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                              April 8, 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
                                                            File No. 000-14384

       Dear Mr. Harlow:

              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-K for the fiscal year ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Critical Accounting Policies and Estimates
       Allowance for Credit Losses, page 29

   1.                                                   You disclose that your
allowance is estimated for loans using a historical loss percentage
                                                        based on losses arising
specifically for each respective loan category, adjusted for various
                                                        economic and
environmental factors that are considered reasonable and supportable
                                                        related to the
underlying loans. Please provide us proposed revised disclosure to be
                                                        included in future
filings that:
                                                            Identifies the key
quantitative inputs used in your estimate of the allowance for credit
                                                             losses;
                                                            Indicates and
quantifies how these key quantitative inputs changed from period to
                                                             period; and
                                                            Quantifies the
qualitative component of your estimate and how it interacts with the
 David Harlow
FirstName   LastNameDavid Harlow
Bancfirst Corporation
Comapany
April       NameBancfirst Corporation
       8, 2022
April 28, 2022 Page 2
Page
FirstName LastName
              quantitative component during the period; and
                Summarizes on page 74 the information requested above and
clarify the length of
              time in your reasonable and supportable forecasts and the
reversion method you
              applied after the reasonable and supportable forecast period. See
Item 303(b)(3) of
              Regulation S-K and ASC 326-20-50-11.

Results of Operations
Average Balances, Income Expenses and Rates, page 32

2.       Please tell us the amounts of fees included in interest income for
each period
         presented. Tell us your consideration for disclosing these amounts as
required by
         Instruction 3 to Item 1402 of Regulation S-K.
Maturity and Rate Sensitivity of Loans, page 41

3.       Please represent to us that, in future filings, you will disaggregate
your disclosure of your
         loans due after one year that have predetermined interest rates and
those with adjustable
         rates for each loan category presented in your table as required by
Item 1404(b) of
         Regulation S-K.
Notes to Consolidated Financial Statements
Note 1: Description of Business and Summary of Significant Accounting Policies
Loans, page 56

4.       In the third paragraph of this policy you disclose your election to
exclude accrued interest
         receivable on loans from your estimate of credit losses. Please
represent to us that in
         future filings you will specifically indicate that you made this
election because you write
         off uncollectible accrued interest in a timely manner and what time
periods you consider
         timely at the individual class of loan level as required by ASC
326-20-50-3C. In your
         response tell us those time periods or tell us where you have made the
required disclosure
         in your filing or why it is not warranted.
5.       In the penultimate paragraph on page 56 you indicate that you reverse
interest accrued
         but not received on nonaccrual loans against interest income. Please
represent to us that in
         future filings you will disclose the amount of such reversals in each
period presented as
         required by ASC 326-20-50-3D or tell us where you made this disclosure
or why it is not
         warranted.
Allowance for Credit Losses on Off-Balance Sheet Credit Exposures, page 58

6.       Please tell us in detail why your adoption of ASC 326 and continuing
application of that
         guidance results in an accrual for credit losses on off-balance sheet
credit exposure that is
         not material when you have over $2.1 billion in loan commitments and
stand-by letters of
         credit outstanding at December 31, 2021 as disclosed on page 91. In
your response tell us
         the historic rates of these off-balance sheet exposures converting to
actual loans and
 David Harlow
FirstName   LastNameDavid Harlow
Bancfirst Corporation
Comapany
April       NameBancfirst Corporation
       8, 2022
April 38, 2022 Page 3
Page
FirstName LastName
         funding and how you can "manage the extension of credit" and
apparently avoid material
         future credit losses. Reference for us the specific authoritative
literature you relied upon to
         support your accounting.
Allowance for Credit Losses on Available-for-Sale Debt Securities, page 59

7.       You disclose that you consider the period of time a security has been
in an unrealized loss
         position in assessing credit losses or other factors. As the length of
time a security is in an
         unrealized loss position is not a factor in assessing whether credit
losses exist as stipulated
         in ASC 326-30-55-1, please tell us whether a change to your allowance
for credit losses
         on debt securities results from removing the length of time from your
         assessment. Separately represent to us that you will modify your
policy disclosure in
         future filings to remove the length of time a security is in an
unrealized loss position from
         the factors considered in your credit loss assessment.
Note 5: Loans Held for Investment and Allowance for Credit Losses on Loans
Nonaccrual loans, page 68

8.       Please tell us the amount of interest income recognized on nonaccrual
loans in 2021 and
         2020 as well as the amortized cost basis of nonaccrual loans for which
there is no related
         allowance for credit losses at the end of 2021 and 2020. Represent to
us that you will
         disclose this information in future filings as required by ASC
326-20-50-16 or tell us why
         this disclosure is not warranted.
Allowance for Credit Losses Methodology, page 74

9.       Please tell us why your adoption of ASC 326 on January 1, 2020
resulted in a $3.2 million
         reduction of your allowance when the inclusion of expected future
credit losses generally
         is expected to result in an allowance increase over the incurred
methodology. Tell us your
         consideration for disclosing the cause of the decline and reference
for us the specific
         authoritative guidance that supports your accounting.
Purchased Credit Deteriorated Loans, page 76

10.      Please tell us why you have no reconciling item for discounts or
premiums attributable to
         factors other than credit losses between the purchase price and par
value of purchased
         credit deteriorated loans for either period presented. In your
response, tell us the market
         interest rates for similar loans and the stated interest rates on
these loans at the dates of
         acquisition. In addition, tell us the interest income accrued on these
loans in each period
         after acquisition and how the inherent rates of return compare to the
market rates for these
         loans upon acquisition.
Collateral Dependent Loans, page 77

11.      Please tell us why the fair value of collateral dependent loans as
disclosed on page 95 is
         different than the carrying value of these loans as depicted here.
 David Harlow
Bancfirst Corporation
April 8, 2022
Page 4

       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 Mark Brunhofer at 202-551-3638 or Sharon Blume at
202-551-
3474 with any questions.



FirstName LastNameDavid Harlow                            Sincerely,
Comapany NameBancfirst Corporation
                                                          Division of
Corporation Finance
April 8, 2022 Page 4                                      Office of Finance
FirstName LastName