United States securities and exchange commission logo

                          July 13, 2020

       Stephen Lasota
       Chief Financial Officer
       COWEN INC.
       599 Lexington Avenue
       New York, New York 10022

                                                        Re: COWEN INC.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed March 4, 2020
                                                            Form 8-K Filed
April 29, 2020
                                                            File No. 001-34516

       Dear Mr. Lasota:

              We have reviewed your filings 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

              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 8-K filed April 29, 2020

       Exhibit 99.1
       Appendix: Non-GAAP Financial Measures, page 9

   1.                                                   Please tell us in more
detail how you use Economic Income (Loss), Economic Operating
                                                        Income (Loss), Economic
Income (Loss) Revenues and the related per share amounts to
                                                        measure your
consolidated operating performance. Include a discussion of the reasons
                                                        why you believe each of
these measures are useful to investors.

       Unaudited Reconcilation of US GAAP and Economic Revenue for the Three
Months Ended
       March 31, 2020, page 11

   2.                                                   It appears that many of
the adjustments you make to GAAP revenue when calculating
                                                        Economic Income revenue
are to reclassify amounts from other income statement line
 Stephen Lasota
FirstName  LastNameStephen Lasota
July       NameCOWEN INC.
     13, 2020
July 13,
Page  2 2020 Page 2
FirstName LastName
         items to revenue. For example, income (loss) from proprietary trading
has been
         reclassified from other income to revenue. Additionally, gross
interest expense for net
         securities borrowed and securities loaned activities has been
reclassified to revenue.
         Please explain to us why you believe it is appropriate to characterize
these amounts and
         any similar    other adjustments    as revenue for non-GAAP purposes
when they not
         recognized as revenue under GAAP.
3.       We note the adjustments to a) recognize incentive fees during periods
when the fees are
         not yet crystalized b) recognize startup costs of a fund over the
expected life of a fund and
         c) recognize retainer fees related to investment banking activities
earned during the period
         that would otherwise be deferred until closing. Please tell us how you
considered the
         guidance in the Division   s Non-GAAP C&DI 100.04 when determining the
         appropriateness of your presentation. Specifically, explain to us how
you considered
         whether your non-GAAP measure includes individually tailored revenue
recognition and
         measurement methods that could violate Rule 100(b) of Regulation G.
Form 10-K for the Fiscal Year Ended December 31, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations, page 35

4.       We note you had material    net gains (losses) on securities,
derivatives and other
         investments    and    net realized and unrealized gains (losses) on
investments and other
         transactions    in the periods presented. Please revise future filings
to disclose the
         underlying causes for material changes in these line items from
period-to-period. For
         example, consider expanding your disclosure to include the specific
investment strategies,
         industries or issuers to which the net gains (losses) on securities,
derivatives and other
         investments relate. Similarly, for your Consolidated Funds, consider
disclosure identifying
         any specific funds performance contributing to net realized and
unrealized gains (losses)
         on investments and other transactions. Show us what your disclosure
will look like in your
         response. Refer to SEC Release 33-8350.
 Stephen Lasota
July 13, 2020
Page 3

        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 Dave Irving at 202-551-3321 or Sharon Blume at
202-551-3474 with
any questions.

FirstName LastNameStephen Lasota                          Sincerely,
Comapany NameCOWEN INC.
                                                          Division of
Corporation Finance
July 13, 2020 Page 3                                      Office of Finance
FirstName LastName