Room 4561

	July 1, 2005

Mr. Randall D. Young, Esq.
DST Systems, Inc.
333 West 11th Street
Kansas City, Missouri 64105

Re:	DST Systems, Inc.
	Post-effective Amendment No. 11 to Form S-3 filed June 24,
2005
	File No. 333-109130

Dear Mr. Young:

      This is to advise you that we have limited our review of the
above registration statement to the matters addressed in the
comments
below.  No further review of the registration statement has been
or
will be made.  All persons who are by statute responsible for the
adequacy and accuracy of the registration statement are urged to
be
certain that all information required under the Securities Act has
been included.

      Where indicated, we think you should revise your document in
response to these comments.  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 some of our comments, 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.

Where You Can Find More Information

1. We note that subsequent to your filing of this post-effective
amendment you filed a Form 8-K on June 29, 2005.  Please revise to
incorporate by reference this filing.

Selling Security Holders

2. We note that you have included J.P. Morgan Securities as a
selling
securityholder in your registration statement.  Please confirm
that
any selling securityholder that is a registered broker-dealer has
been disclosed as such.  If a selling securityholder is a
registered
broker-dealer, please identify such registered broker-dealer as an
underwriter in your disclosure, unless the shares were acquired as
transaction-based compensation for investment-banking services.
Provide a description of the investment-banking services and the
manner in which the compensation for the services was computed, as
applicable.

3. Please confirm that any selling securityholder that is an
affiliate of a registered broker-dealer has been disclosed as
such.
If a selling securityholder is an affiliate of a registered
broker-
dealer, please expand the prospectus disclosure to indicate
whether
such selling securityholder acquired the securities to be resold
in
the ordinary course of business.  Also indicate whether at the
time
of the acquisition such selling securityholder had any agreements,
understandings or arrangements with any other persons, either
directly or indirectly, to dispose of the securities.


*              *              *              *

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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 related to your disclosure, they are
responsible for the accuracy and adequacy of the disclosures they
have made.

      Prior to our declaration of the effective date of the
pending
post-effective amendment pursuant to Section 8(c) of the
Securities
Act, the company should furnish a letter acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert the staff comments and the
declaration
of effectiveness 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 connection with our review of
your
filing or in response to our comments on your filing.

      You may contact Daniel Lee at (202) 551-3477 with any
questions.  If you need further assistance, you may contact me at
(202) 551-3462.

	Sincerely,


	Mark P. Shuman
	Branch Chief - Legal

cc:	Via Facsimile
	John F. Marvin
	Diane M. Bono
	Sonnenschein Nath & Rosenthal LLP
	4520 Main Street, Suite 1100
	Kansas City, Missouri 64111
	Telephone: (816) 460-2400
	Facsimile:  (816) 531-7545