August 29, 2025

James Marischen
Chief Financial Officer
Stifel Financial Corp.
501 North Broadway
St. Louis, MO 63102

        Re: Stifel Financial Corp.
            Form 10-K for Fiscal Year Ended December 31, 2024
            Form 8-K, filed July 30, 2025
            File No. 001-09305
Dear James Marischen:

       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 for Fiscal Year Ended December 31, 2024
IV. Deposits, page 48

1.     Please revise your future filings to disclose the information required
by Item 1406(e)
       and (f) of Regulation S-K, to the extent material.
Note 25 - Income Taxes, page 120

2.     We note your disclosure of $57 million in NOL   s and your recognition
of a deferred
       tax asset valuation allowance of $57 million at December 31, 2024. We
also note your
       disclosure about your    ability to carry back certain tax attributes
against prior year
       taxable income for tax years before 2024 and to carry forward net
operating losses
       indefinitely after 2024, and expectations of future taxable income,
which is supported
       by a history of cumulative income.    Please tell us in detail and
revise your future
       filings, here or in the MD&A, to provide additional information
regarding the specific
       component(s) to which the material amount of deferred tax asset
valuation allowance
       relates and clarify the negative evidence considered under ASC 740-10-30
which
 August 29, 2025
Page 2

       resulted in the recognition of a deferred tax asset valuation allowance.
Further,
       disclose the portion of NOL   s that do not require a valuation
allowance, if material.
Form 8-K, filed July 30, 2025
Exhibit 99.2, page 4

3.     We note disclosure on page 4 of your    Non-GAAP Consolidated Results of
       Operations    which represents a full income statement of non-GAAP
measures. Please
       revise your future filings to remove the presentation of your full
non-GAAP income
       statement. Refer to Question 102.10(a) of the Non-GAAP Compliance and
Disclosure
       Interpretations for guidance.
4.     While you label certain groups of information as non-GAAP, we note your
non-
       GAAP financial measures have the same line-item names as the related
GAAP
       financial measure (e.g., net revenues, earnings per diluted common
share, etc.). Please
       revise the description of each non-GAAP financial measure in future
filings to use a
       different line-item name, for example, adjusted net revenues, adjusted
earnings per
       diluted common share, etc. Refer to Question 100.05 of the Non-GAAP
Compliance
       and Disclosure Interpretations for guidance.
        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 John Spitz at 202-551-3484 or Michael Volley at
202-551-3437 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance