SEC Comment Letter for SIEBERT FINANCIAL CORP (SIEB) (CIK 0000065596) (SIEB) — Feb 19, 2010
SIEBERT FINANCIAL CORP (SIEB) (CIK 0000065596)
Date: Feb. 19, 2010 · CIK: 0000065596 · Accession: 0000000000-10-009315
AI Filing Summary & Sentiment
File numbers found in text: 001-32248
Referenced dates: January 15, 2010
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3010 February 19, 2010 Muriel F. Siebert Siebert Financial Corp. 885 Third Avenue New York, NY 10022
Re: Siebert Financial Corp. Form 10-K for the Fiscal Year Ended December 31, 2008 Form 10-Q for the Fiscal Quar ter Ended September 30, 2009 File No. 001-32248
Dear Mrs. Siebert: We have reviewed your response letter dated January 15, 2010, and have the following additional comments. Form 10-K
Financial Statements and Notes Consolidated Statements of Operations, page F-3
1. We have read and considered your respons e to comment three. We note that you are presenting your Statement of Operations using a singl e-step format; however, such presentation is inconsistent with th e requirements of Rule 5-03 of Regulation S-X. Specifically, non-operating reve nue and expenses should be shown separately from operating revenue and expenses on your Statement of Operations. Please confirm as to whether you plan to revise, in future filings, your Statement of Operations so that the presenta tion is consistent with Rule 5-03.
Note I – Financial Instruments with off-balan ce sheet risk and concentrations of credit risk, page F-15 2. We have read and considered your res ponse to comment four. Please confirm you plan to expand your disclosure in future filings to discuss the company’s exposure in the event the customer does not fulfill their contractual obligation.
Muriel F. Siebert Siebert Financial Crop. February 19, 2010 Page 2 * * * *
As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please file your responses on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comment. You may contact Yolanda Crittendon, A ccountant at (202) 551-3472 or me at (202) 551-3413 with any other questions. S i n c e r e l y , Cicely LaMothe Accounting Branch Chief
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3010 February 19, 2010 Muriel F. Siebert Siebert Financial Corp. 885 Third Avenue New York, NY 10022 Re: Siebert Financial Corp. Form 10-K for the Fiscal Year Ended December 31, 2008 Form 10-Q for the Fiscal Quar ter Ended September 30, 2009 File No. 001-32248 Dear Mrs. Siebert: We have reviewed your response letter dated January 15, 2010, and have the following additional comments. Form 10-K Financial Statements and Notes Consolidated Statements of Operations, page F-3 1. We have read and considered your respons e to comment three. We note that you are presenting your Statement of Operations using a singl e-step format; however, such presentation is inconsistent with th e requirements of Rule 5-03 of Regulation S-X. Specifically, non-operating reve nue and expenses should be shown separately from operating revenue and expenses on your Statement of Operations. Please confirm as to whether you plan to revise, in future filings, your Statement of Operations so that the presenta tion is consistent with Rule 5-03. Note I – Financial Instruments with off-balan ce sheet risk and concentrations of credit risk, page F-15 2. We have read and considered your res ponse to comment four. Please confirm you plan to expand your disclosure in future filings to discuss the company’s exposure in the event the customer does not fulfill their contractual obligation. Muriel F. Siebert Siebert Financial Crop. February 19, 2010 Page 2 * * * * As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please file your responses on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comment. You may contact Yolanda Crittendon, A ccountant at (202) 551-3472 or me at (202) 551-3413 with any other questions. S i n c e r e l y , Cicely LaMothe Accounting Branch Chief