United States securities and exchange commission logo

                           September 23, 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 10-Q for the
Quarter Ended June 30, 2020
                                                            Filed July 30, 2020
                                                            Form 8-K Filed July
28, 2020
                                                            File No. 001-34516

       Dear Mr. Lasota:

              We have reviewed your August 10, 2020 response to our comment
letter 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
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       July 13, 2020 letter.

       Form 8-K Filed July 28, 2020

       Exhibit 99.1
       Non-GAAP Financial Measures, page 8

   1.                                                   We note your response
to prior comment 2. We continue to evaluate your response and
                                                        may have further
   2.                                                   We note your response
to prior comment 3. In future period filings where you provide the
                                                        reconciliation from Net
income attributable to Cowen Inc. Common Stockholders to
                                                        Economic Income (Loss),
please remove the adjustments pertaining to prior periods to
 Stephen Lasota
September 23, 2020
Page 2
         conform to your current presentation. Refer to Question 100.02 of the
Division   s Non-
         GAAP Financial Measures Compliance & Disclosure Interpretations.
Form 10-Q for the Quarter Ended June 30, 2020

Notes to Unaudited Condensed Consolidated Financial Statements
Note 22 - Segment Reporting, page 59

3.       We note you reclassify certain amounts to and make certain adjustments
to the amounts
         you disclose as revenue for each of your reportable segments. Please
tell us how the
         amounts you disclosed as revenue for each reportable segment complies
with ASC 280-
         10-50-22(a). Please also explain to us your basis for disclosing other
amounts for each of
         your reportable segments that reflect adjustments and
reclassifications, such as various
         expense amounts disclosed on page 60, citing the applicable
authoritative guidance. Refer
         to ASC 280-10-50.
4.       You disclose on page 59 that the performance measure for your segments
is    Economic
         Income (Loss).    You appear to disclose measures of profit or loss
for each reportable
         segment in addition to    Economic Income (Loss),    including amounts
in the    Income
         (loss) attributable to Cowen Inc.,    line item, as well as
Economic Operating Income
         (Loss).    If your chief operating decision maker uses more than one
measure in assessing
         segment performance and deciding how to allocate resources, the
reported measure shall
         be the measure that management believes is determined in accordance
with the
         measurement principles most consistent with those used in measuring
the corresponding
         amounts in your consolidated financial statements. Please tell us how
your disclosure
         complies with ASC 280-10-50-22 and 28.
5.       Please tell us how your disclosure complies with the requirement to
reconcile from the
         total of your reportable segments    measures of profit or loss to
consolidated income before
         income taxes and discontinued operations. Refer to ASC
       You may contact Dave Irving at 202-551-3321 or Sharon Blume at
202-551-3474 if you
have questions.

FirstName LastNameStephen Lasota                              Sincerely,
Comapany NameCOWEN INC.
                                                              Division of
Corporation Finance
September 23, 2020 Page 2                                     Office of Finance
FirstName LastName