United States securities and exchange commission logo June 21, 2024 J. Mariner Kemper Chief Executive Officer UMB Financial Corporation 1010 Grand Boulevard Kansas City, MO 64106 Re: UMB Financial Corporation Registration Statement on Form S-4 Filed June 13, 2024 File No. 333-280190 Dear J. Mariner Kemper: 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 Madeleine Joy Mateo at 202-551-3465 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: Lee Hochbaum, Esq.