# HORANG SECURITIES, LLC X-17A-5 (2022-03-29) — Broker-dealer annual report

- Company: HORANG SECURITIES, LLC
- Form: X-17A-5
- Filed: 2022-03-29
- Period: 2021-12-31
- Accession: 0000084940-22-000001
- CIK: 84940
- File #: 8-16608
- Type: Broker-dealer
- Material weakness: No
- Auditor: Rubio CPA, PC
- Auditor location: Atlanta, GA
- Contact: Brent E Hippert
- Phone: 14435418400
- Email: brrent@bdexpert.com
- Website: bdexpert.com
- Signed by: Brent Hippert (CFO)

Original filing: https://www.sec.gov/Archives/edgar/data/84940/000008494022000001/hs_fs2021va.pdf

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UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

### **ANNUAL REPORTS FORM X-17A-5 PART Ill**

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8-16608

FACING PAGE

Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934

| FILING FOR THE PERIOD BEGINNING                                                                                                                                                                                                                                                              | ___                                                        | ___<br>.:::0.:.1/i.o:O=l"-'/2=1=--.-ANO ENDING                                                          | -=1""'2/'""'3-=1  /2  1.___                 |
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|                                                                                                                                                                                                                                                                                              | MM/DD/YY                                                   |                                                                                                         | MM/DD/YY                                    |
|                                                                                                                                                                                                                                                                                              | A. REGISTRANT IDENTIFICATION                               |                                                                                                         |                                             |
| NAME OF FIRM: Horang Securities, LLC                                                                                                                                                                                                                                                         |                                                            |                                                                                                         |                                             |
| TYPE OF REGISTRANT (check all applicable boxes):                                                                                                                                                                                                                                             |                                                            |                                                                                                         |                                             |
| 0 Broker-dealer<br>0 Security-based swap dealer                                                                                                                                                                                                                                              |                                                            | 0 Major security-based swap participant<br>0 Check here if respondent is also an OTC derivatives dealer |                                             |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                                                                                                                                                                          |                                                            |                                                                                                         |                                             |
| 400 Madison Ave, RM 11A                                                                                                                                                                                                                                                                      |                                                            |                                                                                                         |                                             |
|                                                                                                                                                                                                                                                                                              | (No. and Street)                                           |                                                                                                         |                                             |
| New York                                                                                                                                                                                                                                                                                     | NY                                                         |                                                                                                         | 10017                                       |
| (Qty)                                                                                                                                                                                                                                                                                        | (State)                                                    |                                                                                                         | (Zip Code)                                  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING<br>Brent Hippert                                                                                                                                                                                                                                | (443) 541-8400                                             |                                                                                                         | brrent@bdexpert.com                         |
| (Name)                                                                                                                                                                                                                                                                                       | (Area Code -Telephone Number)                              | (Email Address)                                                                                         |                                             |
|                                                                                                                                                                                                                                                                                              | B. ACCOUNTANT IDENTIFICATION                               |                                                                                                         |                                             |
| INDEPEINDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>Rubio CPA, PC                                                                                                                                                                                                  | {Name - if individual, state last, first, and middle name) |                                                                                                         |                                             |
| 2727 Paces Ferry Rd SE, STE 2-1680                                                                                                                                                                                                                                                           | Atlanta                                                    | Georgia                                                                                                 | 30339                                       |
| {Address.)                                                                                                                                                                                                                                                                                   | {City)                                                     | (:State)                                                                                                | {Zip Code)                                  |
| 05/05/2009                                                                                                                                                                                                                                                                                   |                                                            | 3514                                                                                                    |                                             |
| (Date of Registration with PCAOB)(if applicable)                                                                                                                                                                                                                                             |                                                            |                                                                                                         | (PCAOB Reitistration Number, if applicable) |
|                                                                                                                                                                                                                                                                                              | FOR OFFICIAL USE ONLY                                      |                                                                                                         |                                             |
| •Claims for exemption from the requirement t hat the annual reports be covered by the reports of an Independent publlc<br>accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17<br>CFR 240.17a-S(e)(l)(ii), if .applicable. |                                                            |                                                                                                         |                                             |

PQrsons who are to respond to the collection of Information contained In this form are not required to respond unless the form displays a currently valid OMB control number.

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#### OATH OR AFFIRMATION

| I, | Brent E. Hippert | , swear (or affirm) that, to the best of my knowledge and belief, the |
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|    |                  |                                                                       |

financial report pertaining to the firm of Horang Securities, LLC • as of

December 31 , 2021 , is true and correct. I further swear (or affirm) that neither the company nor any partner, officer, director, or equlvalent person, as the case may be, has any proprietary Interest In any account classified solely as tha MCNEAL SHEELER /!:J

| Baltimore Notaiy Pub County lic      |        |
|--------------------------------------|--------|
| My Commission Expires Oct.<br>/<br>1 | Title: |
| 4'5.etibU!tri m                      |        |

Signature: ~ Ma~~nd ~~~~~~~-==-r~~~\_,,.""'""7!~~~~

Notary Public

#### This filing\*\* contains (check all applicable boxes):

- 0 (a) Statement of financial condition.
- 0 (b) Notes to consolidated statement of financial condition.
- 0 (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a .statement of comprehensive income (as defined in§ 210.1-02 of Regulation S-X).
- 0 (d) Statement of cash flows.
- 0 (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- 0 (f) Statement of changes in liabilities subordinated to claims of creditors.
- 0 (g) Notes to consolidated financial statements.
- 0 (h) Computation of net capirtal under 17 CFR 240.15c3-1or17 CFR 240.18a-1, as applicable.
- 0 (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- 0 U) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR240.15c3-3.
- 0 {k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- 0 (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.1Sc3-3.
- 0 (m) Information relating to possession or control requirements for customers under 17 CFR 240.1Sc3-3.
- 0 {n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.1Sc3-3(p)(2) or 17 CFR 240.18a-4, as applicable.
- 0 (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-l, 17 CFR 240.18a-l, or 17 CFR 240.18a-2, as applicable, and the reserve requirements urnder 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- 0 (p) Summairv of financial data for subsidiaries not consolidated in the statement of financial condition.
- 0 (q) Oath or affirmation in accordance with 17 CFR 240.17a-S, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- 0 (r) Compliance report in accordance with 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable.
- 0 (s) Exemption report in accordance with 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable.
- 0 (t) Independent public accountant's report based on an examination of the statement of financial condirtion.
- 0 (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-S, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- 0 (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable.
- li1 (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- 0 (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable.
- D (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statementthat no material inadequacies exist, under 17 CFR 240.17a-12(k). 0 (z) Other:-------- ------------------------------

"'"To request confidential treatment of certain portions of this filing, see 17 CFR 240.17o-5(e)(3) or 17 CFR 240.18a-7(d}{2), as applicable.

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FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31 , 2021 WITH REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

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### **Table of Contents**

Report of Independent Registered Public Accounting Firm

Financial Statements

Statement of Financial Condition

Statement of Operations

Statement of Changes in Member's Equity

Statement of Cash Flows

- Notes to Financial Statements
- Schedule I Computation of Net Capital

Schedules II and Ill

Independent Registered Public Accounting Firm Report on Exemption Report

Exemption Report

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# **RUBIO CPA, PC**

CERTIFIED PUBLIC ACCOUNTANTS 2727 Paces Ferry Road SE

Building 2, Suite 1680 Atlanta, GA 30339 Office: 770 690-8995 Fax: 770 838-7123

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Member of Harang Securities, LLC

#### Opinion on the Financial Statements

We have audited the accompanying statement of financia l condition of Horang Securities, LLC (the "Company") as of December 31, 2021, the related statements of operations, changes in member's equity, and cash flows for the year then ended and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31 , 2021 , and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America.

#### Basis for Opinion

These financial statements are the responsibility of the Company' s management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting finn registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whetiher due to error or fraud. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audit we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion.

Our audit included performing procedures to assess the risks of material misstatement to the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

#### Supplemental Information

The information contained in Schedules I, II and Ill has been subjected to audit procedures performed in conjunction with the audit ofthe Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determining whether the information in Schedules I, II and III reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the accompanying schedules. In forming our opinion on the accompanying schedules, we evaluated whether the supplemental information, including its form and content, is presented

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in conformity with 17 C.F.R. §240. I 7a-5. In our opinion, the aforementioned supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole.

We have served as the Company's auditor since 2016.

March 22, 2022 Atlanta, Georgia

~CPA,~ Rubio CPA, PC

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#### STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2021

#### **ASSETS**

| Cash<br>Accounts Receivable | \$<br>40,1 13<br>9,928 |
|-----------------------------|------------------------|
| Total Assets                | \$<br>50,041           |

#### **LIABILITIES AND MEMBER'S EQUITY**

| Due to Member                         | \$<br>4,370  |
|---------------------------------------|--------------|
| Total Liabilities                     | 4,370        |
| MEMBER'S EQUITY                       | 45,671       |
| Total Liabilities and member's equity | \$<br>50,041 |

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#### **STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER** 31, **2021**

#### **REVENUE**

| Mutual Fund Fees              | \$<br>38,732  |
|-------------------------------|---------------|
| Advisory Fees                 | 2,950,000     |
| Other                         | 6,000         |
| TOTAL REVENUE                 | 2,994,732     |
| EXPENSES:                     |               |
| Commissions and Compensation  | 2,798,500     |
| Professional fees             | 34,000        |
| Occupancy                     | 4,800         |
| Technology and Communications | 4,375         |
| Other                         | 8,738         |
| Total expenses                | 2,850,413     |
| Net Income                    | \$<br>144,319 |

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#### STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31, 2021

| MEMBER'S EQUITY, DECEMBER 31, 2021 | \$<br>45,671   |
|------------------------------------|----------------|
| Distributions                      | (220,000)      |
| Net income                         | 144,319        |
| MEMBER'S EQUITY, JANUARY 1, 2021   | \$<br>121 ,352 |

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#### **STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER** 31, **2021**

#### **CASH FLOWS FROM OPERATING ACTIVITIES:**

| Net income                                      | \$<br>144,319 |
|-------------------------------------------------|---------------|
| Adjustments to reconcile net income to net cash |               |
| provided by operating activities:               |               |
| Changes in assets and liabilities               |               |
| Accounts receivable                             | (1 ,789)      |
| Accrued expenses                                | (877)         |
| Due to Member                                   | 3,403         |
| Net cash provided by operating activities       | 145,056       |
| CASH FLOWS FROM FINANCING ACTIVITIES            |               |
| Distributions                                   | (220,000)     |
| Net cash used by financing activities           | (220,000)     |
| NET DECREASE IN CASH                            | (74,944)      |
| CASH AT BEGINNING OF YEAR                       | 115,057       |
| CASH AT END OF YEAR                             | \$<br>40,1 13 |

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#### **Note A - Organization and Summary of Significant Accounting Policies**

#### **Organization and Nature of Operations**

Horang Securities, LLC (the "Company") is a securities brolker-dealer registered with the Securities and Exchange Commission (SEC) and a member of the Financial Industry Regulatory Authority (FINRA). As a Limited Liability Company, the Member's liability is limited to its investment. The Company was formed under the laws of the State of Delaware on June 1, 1971 . Activities of the Company include merger and acquisition activities and a historic business of collecting trail commissions from prior sales of mutual funds and of variable annuity contracts. The Company is a wholly owned subsidiary of Horang Capital, LLC (the "Member"). The Company principally works with companies that have a relationship with its Member that are involved in M&A transactions, and are raising additional equity and debt capital.

#### **Accounting Policies**

The Company follows Generally Accepted Accounting Principles (GAAP), as established by the Financial Accounting Standards Board (the FASB), to ensure consistent reporting of financial condition, results of operations, and cash flow.

The Company maintains its bank account in a high credit quality financial institution. The balance at times may exceed federally insured limits.

#### **Revenue Recognition**

Revenue from contracts with customers includes placement and advisory se1rvices as well as mutual fund fees. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgement is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on appropriate measure of the Company's progress under the contract; whether revenue should be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events.

Mutual funds or pooled investment vehicles (collectively, "funds") have entered into agreements with the Company to distribute/sell its shares to investors. The Company may receive distribution fees paid by the funds, upfront, over time, or as a combination thereof. The Company believes its performance obligation is the sale of securities to investors and as such this is fulfilled on the trade date. Any fixed amounts are recognized on the trade date and variable amounts are recognized to the extent it is probable that a significant revenue reversal will not occur once the uncertainty is resolved. For variable a.mounts, as the uncertainty is dependent on the value of the shares at future points in time as well as the length of time the investor remains in the fund, both of which are highly susceptible to factors outside the Company's influence, the Company does not believe that it can overcome this constraint until the market value of the fund and the investor activities are known, which are usually quarterly or monthly.

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### Note A- Organization and Summary of Signiificant Accounting Policies (continued)

#### Revenue Recognition (continued)

The Company provides placement and advisory services related to capital raising activities and mergers and acquisitions transactions. Revenue from advisory arrangements is generally recognized at the point in time that performance under the agreement is completed (the closing date of the transaction) or the contract is terminated. However, for certain contracts, revenue is recognized over time for advisory arrangements in which the performance obligations are simultaneously provided by the Company and consumed by the customer. In some circumstances, significant judgment is needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract.

Success fees are recognized in accordance with terms agreed upon with each customer and are generally based on (1) a percentage of capital raised or (2) profit allocated and management fees earned by a customer on funds received from investors introduced by the Company. These fees are recognized upon the consummation of a transaction as this satisfies the only performance obligation identified by the Company.

#### Accounts Receivable

Accounts receivable are non-interest-bearing uncollateralized obligations receivable in accordance with the terms agreed upon with each customer. The Company regularly reviews its accounts receivable for any uncollectible amounts. The review for uncollectible amounts is based on an analysis of the Company's collection experience, customer credit worthiness, and current economic treads. Based on management's review, no allowance for credit losses is considered to be necessary.

#### Income Taxes

The Company is a single member limited liability company and is considered a disregarded entity for federal income tax reporting purposes and as such, does not file a separate income tax return. The income or losses of the Company flow through to and are taxable to the Member. Therefore, no income taxes are reflected in the accompanying financial statements.

fhe Company has adopted the provisions of f'ASB Accounting Standards Codification 740- 10 (ASC 740-10), Accounting for Uncertainty in Income Taxes. Under ASC 740-10, the Company is required to evaluate each of its tax positions to determine if they are more likely than not to be sustained if the taxing authority examines the respective position. A tax position includes an entity's status, including its status as a pass-through entity, and the decision not to file a tax return. The Company has evaluated each of its tax positions and has determined that no provision or liability for income taxes is necessary.

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### Note A- Organization and Summary of Signiificant Accounting Policies (continued)

#### Use of Estimates

The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets, liabilities, revenues, and expenses. Actual results could vary from the estimates that were assumed in preparing the financial statements.

#### Subsequent Events

The Company evaluated subsequent events through the date the financial statements were issued. The evaluation did not result in any subsequent events that required disclosure and I or adjustments.

#### Note B - Net Capital

The Company, as a registered broker dealer, is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 115c3-1 ), which requires the maintenance of minimum net capital, equal to the greater of \$5,000 or 6 2/3% of aggregate indebtedness as well as a ratio of aggregate indebtedness to net capital, both as defined, that shall not exceed 15 to 1. At December 31 , 2021 , the Company had net capital of \$35, 7 43 which was, \$30, 7 43 in excess of its required minimum net capital of \$5,000 and the percentage of aggregate indebtedness to net capital was 12.2%.

#### Note C - Related Party Transactions

The Company has a services agreement in place with its Member for office space, personnel, and other administrative services provided to the Company. Under the terms of this agreement, the Company pays the Member its allocated share for the services provided. Expenses allocated to the Company under the agreement amounted to approximately \$16,200 for the year ended December 31 , 2021. The balance due to Member on the accompanying statement of financial condition arose from this agreement. Amounts due to Member are not interest bearing and have no specified due date. Financial position and results of operations might differ from the amounts in accompanying financial statements if this agreement did not exist.

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#### **Note D - Contingencies**

The Company is subject to litigation in the normal course of business. The Company has no litigation in progress at December 31, 2021.

#### **Note E - Concentration**

Approximately 93% of investment banking revenues earned in 2021 were from two customers and approximately 81 % of mutual fund fees were earned from one fund company.

Approximately 85% of accounts receivable at December 31 , 2021 are due from one fund company.

#### **Note F - Economic Risks**

In March 2020, the World Health Organization (WHO) declared COVID-19 a global pandemic. This pandemic event has resulted in significant business disruption and uncertainty in both global and U.S. markets. While the Company believes that it is in an appropriate position to sustain the potential short-term effects of these world-wide events, the direct long-term impact to the Company and its financial statements is undetermined at this time.

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#### **Schedule** I - **Computation Of Net Capital Under Rule 15c3-1 Of The Securities And Exchange Commission As Of December 31, .2021**

| Total Member's Equity                                                                    | \$<br>45,671                         |
|------------------------------------------------------------------------------------------|--------------------------------------|
| Less: Nonallowable assets<br>Accounts receivable                                         | 9,928                                |
| Net capital                                                                              | \$<br>35,743<br>===================  |
| Minimum net capital requirement (greater of \$5,000 or 6 2/3% of aggregate indebtedness) | \$<br>5,000<br>====================  |
| Excess net capital                                                                       | \$<br>30,743<br>==================== |
| Total Aggregate indebtedness                                                             | \$<br>4,370<br>===================   |
| Percentage of aggregate indebtedness to net capital                                      | 12.2%                                |

Reconciliation with the Company's computation of net capital included in Part II A of Form X-17A-5 as of December 31 , 2021:

There is no difference between the above computation and net capital as reported in the Company's Part llA of Form X-17A-5 as of December 31, 2021

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#### HORANG SECURITIES, LLC As of December 31, 2021

#### SCHEDULE II

#### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

The Company does not claim exemption from SEA Rule 15c3-3 in reliance upon Footnote 7 4 of the 2013 Release. The Company does not hold customer funds or securities.

#### SCHEDULE Ill

#### INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION

The Company does not claim exemption from SEA Rule 15c3-3 in reliance upon Footnote 7 4 of the 2013 Release. The Company does not hold customer funds or securities.

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# **RUBIO CPA, PC**

CERTIFIED PUBLIC ACCOUNTANTS 2727 Paces Ferry Road SE

Building 2, Suite 1680 Atlanta, GA 30339 Office: 770 690-8995 Fax: 770 838-7123

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Member of Horang Securities, LLC

We have reviewed management's statements included in the accompanying Broker Dealers Annual Exemption Report in which (I) Horang Securities, LLC did not claim an exemption from Rule I Sc3-3 in reliance upon Footnote 74 of the 2013 Release, and (2) Horang Securities, LLC stated that Horang Securities, LLC met the identified conditions for such reliance throughout the most recent fiscal year without exception. Horang Securities, LLC's management is responsible for compliance with the exemption provisions and its statements.

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Horang Securities, LLC's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.

Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth En Footnote 74 of the 2013 Release.

March 22, 2022 Atlanta, GA

> ~U'f-.Jfc. Rubio CPA, PC

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### **Exemption Report**

Horang Securities, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following:

(1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to (1) effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; (2) receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients, referring securities transactions to other broker-dealers, or providing technology or platform services; (3) participating in distributions of securities (other than firm commitment underwritings) in accordance with the requirements of paragraphs (a) or (b)(2) of Rule 15c2-4; and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

Harang Securities, LLC

I, Brent E. Hippert, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

By: /3:;st-~

Title: CFO March 14, 2022


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
