September 7, 2018

Andrew H. Reich
Chief Financial Officer
Siebert Financial Corp.
120 Wall Street
New York, New York 10005

       Re: Siebert Financial Corp.
           Form 10-K for Fiscal Year Ended December 31, 2017
           Filed April 13, 2018
           Form 10-Q for Fiscal Quarter Ended June 30, 2018
           Filed August 13, 2018
           File No. 000-05703

Dear Mr. Reich:

       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 Fiscal Year Ended December 31, 2017

Notes to Consolidated Financial Statements
Note E - Income Taxes, page F-11

1.    Please tell us and revise your future filings to discuss in detail how
the adoption of the Tax
      Cuts and Jobs Act impacted your current and future financial results and
your financial
      position at December 31, 2017. Refer to ASC 740-10-50-9(g) for guidance.
Note A - Business Order, page F-8

2.    You disclose that you accounted for the StockCross acquisition as an
entity under
      common control, pursuant to ASC 805-50 and that the acquisition did not
change the
 Andrew H. Reich
FirstName LastNameAndrew H. Reich
Siebert Financial Corp.
Comapany 7, 2018
September NameSiebert Financial Corp.
September 7, 2018 Page 2
Page 2
FirstName LastName
         composition of Muriel Siebert & Co, Inc., a wholly owned subsidiary of
the company, as a
         reporting entity. Please tell us in detail how you considered whether
the acquisition
         resulted in a change in reporting entity of Siebert Financial Corp.
considering the
         guidance in ASC 250. If you believe the transaction resulted in a
change in reporting
         entity, please tell us how you concluded that the consolidated
financial statements are
         presented in accordance with the guidance in ASC 805-50-45, or revise
as appropriate.
Form 10-Q for Fiscal Quarter Ended June 30, 2018

Financial Statements
Note 7. Provision for Income Taxes, page 9

3.       We note your disclosure that due to cumulative previous losses
incurred by the Company,
         the Company is unable to conclude it is more likely than not to
realize its deferred tax
         asset in excess of the deferred tax liability and accordingly, the
Company has recorded a
         full valuation allowance as of December 31, 2017 and June 30, 2018. We
also note you
         have recorded net income for fiscal year ended December 31, 2017 and
subsequent
         quarterly periods ended March 31, 2018 and June 30, 2018. Please
ensure you consider
         all available evidence, both positive and negative, to determine
whether, based on the
         weight of that evidence, a valuation allowance for deferred tax assets
is needed. Refer to
         ASC 740-10-30-16 through 30-25 for guidance. Additionally, please
revise future
         filings to discuss the factors that impact your estimates and judgment
regarding the
         realizability of your deferred tax asset and the measurement of your
valuation allowance.
         Refer to ASC 740-10-50-21 for guidance.
Item 4. Controls and Procedures, page 13

4.       In your December 31, 2017 Form 10-K, you disclosed on page 25 that
your disclosure
         controls and procedures were ineffective based on material weaknesses
in internal control
         over financial reporting relating to (i) your lack of sufficient
qualified financial reporting
         and accounting personnel with an appropriate level of expertise to
properly address
         complex accounting issues under generally accepted accounting
principles (GAAP) and to
         prepare and review your consolidated financial statements and related
disclosures to fulfill
         GAAP and SEC financial reporting requirements; and (ii) failure to
utilize a disclosure
         checklist to ensure that all relevant and required GAAP disclosures
are properly included
         in the financial statements. We also note your disclosure on page 26
related to your
         remediation efforts. Given your disclosure in both your 2018 Forms
10-Q that there were
         no material changes in your internal controls over financial reporting
and that you were in
         the process of developing a remediation plan under the supervision of
the Audit
         Committee and Board of Directors to improve the effectiveness of your
controls, please
         tell us and revise to disclose in detail the basis for your officers'
conclusions that the
         company's disclosure controls and procedures were effective as of the
end of each of the
         interim reporting periods ended March 31, 2018 and June 30, 2018.
 Andrew H. Reich
Siebert Financial Corp.
September 7, 2018
Page 3

       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 John Spitz, Staff Accountant, at (202) 551-3484 or
Michael Volley,
Staff Accountant, at (202) 551-3437 with any questions.



FirstName LastNameAndrew H. Reich                         Sincerely,
Comapany NameSiebert Financial Corp.
                                                          Division of
Corporation Finance
September 7, 2018 Page 3                                  Office of Financial
Services
FirstName LastName