SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

October 9, 2007
  Mr. Joseph M. Ramos, Jr. Chief Financial Officer, Siebert Financial Corp.
885 Third Avenue New York, NY 10022
Re: Siebert Financial Corp.
Form 10-K for the year ended December 31, 2006 File No. 0-5703

Dear Mr. Ramos:

We have reviewed your response to our letter dated September 20, 2007 and have the
following comments.  We ask that  you respond by October 23, 2007.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing.  We look forward to working with you in these respects.  We welcome any questions
you may have about our comments or on any other aspe ct of our review.  Feel free to call us at
the telephone numbers listed at  the end of this letter.
 Consolidated Statement of Income, page F-3

1. We note your response to comment 2 in our  letter dated September 20, 2007.  We note
that you continue to believe income from e quity investees should be presented within
revenues as Rule 5-03.13 of Re gulation S-X provides for flexibility in the position of
income from equity investees and does not sp ecifically prohibit this line item from being
shown as revenues.  As previously refe renced, Section XI.B. of the March 11, 2003
meeting minutes of the SEC Regulations Co mmittee notes that Regulation S-X allows
equity income of investees to be include d within operating inco me, but not within
revenues.  Further, we note your secondary suggestion to present income from equity
investees between revenue and expenses and incl ude a subtotal of revenues and equity in
investees earnings.  Based on your respons e letter, it appears your equity method
investees are integral to your operations.  However, based on the guidance in Rule 5-
03.13 of Regulation S-X, a more appropriate location for income from equity method
investees integral to your opera tions would be after the expens es subtotal.  Please revise
your consolidated statements of income presentation accordingly in future filings.

Mr. Joseph M. Ramos, Jr.
Siebert Financial Corp.
October 9, 2007 Page 2

As appropriate, please amend your filing a nd respond to these comments within 10
business days or tell us when you will provide us  with a response.  Please provide us with a
supplemental response letter that keys your re sponses to our comments and provides any
requested supplemental information.  Detailed letter s greatly facilitate our review.  Please file
your supplemental response on EDGAR as a corres pondence file.  Please understand that we
may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to Mindy
Hooker, Staff Accountant, at (202) 551-3732, Tr acey Houser, Staff Accountant, at (202) 551-
3736 or to the undersigned at (202) 551-3768.
Sincerely,    John Cash Branch Chief