June 27, 2019

Ronald J. Kruszewski
Chief Executive Officer
Stifel Financial Corp.
501 North Broadway
St. Louis, Missouri 63102-2188

       Re: Stifel Financial Corp.
           Form 10-K for the fiscal year ended December 31, 2018
           Filed February 20, 2019
           File No. 001-09305

Dear Mr. Kruszewski:

       We have reviewed your June 13, 2019 response to our comment letter 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
May 8, 2019 letter.



Form 10-K for the fiscal year ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations - Global Wealth Management, page 39

1.    We note your response to our comment and that you do not utilize
comprehensive
      rollforward information for fee-based assets to manage your business as
substantially all
      of the asset management fees you earn are calculated based on
point-in-time balances as
      of the end of the previous quarter and that in addition, the current
infrastructure, which
      supports the administration of your assets in fee-based accounts, is not
a centralized
      platform and does not provide this information. We also note your risk
factor on page 17,
      that fee revenue is impacted by AUM balances, including net
inflows/outflows of client
 Ronald J. Kruszewski
Stifel Financial Corp.
June 27, 2019
Page 2
         assets and market values and that below-market investment performance
by your funds
         and portfolio managers could result in a loss of managed accounts.
Please address the
         following:

             Disclose, in future filings, how you manage the risk(s) of your
decentralized
             investment advisory platform, considering also the potential
impact to fee revenues or
             add a risk factor to address how your decentralized platform
impacts your ability to
             track total client asset activity and the related financial
statement risks; and
             Disclose, in future filings, in your Global Wealth Management
segment discussion, the
             number of underlying accounts for both total client assets managed
(AUM) and fee-
             based assets, consistent with the disclosure in your investor
presentations to support
             asset management and service fees recognized for the periods
presented. Refer to Item
             303 of Regulation S-K.

       You may contact Michelle Miller at 202-551-3368 or John Nolan at
202-551-3492 if you
have questions.



FirstName LastNameRonald J. Kruszewski                        Sincerely,
Comapany NameStifel Financial Corp.
                                                              Division of
Corporation Finance
June 27, 2019 Page 2                                          Office of
Financial Services
FirstName LastName