[LETTERHEAD OF KEEFE, BRUYETTE & WOODS, INC.]
August 8, 2012
Via Facsimile and Edgar
(202) 772-9216
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Madison County Financial, Inc. |
Registration Statement on Form S-1 (Registration Number 333-181070)
Request for Acceleration of Effectiveness
Ladies and Gentlemen:
In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, we hereby join Madison County Financial, Inc. in requesting that the effective date of the above-referenced Registration Statement be accelerated so that it will become effective at 12:00 p.m. on August 10, 2012, or as soon thereafter as may be practicable.
| Very Truly Yours, |
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| Keefe, Bruyette & Woods, Inc. |
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| /s/ Allan D. Jean |
| Name: Allan D. Jean |
| Title: Vice President |