United States securities and exchange commission logo





                             June 10, 2022

       David Harlow
       President and Chief Executive Officer
       BancFirst Corporation
       100 N. Broadway Ave.
       Oklahoma City, Oklahoma 73102

                                                        Re: BancFirst
Corporation
                                                            Form 10-K for the
fiscal year ended December 31, 2021
                                                            Filed February 25,
2022
                                                            Form 10-Q for the
quarterly period ended March 31, 2022
                                                            Filed May 6, 2022
                                                            File No. 000-14384

       Dear Mr. Harlow:

               We have reviewed your May 9, 2022 response to our comment letter
and the above
       referenced filings and have the following comment. In our comment, we
ask you to provide us
       with information so we may better understand your disclosure.

              Please respond to this comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 10-Q for the quarterly period ended March 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Summary, page 30

   1.                                                   In the second paragraph
on page 30 you indicate that total assets at March 31, 2022 were
                                                        $12.6 billion, an
increase of $3.2 billion from December 31, 2021. You attribute this
                                                        increase and the $3.2
billion increase in deposits primarily to the return of off-balance
                                                        sheet sweep accounts
related to your year-end sweep program. In the second paragraph
                                                        on page 29 of your 2021
Form 10-K, you indicate that $2.3 billion of the total off-balance
                                                        sheet sweep accounts of
$5.1 billion at December 31, 2021 were temporary. Please
                                                        address the following
regarding your off-balance sheet sweep accounts, referencing where
                                                        appropriate the
authoritative literature you rely upon to support your accounting:
                                                            Provide additional
details regarding your year-end sweep account program. Describe
 David Harlow
BancFirst Corporation
June 10, 2022
Page 2
              the history of the program, its purpose, the nature of the
customer deposit accounts
              involved, to whom the sweep accounts are transferred and how you
determine the
              related dollar amounts to transfer.
                Provide us an analysis under GAAP supporting your determination
to derecognize the
              deposit liability and associated assets from your balance sheet.
As part of your
              analysis, describe any material rights and responsibilities you
and the transferees
              have with regard to the transferred accounts.
                Specifically explain what you mean by "temporary sweep amount"
at December 31,
              2021. Tell us whether you were obligated to reacquire or the
transferee was obligated
              to return the temporary sweep amounts. If so, tell us how you
analyzed these
              obligations under GAAP when determining it was appropriate to
derecognize the
              deposit liability and related assets from your balance sheet.
                As the $3.2 billion increase in total assets and total deposits
from December 31, 2021
              to March 31, 2022 was attributed primarily to the return of
off-balance sheet sweep
              accounts, tell us whether any of the sweep accounts not
characterized as the $2.3
              billion in temporary sweep amounts were also returned/reassumed
by you.

        You may contact Mark Brunhofer at (202) 551-3638 or Sharon Blume at
(202) 551-
3474 if you have any questions.



FirstName LastNameDavid Harlow                                Sincerely,
Comapany NameBancFirst Corporation
                                                              Division of
Corporation Finance
June 10, 2022 Page 2                                          Office of Finance
FirstName LastName