance.

24. Please revise future filings to explicitly disclose your policy for determining which
loans are individually assessed for impair ment.  Refer to ASC 310-10-50-15(d).
 25. In the table on page 14, you disclose that you collectively evaluate all or almost all of
your construction real estate, commercial real estate and commercial loans for impairment.  Please explain to us why you do not individually evaluate some of these

Southern Missouri Bancorp, Inc. - Form S-1
Mr. Greg A. Steffens
June 6, 2011 Page 7

loans for impairment since these types of loans generally have a larger balance and are not homogeneous.

26. Please future filings to disclose your policy for recognizing interest income and how
cash receipts are recorded on impaired loans.  Refer to ASC 310-10-50-15(b).

27. Please revise future filings to disclose the information required by ASC 310-10-50-
15(c)(1), (2) and (3) for each period for which results of operations are presented.
 28. Please revise future filings to disclose the amount of interest income that represents
the change in present value attributable to the passage of time or disclose that you recognize this amount as bad-debt expense.  Refer to ASC 310-10-50-19.
 29. You disclose on page 17 total nonaccrual loans of approximately $103,000 and total
impaired loans of approximately $11,182,000 at March 31, 2011.  Please tell us in detail and revise future filings to reconcile and to clearly explain the relationship between loans classified as nonaccrual and impaired.  Specifically discuss why certain loans are considered impaired but not placed on nonaccrual status.
 Credit Quality Indicators, page 16

30. Please revise future filings to explicitly disclose the date or range of dates for which
your loan risk rankings were updated.  Refer to ASC 310-10-50-29(c).
 Note 5: Accounting for Certain Loans Acquired in a Transfer, page 17

31. Please tell us in detail and revise future filings to disclose your income recognition
policy related to the purchase impaired loans in which you cannot reasonably estimate cash flows expected to be collected.
 32. Please explain to us your fair value methodology for your purchased impaired loans
considering your disclosure that you cannot reasonably estimate cash flows expected to be collected.
 Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
23

33. Please revise your MD&A in future filings  to quantify the amount of one- to four-
family residential mortgage loans with LTV’s greater than 80% with no PMI and the amount of HELOC’s outstanding at period end and provide an analysis of the credit
risk associated with these loans.

Southern Missouri Bancorp, Inc. - Form S-1
Mr. Greg A. Steffens
June 6, 2011 Page 8

 Average Balance Sheet for the Three- and Nine-Month Periods Ended March 31, 2011 and 2010,
page 28

34. We note your disclosure on page 25 that your results of operations depend primarily
on your net interest margin which is directly impacted by the interest rate environment.  Considering this disclosure, please revise future interim filings to include a rate/volume analysis.
 Results of Operations – Comparison of the Three- and Nine-Month Periods Ended March 31,
2011 and 2010
 Provisions for Loan Losses, page 31

35. You disclose that the increase in the provision for loan losses to $1.2 million from
$101,000 during the three months ended March

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SANDLER O’NEILL & PARTNERS, L.P.

919 Third Avenue, 6th Floor

New York, New York 10022

November 15, 2011

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Southern Missouri Bancorp, Inc. (the “Company”)

Request for Acceleration of Effectiveness of

Registration Statement on Form S-1 (File No. 333-174113)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby join Southern Missouri Bancorp, Inc. in requesting acceleration of the effective date of the above-referenced registration statement to November 16, 2011 at 3:00 p.m., Eastern Standard Time, or as soon thereafter as is practicable.

Sincerely,

SANDLER O’NEILL & PARTNERS, L.P.

By:

Sandler O’Neill & Partners Corp., the sole general partner

By:

/s/ Jennifer A. Docherty

Jennifer A. Docherty

Authorized Signatory

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SOUTHERN MISSOURI BANCORP, INC.

531 Vine Street

Poplar Bluff, Missouri 63901

November 15, 2011

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Southern Missouri Bancorp, Inc. (the “Company”)

Request for Acceleration of Effectiveness of

Registration Statement on Form S-1 (File No. 333-174113)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the above-referenced registration statement to November 16, 2011 at 3:00 p.m., Eastern Standard Time, or as soon thereafter as is practicable. We acknowledge that:

•

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, 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.

Sincerely,

SOUTHERN MISSOURI BANCORP, INC.

By:

/s/ Greg A. Steffens

Name:

Greg A. Steffens

Title:

President and Chief Executive Officer

CORRESP
1
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    smbc-corresp080311.htm

LAW OFFICES

Silver, Freedman & Taff, L.L.P.

A LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS

3299 K STREET, N.W., SUITE 100

WASHINGTON, D.C. 20007

PHONE: (202) 295-4500

FAX: (202) 337-5502

WWW.SFTLAW.COM

August 3, 2011

VIA EDGAR

Michael Clampitt, Senior Counsel

Division of Corporation Finance

Securities and Exchange Commission

Mail Stop 4720

100 F Street, N.E.

Washington, D.C.  20549

Re:   Southern Missouri Bancorp, Inc.

Registration Statement on Form S-1

File No. 333-174113

Dear Mr. Clampitt:

On behalf of our client, Southern Missouri Bancorp, Inc. (the “Registrant”), this letter responds to comments raised by the staff of the Securities and Exchange Commission (the “Staff”) in its letter to the Registrant dated July 8, 2011 (the “Comment Letter”) regarding the above-referenced registration statement. The Registrant’s responses to the Staff’s comments are numbered to correspond to the numbered comments in the Comment Letter and the Staff’s comments are repeated below for your convenience.

General

1.

Please add a recent development section to the summary and disclose at a minimum that management believes that there have been no material adverse changes in the results of operation or financial condition thru June 30, 2011.

RESPONSE: The Registrant is in the process of updating its financial information to June 30, 2011 and will incorporate its Form 10-K for the fiscal year ended June 30, 2011 into the Registration Statement prior to any request for effectiveness.  As a result, a recent development section is not believed to be necessary.

2.

We note the red herring language and that the number of shares to be offered has not been included yet. Please confirm that no preliminary distribution has been made.

RESPONSE:  We hereby confirm that, to date, no preliminary distribution of the prospectus has been made.

Impaired Loans (Collateral Dependent), page 7

3.

We note your response to comment 11 in your June 24, 2011 letter. Please revise future filings to describe in more detail how you measure impairment on collateral dependent loans in situations where the economic environment has worsened and/or the real estate market has declined since the last appraisal.

Michael Clampitt, Senior Counsel

August 3, 2011

Page 2 of 8

RESPONSE: Future filings will include disclosure similar in form to the following: In instances where the economic environment has worsened and/or the real estate market has declined since the last appraisal, a higher distressed sale discount would be applied to the appraised value.

Note 4: Loans, page 11

4.

We note your response to comments 14 and 15 in your June 24, 2011 letter. Please revise future filings to clearly disclose that purchased credit impaired loans are classified as impaired and on non-accrual status immediately after acquisition if they meet the appropriate standards.  Additionally, in all of your credit quality disclosures (including disclosures of impaired and non-accrual loans), please clearly disclose if purchased credit impaired loans are included and quantify the amount.

RESPONSE: Future filings will include disclosure similar in form to the following:

Included in the Company’s loan portfolio are certain loans accounted for in accordance with ASC 310-30, Loans and Debt Securities Acquired with Deteriorated Credit Quality.  These loans were written down at acquisition to an amount estimated to be collectible.  As a result, certain ratios regarding the Company’s loan portfolio and credit quality cannot be used to compare the Company to peer companies or to compare the Company’s current credit quality to prior periods.  The ratios particularly affected by accounting under ASC 310-30 include the allowance for loan losses as a percentage of loans, nonaccrual loans, and nonperforming assets, and nonaccrual loans and nonperforming loans as a percentage of total loans.

The following tables present the credit risk profile of the Company’s loan portfolio (excluding loans in process and deferred loan fees) based on rating category as of [interim date], and [prior fiscal year end date].  These tables include purchased credit impaired loans, which are reported according to risk categorization after acquisition based on the Company’s standards for such classification:

[interim date]

Conventional

Construction

Commercial

Real Estate

Real Estate

Real Estate

Consumer

Commercial

Pass

$

-

$

-

$

-

$

-

$

-

Special Mention

-

-

-

-

-

Substandard

-

-

-

-

-

Doubtful

-

-

-

-

-

      Total

$

-

$

-

$

-

$

-

$

-

Michael Clampitt, Senior Counsel

August 3, 2011

Page 3 of 8

[prior fiscal year end date]

Conventional

Construction

Commercial

Real Estate

Real Estate

Real Estate

Consumer

Commercial

Pass

$

-

$

-

$

-

$

-

$

-

Special Mention

-

-

-

-

-

Substandard

-

-

-

-

-

Doubtful

-

-

-

-

-

      Total

$

-

$

-

$

-

$

-

$

-

The above amounts include purchased credit impaired loans.  At [interim date], these loans comprised $[amount] of credits rated “Pass”; $[amount] of credits rated “Special Mention”; $[amount] of loans rated “Substandard”; and $[amount] of credits rated “Doubtful”.  At [prior fiscal year end date], these loans comprised $[amount] of credits rated “Pass”; $[amount] of credits rated “Special Mention”; $[amount] of loans rated “Substandard”; and $[amount] of credits rated “Doubtful”.

Credit Quality Indicators. The Company categorizes loans into risk categories based on relevant information about the ability of borrowers to service their debt such as: current financial information, historical payment experience, credit documentation, public information, and current economic trends among other factors.  The Company analyzes loans individually by classifying the loans as to credit risk.  This analysis is performed on all loans at origination.  In addition, lending relationships over $250,000 are subject to an independent loan review following origination, and lending relationships in excess of $1,000,000 are subject to an independent loan review annually, in order to verify risk ratings.

The Company uses the following definitions for risk ratings:

Special Mention – Loans classified as special mention warrant more than usual monitoring.  Issues may include deteriorating financial condition, payments made after the due date but within 30 days, adverse industry conditions, management problems, or other signs of deterioration that indicate a potential weakening of the institution’s credit position in the future.

Substandard – Loans classified as substandard possess weaknesses that jeopardize the ultimate collection of the principal and interest outstanding.  These loans exhibit continued financial losses, ongoing delinquency, overall poor financial condition, and insufficient collateral.  They are characterized by the distinct possibility that the institution will sustain some loss if the deficiencies are not corrected.

Doubtful – Loans classified as doubtful have all the weaknesses of substandard loans, and have deteriorated to the level that there is a high probability of substantial loss.

Michael Clampitt, Senior Counsel

August 3, 2011

Page 4 of 8

Loans not meeting the criteria above that are analyzed individually as part of the above described process are considered to be Pass rated loans.

The following tables present the credit risk profile of the Company’s loan portfolio (excluding loans in process and deferred loan fees) based on the Company’s loan portfolio aging analysis as of [interim date], and [prior fiscal year end date].  These tables include purchased credit impaired loans, which are reported according to aging analysis after acquisition based on the Company’s standards for such classification:

[interim date]

Total Loans > 90

30-59 Days Past Due

60-89 Days Past Due

Greater Than 90 Days

Total Past Due

Current

Total Loans Receivable

Days & Accruing

Real Estate Loans:

      Conventional

$

-

$

-

$

-

$

-

$

-

$

-

$

-

      Construction

-

-

-

-

-

-

-

      Commercial

-

-

-

-

-

-

-

Consumer loans

-

-

-

-

-

-

-

Commercial loans

-

-

-

-

-

-

-

      Total loans

$

-

$

-

$

-

$

-

$

-

$

-

$

-

[prior fiscal year end date]

30-59 Days

60-89 Days

Greater Than

Total

Total Loans

Total Loans > 90

Past Due

Past Due

90 Days

Past Due

Current

Receivable

Days & Accruing

Real Estate Loans:

      Conventional

$

-

$

-

$

-

$

-

$

-

$

-

$

-

      Construction

-

-

-

-

-

-

-

      Commercial

-

-

-

-

-

-

-

Consumer loans

-

-

-

-

-

-

-

Commercial loans

-

-

-

-

-

-

-

      Total loans

$

-

$

-

$

-

$

-

$

-

$

-

$

-

The above amounts include purchased credit impaired loans.  At [interim date], these loans comprised $[amount] of credits 30-59 Days Past Due; $[amount] of credits 60-89 Days Past Due; $[amount] of credits Greater Than 90 Days Past Due; $[amount] of Total Past Due credits; $[amount] of credits Current; and $[amount] of Total Loans > 90 Days & Accruing.  At [prior fiscal year end date], these loans comprised $[amount] of credits 30-59 Days Past Due; $[amount] of credits 60-89 Days Past Due; $[amount] of credits Greater Than 90 Days Past Due; $[amount] of Total Past Due credits; $[amount] of credits Current; and $[amount] of Total Loans > 90 Days & Accruing.

Michael Clampitt, Senior Counsel

August 3, 2011

Page 5 of 8

A loan is considered impaired, in accordance with the impairment accounting guidance (ASC 310-10-35-16), when based on current information and events, it is probable the Company will be unable to collect all amounts due from the borrower in accordance with the contractual terms of the loan.  Impaired loans include nonperforming loans but also include loans modified in troubled debt restructurings where concessions have been granted to borrowers experiencing financial difficulties.  These concessions could include a reduction in the interest rate on the loan, payment extensions, forgiveness of principal, forbearance or other actions intended to maximize collection.

The following tables present impaired loans (excluding loans in process and deferred loan fees) as of [interim date], and [prior fiscal year end date].  These tables include purchased credit impaired loans:

[interim date]

Recorded

Unpaid Principal

Specific

Balance

Balance

Allowance

Loans without a specific valuation allowance:

      Conventional real estate

$

-

$

-

$

-

      Construction real estate

-

-

-

      Commercial real estate

-

-

-

      Consumer loans

-

-

-

      Commercial loans

-

-

-

Loans with a specific valuation allowance:

      Conventional real estate

$

-

$

-

$

-

      Construction real estate

-

-

-

      Commercial real estate

-

-

-

      Consumer loans

-

-

-

      Commercial loans

-

-

-

Total:

      Conventional real estate

$

-

$

-

$

-

      Construction real estate

$

-

$

-

$

-

      Commercial real estate

$

-

$

-

$

-

      Consumer loans

$

-

$

-

$

-

      Commercial loans

$

-

$

-

$

-

Michael Clampitt, Senior Counsel

August 3, 2011

Page 6 of 8

[prior fiscal year end date]

Recorded

Unpaid Principal

Specific

Balance

Balance

Allowance

Loans without a specific valuation allowance:

      Conventional real estate

$

-

$

-

$

-

      Construction real estate

-

-

-

      Commercial real estate

-

-

-

      Consumer loans

-

-

-

      Commercial loans

-

-

-

Loans with a specific valuation allowance:

      Conventional real estate

$

-

$

-

$

-

      Construction real estate

-

-

-

      Commercial real estate

-

-

-

      Consumer loans

-

-

-

      Commercial loans

-

-

-

Total:

      Conventional real estate

$

-

$

-

$

-

      Construction real estate

$

-

$

-

$

-

      Commercial real estate

$

-

$

-

$

-

      Consumer loans

$

-

$

-

$

-

      Commercial loans

$

-

$

-

$

-

The above amounts include purchased credit impaired loans.  At [interim date], these loans comprised $[amount] of impaired loans without a specific valuation allowance; $[amount] of impaired loans with a specific valuation allowance, and $[amount] of total impaired loans.  At [prior fiscal year end date], these loans comprised $[amount] of impaired loans without a specific valuation allowance; $[amount] of impaired loans with a specific valuation allowance, and $[amount] of total impaired loans.

The following table presents the Company’s nonaccrual loans at [interim date], and [prior fiscal year end date].  This table includes purchased credit impaired loans (if these loans were placed on nonaccrual status according to the Company’s policy) and excludes performing troubled debt restructurings:

[interim date]

[prior fiscal year end date]

Conventional real estate

$

-

$

-

Construction real estate

-

-

Commercial real estate

-

-

Consumer loans

-

-

Commercial loans

-

-

      Total loans

$

-

$

-

Michael Clampitt, Senior Counsel

August 3, 2011

Page 7 of 8

The above amounts include purchased credit impaired loans.  At [interim date], these loans comprised $[amount] of nonaccrual loans; at [prior fiscal year end date], these loans comprised $[amount] of nonaccrual loans.

5.

Also, please discuss the comparability of your credit metrics and trends between periods and with your peers considering that you have reduced the carrying value of these loans to fair value during purchase accounting and therefore these loans which may be classified and reported as non-accrual or impaired may not have any loss content.

RESPONSE: Please see paragraph 1 of our response to comment #4, above, for proposed discussion related to this item.

6.

We note your response to comment 27 in your June 24, 2011 letter. Please note that ASC 310-10-50-15(c)(1), (2) and (3) requires information about impaired loans, not nonaccrual loans. Please revise future filings accordingly.

RESPONSE: Future filings will include disclosure similar in form to the following:

[interim date]

Average Investment In Impaired Loans

Interest Income Recognized

Interest Income Recognized on a Cash Basis

  Conventional real estate

$

-

$

-

$

-

Construction real estate

-

-

-

Commercial real estate

-

-

-

Consumer loans

-

-

-

Commercial loans

-

-

-

[prior fiscal year end date]

Average Investment In Impaired Loans

Interest Income Recognized

Interest Income Recognized on a Cash Basis

  Conventional real estate

$

-

$

-

$

-

Construction real estate

-

-

-

Commercial real estate

-

-

-

Consumer loans

-

-

-

Commercial loans

-

-

-

7.

We note your response to comment 28 in your June 24, 2011 letter. Please note that ASC 310-10-50-19 relates to all impaired loans, not just acquired impaired loans. Please revise future filings accordingly.

RESPONSE: Future filings will include disclosure similar in form to the following:

Michael Clampitt, Senior Counsel

August 3, 2011

Page 8 of 8

The amount of interest income recorded for impaired loans that represents a change in the present value of future cash flows attributable to the passage of time was approximately $[amount] and $[amount], respectively, for the three- and [ ]-month periods ended [date], as compared to $[amount] and $[amount], respectively, for the three- and [ ]-month periods ended [date].

Closing Comments

In connection with responding to the Comment Letter, the Registrant acknowledges that:

·

it is responsible for the adequacy and accuracy of the disclosure in the filing;

·

staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

·

the Registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or any p

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

July 8, 2011

Via E-mail
Greg A. Steffens President and Chief Executive Officer Southern Missouri Bancorp, Inc. 531 Vine Street Poplar Bluff, Missouri  63901
 Re: Southern Missouri Bancorp, Inc.
Registration Statement on Form S-1/A
  Filed June 27, 2011   File No. 333-174113

 Dear Mr. Steffens:
We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.
 Please respond to this letter within te n business days by amending your registration
statement and providing the requested inform ation, including a draft of your proposed
disclosures to be made in future filings clearly identifying new and deleted disclosure
, or by
advising us when you will provide the requested response.   If you do not believe our comments
apply to your facts and circumstances or do not be lieve an amendment is appropriate, please tell
us why in your response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.     General

1. Please add a recent development section to th e summary and disclose at a minimum that
management believes that there have been no material adverse changes in the results of
operation or financial co ndition thru June 30, 2011.

2. We note the red herring language  and that the number of shares to be offered has not
been included yet. Please confirm that no preliminary distribution has been made.

Mr. Greg A. Steffens
Southern Missouri Bancorp, Inc.
July 8, 2011 Page 2

March 31, 2011 Form 10-Q
 Impaired Loans (Collateral Dependent), page 7

3. We note your response to comment 11 in your June 24, 2011 letter.  Please revise future
filings to describe in more detail how you measure impairment on collateral dependent
loans in situations where the economic envir onment has worsened and/ or the real estate
market has declined since the last appraisal.
 Note 4: Loans, page 11

4. We note your response to comments 14 and 15 in  your June 24, 2011 lett er.  Please revise
future filings to clearly disclose that purchas ed credit impaired loans are classified as
impaired and on non-accrual status immediat ely after acquisition if they meet the
appropriate standards.  Additionally, in all of your credit quality disclosures (including
disclosures of impaired and non- accrual loans), please clearly disclose if purchased credit
impaired loans are included and quantify the amount.

5. Also, please discuss the comparability of your credit metrics and trends between periods
and with your peers considering that you have  reduced the carrying value of these loans
to fair value during purchase accounting a nd therefore these loans which may be
classified and reported as non-accrual or im paired may not have any loss content.

6. We note your response to comment 27 in your June 24, 2011 letter.  Please note that ASC
310-10-50-15(c)(1), (2) and (3 ) requires information about impaired loans, not non-
accrual loans.  Please revise futu re filings accordingly.

7. We note your response to comment 28 in your June 24, 2011 letter.  Please note that ASC
310-10-50-19 relates to all impaired loans, not just acquired impaired loans.  Please
revise future fili ngs accordingly.

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing reviewed by the staff to be certain that they have provided all information investors
require for an informed decision.  Since the comp any and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.     In connection with responding to our comme nts, please provide, in writing, a statement
from the company and each filing person acknowledging that:

Mr. Greg A. Steffens
Southern Missouri Bancorp, Inc.
July 8, 2011 Page 3

  the company or filing person is responsible  for the adequacy and accuracy of the
disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company or filing person may not assert  staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
 You may contact Michael Vo lley at 202-551-3437 or Amit Pande at 202-551-3423 if you
have questions regarding comments on the financ ial statements and related matters.  You may
contact Jessica Livingston at 202-551-3448 or me at 202-551-3434 with any questions.

Sincerely,
               /s/ Michael R. Clampitt         M i c h a e l  C l a m p i t t          Senior Counsel