Mail Stop 4561
February 23, 2006
By U.S. Mail and facsimile to (727) 567-8365.
Jennifer C. Ackart
Controller and Chief Accounting Officer
Raymond James Financial, Inc.
880 Carillon Parkway
St. Petersburg, FL 33716
Re: Raymond James Financial, Inc.
Form 10-K for Fiscal Year Ended September 30, 2005
Filed December 14, 2005
File No. 001-09109
Dear Ms. Ackart:
We have reviewed your filing and have the following
comments.
We have limited our review to only the issue raised in our
comments.
Where indicated, we think you should revise your document in
response
to these comments in future filings. If you disagree, we will
consider your explanation as to why our comment is inapplicable or
a
revision is unnecessary. Please be as detailed as necessary in
your
explanation. In our comment, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies, page 46
Derivative Financial Instruments, page 50
1. We note your disclosure on page 50 that you net-by-counterparty
the fair value of your interest rate swaps for which you have a
legally enforceable master netting agreement. It appears that
similar disclosure was not provided in your September 30, 2004
Form
10-K. Please tell us whether this represents an accounting policy
change to your method of recording your interest rate swaps. If
your
policy has changed, please tell us when this change was made and
whether all periods are presented on the same basis. If
applicable,
please tell us whether you received a preferability letter from
your
independent accountants regarding this change.
Note 11 - Derivative Financial Instruments, page 59
2. Please tell us the following related to your derivative
financial
instruments:
* Identify each type of asset or liability for which you employ
hedging strategies.
* Clearly describe the terms of both the hedging instrument and
the
hedged item.
* Describe the specific documented risk being hedged.
* Disclose the hedging classification for each derivative
instrument.
* Tell us how you determined that these hedging relationships met
all
of the criteria of paragraphs 20-21 or 28-29 of SFAS 133 to
qualify
as fair value or cash flow hedges.
* Identify whether you use the long-haul method, the short-cut
method, or matched terms to assess the effectiveness of each
hedging
strategy.
* Describe how you assess hedge effectiveness and measure hedge
ineffectiveness.
* * * * *
Please respond to these comments within 10 business days or
tell us when you will provide us with a response. Please furnish
a
cover letter that keys your response to our comments, indicates
your
intent to include the requested revisions in future filings and
provides any requested supplemental information. Please
understand
that we may have additional comments after reviewing your
responses
to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Rebekah Moore, Staff Accountant, at (202)
551-
3463 or me at (202) 551-3851 if you have questions.
Sincerely,
Paul Cline
Senior Accountant
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Jennifer C. Ackart
Raymond James Financial, Inc.
February 23, 2006
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