SIEBERT FINANCIAL CORP 10-K

ITEM 3. LEGAL PROCEEDINGS We are party to certain claims, suits and complaints arising in the ordinary course of business. For activity related to operations of StockCross prior to our acquisition of StockCross, FINRA’s Division of Enforcement is currently investigating UIT transactions that were executed by StockCross that the enforcement staff believes were terminated early. We believe that many of these transactions were UIT transactions that were the subject of our prior settlements with the Commonwealth of Massachusetts and the State of California. All of these transactions occurred prior to our acquisition of StockCross on January 1, 2020. Siebert 2021 Form-10K 17 Management cannot at this time assess either the duration or the likely outcome or consequences of the FINRA investigation. Nevertheless, FINRA has the authority to impose sanctions on Siebert or require that it make offers of restitution to other customers who FINRA believes incurred sales charges in early liquidations of UITs. No assurances can be given that a mutual settlement with FINRA regarding the investigation can be reached or that any amount paid in settlement will not be material. Refer to Note 22 – “Commitments, Contingencies and Other” for more detail. As of December 31, 2021, in the opinion of management, all other legal matters are without merit, or involve amounts which would not have a significant effect on our results of operations or financial position. ITEM 4. MINE SAFETY DISCLOSURES Not applicable. Siebert 2021 Form-10K 18 PART II