March 21, 2019

Jeffrey P. Julien
Chief Financial Officer
Raymond James Financial Inc.
880 Carillon Parkway
St. Petersburg, FL

       Re: Raymond James Financial, Inc.
           Form 10-Q for the Quarterly Period Ended December 31, 2018
           Filed February 8, 2019
           File No. 001-09109

Dear Mr. Julien:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

Form 10-Q for the Quarterly Period Ended December 31, 2018

Management's Discussion and Analysis
Results of Operations - Private Client Group
Selected Key Metrics, page 53

1.    We note your disclosure on page 54 as it relates to changes in your asset
management and
      related administrative fees. We also note the various factors that can
impact those fees,
      such as market movements and shifts to fee-based accounts, advisor
recruiting and
      retention, etc. Please revise your future filings to address the items
below.
        Include a rollforward of your fee-based accounts (i.e., similar to the
rollforward
          activity presented on page 57).
        Provide a table presenting your fee-based accounts by objective (i.e.,
similar to the
          tabular presentation on page 57).
        In addition to the bullet point above, provide fee rate information
(e.g., weighted
          average fee rate) by objective, including, as needed, a narrative
discussing fee rate
 Jeffrey P. Julien
Raymond James Financial Inc.
March 21, 2019
Page 2
             trends and related drivers.
Results of Operations - Asset Management
Financial Assets Under Management, page 57

2.       We note your tabular presentation of fee-billable financial assets
under management by
         objective. Please revise your table in future filings to also include
fee rate information
         (e.g., weighted average fee rate) by objective, including, as needed,
a narrative discussing
         fee rate trends and related drivers.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Cara Lubit at 202-551-5909 or Hugh West at 202-551-3872
with any
questions.



FirstName LastNameJeffrey P. Julien                            Sincerely,
Comapany NameRaymond James Financial Inc.
                                                               Division of
Corporation Finance
March 21, 2019 Page 2                                          Office of
Financial Services
FirstName LastName