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                               February 13, 2023

       Kathleen Simpson-Taylor
       Chief Financial Officer
       A-Mark Precious Metals, Inc.
       2121 Rosecrans Ave., Suite 6300
       El Segundo, CA 90245

                                                        Re: A-Mark Precious
Metals, Inc.
                                                            Form 10-K for the
Fiscal Year Ended June 30, 2022
                                                            Filed September 2,
2022
                                                            File No. 1-36347

       Dear Kathleen Simpson-Taylor:

              We have reviewed your filings 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 the Fiscal Year Ended June 30, 2022

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Non-GAAP Measures
       Earnings before interest, taxes, depreciation, and amortization, page 46

   1.                                                   Your reconciliation of
EBITDA to Operating Cash Flows presents the non-GAAP
                                                        measure more
prominently than the comparable GAAP measure. Please revise the
                                                        reconciliation to begin
with the net cash used in operating activities for equal or greater
                                                        prominence. Refer to
Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10(b) of
                                                        the Non-GAAP Financial
Measures Compliance and Disclosure Interpretations. This
                                                        comment also applies to
your disclosure in the Form 10-Q for fiscal quarter ended
                                                        December 31, 2022 and
Item 2.02 Form 8-K dated February 7, 2023.
       Item 7A. Quantitative and Qualitative Disclosures About Market Risk,
page 55

   2.                                                   Please tell us your
consideration of including the disclosures in Item 305 of Regulation S-
 Kathleen Simpson-Taylor
A-Mark Precious Metals, Inc.
February 13, 2023
Page 2
         K since you are no longer a smaller reporting company.
Item 8. Financial Statements and Supplemental Data, page 56

3.       Please tell us your consideration of presenting statements of
comprehensive income,
         statements of cash flows, and statements of stockholders' equity for
each of the three fiscal
         years ended June 30, 2022 in accordance with Rules 3-02 and 3-04 of
Regulation S-X.
Signatures, page 107

4.       The annual report should also be signed by Kathleen Simpson-Taylor in
her capacity as
         the Chief Accounting Officer or Controller or the person performing
this function. Refer
         to General Instruction D(2)(a) to Form 10-K.
        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 Tony Watson at (202) 551-3318 or Suying Li at (202)
551-3335 if you
have questions.



FirstName LastNameKathleen Simpson-Taylor                      Sincerely,
Comapany NameA-Mark Precious Metals, Inc.
                                                               Division of
Corporation Finance
February 13, 2023 Page 2                                       Office of Trade
& Services
FirstName LastName