Document

This letter sets forth the response of Stellar Bancorp, Inc. (the “Company”), a Texas corporation, to the comment letter, dated December 19, 2024 (the “Comment Letter”), from the staff (the “Staff”) of the Division of Corporate Finance of the Securities and Exchange Commission (the “Commission”). As the Staff is aware, the Comment Letter was not received by the Company until January 15, 2025 as a result of an incorrect email address. For convenience of the Staff, the Company has restated in this letter the Comment set forth in the Comment Letter in italics.

1.We note that commercial real estate loans (including multi-family residential) totaled $4.1 billion, or 51.3%, of the total loan portfolio at December 31, 2023. In addition, we note from your disclosure on page 9 of Exhibit 99.2 of your Third Quarter 2024 Earnings Presentation that your CRE portfolio is broadly diversified by property type including loans secured by retail, warehouse, convenience store, multifamily, etc. Please revise your disclosures, in future filings, to provide disaggregation and quantification of the composition of your CRE loan portfolio by property type and other characteristics (e.g., current weighted average and/or range of loan-to-value ratios, occupancy rates, etc.). For example, your disclosure should include details similar to those provided on slide 9 as well as other details relevant to the understanding of this significant portion of your loan portfolio.

The Company acknowledges the Staff’s comment. In its future filings with the Commission, the Company will provide further disclosure to disaggregate the composition of its commercial real estate loan portfolio. Disclosures will incorporate additional available information related to characteristics we believe are material to investor understanding of the components and risks inherent in our commercial real estate portfolio. These updates will begin with the Company’s Annual Report on Form 10-K for the fiscal year ending December 31, 2024.