# BRADESCO INVESTMENTS INC. X-17A-5 (2025-03-26) — Broker-dealer annual report

- Company: BRADESCO INVESTMENTS INC.
- Form: X-17A-5
- Filed: 2025-03-26
- Period: 2024-12-31
- Accession: 0000811093-25-000006
- CIK: 811093
- File #: 8-37483
- Type: Broker-dealer
- Material weakness: No
- Auditor: KPMG LLP
- Auditor location: NEW YORK, NY
- Contact: MAURICIO CUNHA
- Phone: 305 523 6529
- Email: montha@bradessopank.com
- Website: bradessopank.com
- Signed by: MAURICIO CUNHA (Head of Bradesco Investments)

Original filing: https://www.sec.gov/Archives/edgar/data/811093/000081109325000006/bi2024fspb.pdf

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| OWER OMB AMOVAL<br>ON 8 Nomber: 3335-0123<br>hours per response: 12<br>Estimated average burden<br>Expires: Nov. 30, 2026 |
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| ABBINON 321-235<br>8-37488 |  |
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| 10 m 1 m 1 m 1 m 1 m 1 m 1 m 1 - 6 m 1 - 6 1 b 1 2 - 5 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 |
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|        | AND AND STORES ONLY CARS                                                                                                                                                       |
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| anii<br>Ina-                                 | No. and Street)               |                         |
|----------------------------------------------|-------------------------------|-------------------------|
| Coral Gables                                 | Fornol F                      | 33134                   |
| City                                         | State                         | Zip Code)               |
| DOLLIFE SHE OT GRADER HTIW TOATHOO OT MOSSES |                               |                         |
| suuntion Cunha                               | 8059-823-6599                 | montha@bradessopank.com |
| Name                                         | Area Code - Telephone Number) | Email Address)          |
|                                              | ИОНТАЭГЧИНЭОГ ТИАТИЦОЭЭА .8   |                         |

| 345 Park Avenue                                 | ə qalınması və qalınmışdır. Bu mənist | AN    | 10154-0102                                  |
|-------------------------------------------------|---------------------------------------|-------|---------------------------------------------|
| Address                                         | City)                                 | State | Zip Code)                                   |
| 00/2002/02/01                                   |                                       | G8    |                                             |
| Des of Restaurantin PORGO (fragues) (fraggicals |                                       |       | 900 Residents Resembly Rummer if applicably |
|                                                 | ON OFFICIAL USSE ONLY                 |       |                                             |

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

**STATEMENT OF FINANCIAL CONDITION**  December 31, 2024

**BRADESCO INVESTMENTS INC. (S.E.C I.D. No. 8-37483)** 

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### BRADESCO INVESTMENTS INC.

## FINANCIAL STATEMENTS CONDITION

December 31, 2024

### TABLE OF CONTENTS

| NOTES TO FINANCIAL STATEMENT  3<br>STATEMENT OF FINANCIAL CONDITION  2 | FINANCIAL STATEMENT |
|------------------------------------------------------------------------|---------------------|
| REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM  1             |                     |

.

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Miami, FL 33130 78 SW 7 Street Brickell City Centre, Suite 1200 KPMG LLP

## **Report of Independent Registered Public Accounting Firm**

Bradesco Investments Inc.: To the Stockholder and Board of Directors

*Opinion on the Financial Statement*

We have audited the accompanying statement of financi al condition of Bradesco Investments Inc. (the Company) as of December 31, 2024, and the related notes (collectively, the financial statement). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2024, in conformity with U.S. generally accepted accounting principles.

### *Basis for Opinion*

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

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 statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, 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 statement. 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 statement. We believe that our audit provides a reasonable basis for our opinion.

We have served as the Company's auditor since 2021.

March 14, 2025 Miami, Florida

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### BRADESCO INVESTMENTS INC. STATEMENT OF FINANCIAL CONDITION December 31, 2024

|                                                                      | 2024                       |
|----------------------------------------------------------------------|----------------------------|
| ASSETS                                                               |                            |
| Cash and due from banks                                              | \$<br>3,259,144            |
| Deposits with clearing firm                                          | 9,892,951                  |
| Operating lease right-of-use asset                                   | 784,091                    |
| Trailer fee receivable                                               | 548,931                    |
| Due from affiliates                                                  | 53,462                     |
| Deferred tax asset, net                                              | 400,057                    |
| Prepaid expenses and other assets                                    | 238,391                    |
| Total assets                                                         | \$<br>15,177,027           |
| Liabilities:<br>LIABILITIES AND STOCKHOLDER'S EQUITY                 |                            |
| Operating lease liability<br>Accounts payable and accrued expenses   | \$<br>2,610,943<br>808,129 |
| Due to affiliates<br>Accrued commissions and other payables          | 1,106,000<br>47,980        |
| Total liabilities                                                    | 4,573,052                  |
| Common stock, \$1 par value; 100,000 shares<br>Stockholder's Equity: |                            |
| Additional paid in capital<br>authorized, issued and outstanding     | 6,911,014<br>100,000       |
| Retained earnings                                                    | 3,592,961                  |
| Stockholder's equity                                                 | 10,603,975                 |
| Total liabilities and stockholder's equity                           | \$<br>15,177,027           |
|                                                                      |                            |
|                                                                      |                            |

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# **NOTE 1 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

Nature of Business: Effective February 26, 2021, BAC Florida Investments Corp.'s legal name changed to corresponding effective dates: Bradesco Investments Inc. is approved to operate as a broker-dealer in the following states since the clearing firm, Apex Clearing Corporation, to clear transactions introduced through Apex's digital platform. York Mellon Corporation. On May 28, 2024, the Company entered into a similar agreement with another transactions on a fully disclosed basis through Pershing LLC ("Pershing"), a subsidiary of The Bank of New transaction services to its customers. The Company clears its regular (i.e., non-digital) securities The Company is 100% owned by Bradesco Bank ("Parent Company"). The Company offers securities and Exchange Commission ("SEC") and is a member of Financial Industry Regulatory Authority ("FINRA"). Bradesco Investments Inc. (the "Company"). The Company is a broker-dealer registered with the Securities Bradesco BAC Florida Investments Corp. Effective March 20, 2023 the Company changed its name to

| US States & Territories | Effective Date |
|-------------------------|----------------|
| Florida                 | 10/28/1987     |
| New York                | 07/08/1991     |
| Georgia                 | 12/13/2017     |
| Delaware                | 03/08/2018     |
| North Carolina          | 12/05/2019     |
| Texas                   | 01/23/2020     |
| District of Columbia    | 08/20/2021     |
| Massachusetts           | 03/30/2022     |
| New Jersey              | 07/08/2022     |
| Tennessee               | 08/18/2022     |
| Maryland                | 09/01/2022     |
| Colorado                | 09/07/2022     |
| Louisiana               | 02/27/2023     |
| Wyoming                 | 06/07/2023     |
| Ohio                    | 09/29/2023     |
| California              | 10/13/2023     |
| South Dakota            | 11/28/2023     |
| Illinois                | 07/31/2024     |
| Missouri                | 09/17/2024     |
| Pennsylvania            | 02/14/2025     |
| Arizona                 | 02/19/2025     |
|                         |                |

Cash and Cash Equivalents: Cash and cash equivalents consists primarily of cash held with its Parent of 90 days or less. Company, clearing firm, and deposits with other financial institutions, all of which have original maturities

and amounts due from and payable to the clearing firm for fees and commissions. Deposits with Clearing Firm: Deposits with our clearing firms consist of restricted cash disclosed in Note 2

Use of Estimates: The preparation of financial statements in conformity with accounting principles generally periods. Actual results could differ from those estimates. date of the financial statements and the reported amounts of revenues and expenses during the reporting affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the accepted in the United States of America requires management to make estimates and assumptions that

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# **NOTE 1 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** (continued)

Revenue Recognition: The Company has identified commissions and trailer fees as its most significant revenue streams.

basis. fund holdings period. The receivable associated to accrued trailer fees is generally settled on a quarterly Trailer fees are estimated based on an agreed upon distribution rate with each fund family over the average

Financial Instruments with Off-Balance-Sheet Risk: In the normal course of its business and under standard customers are unable to fulfill contractual obligations under margin accounts. transactions. The Company is, therefore, exposed to off-balance-sheet risk of loss in the event that the Company has agreed to indemnify its clearing firms from damages or losses resulting from customer contract terms included in the correspondent agreements with Pershing LLC and Apex, its clearing firms,

2024. under this indemnification provision. Unsettled customer trades amounted to \$26,519 at December 31, its financial statements. Since its inception, the Company has not been required to make any payment under customary margin requirements. As a result, the Company did not record any contingent liability in At December 31, 2024, there were no margin accounts that were not fully secured by marketable securities

Fair Value of Financial Instruments: The carrying amount of the Company's financial instruments in note 3. instruments are estimated using relevant market information and other assumptions, as more fully disclosed approximate their fair value because of the short maturity of the instruments. Fair values of financial

repurchase them before their maturity. Company does not maintain effective control over the transferred assets through an agreement to constrain it from taking advantage of that right) to pledge or exchange the transferred assets, and the assets have been isolated from the Company, the transferee obtains the right (free of conditions that the assets has been relinquished. Control over transferred assets is deemed to be surrendered when the Transfers of Financial Assets: Transfers of financial assets are accounted for as sales, when control over

Loss Contingencies: Loss contingencies, including claims and legal actions arising in the ordinary course effect on the financial statements. loss can be reasonably estimated. Management does not believe that such matters will have a material of business, are recorded as liabilities when the likelihood of loss is probable, and an amount or range of

to be realized. enacted tax rates. A valuation allowance, if needed, reduces deferred tax assets to the amount expected temporary differences between carrying amounts and tax bases of assets and liabilities, computed using assets and liabilities. Deferred tax assets and liabilities are the expected future tax amounts for the (benefit) is the total of current year income tax due or refundable (if any), and the change in deferred tax proportion to their contribution to the consolidated U.S. and State taxable income. Income tax expense method of allocating the U.S. and State consolidated tax liability among the participants generally in Parent Company and its subsidiaries. The consolidated group of the Parent Company follows the pro rata Income Taxes: The Company is included in the consolidated federal and state income tax return of its

unrecognized tax positions at December 31, 2024. positions not meeting the "more likely than not" test, no tax benefit is recorded. There were no material is the largest amount of tax benefit that is greater than 50% likely of being realized on examination. For tax sustained in a tax examination, with a tax examination being presumed to occur. The amount recognized A tax position is recognized as a benefit only if it is "more likely than not" that the tax position would be

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# **NOTE 1 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** (continued)

Company is not subject to examination by taxing authorities for years prior to 2021. The Company is subject to U.S. federal income tax as well as income tax of the state of Florida. The

Leases: Leases are classified as operating or finance leases at the lease commencement date. Lease the date of adoption. of remaining minimum lease payments, discounted using the Company's incremental borrowing rate as of value of lease payments over the lease term. These amounts are determined based on the present value assets and lease liabilities are recognized at the lease commencement date based on the estimated present liabilities represent the Company's obligation to make lease payments arising from the lease. Right-of-use term. Right-of-use assets represent our right to use an underlying asset for the lease term and lease expense for operating leases and short-term leases are recognized on a straight-line basis over the lease

## **NOTE 2 - FULLY DISCLOSED CLEARING AGREEMENT**

respectively, to satisfy this requirement. the Company had cash on deposit, amounting to \$500,000 and \$125,000 at Pershing and Apex, a minimum deposit balance in an account maintained by Pershing, LLC and Apex. At December 31, 2024, accounts are cleared and carried by these clearing firms. The agreements call for the Company to maintain The Company has fully disclosed clearing agreements with Pershing LLC and Apex whereby customer

180 days written notice. Either party, Pershing or the Company, may terminate the agreement without cause upon the receipt of

upon 90 days written notice or (ii) at any time without cause upon 180 days written notice. its agreement with the Company without cause (i) at or prior to the end of two years from the Live Date seeks to increase its fees, the Company objects and elects to terminate the agreement. Apex may terminate terminate its agreement with Apex at any time on 30 days written notice to Apex in the event that Apex period following the initial two-year period upon 30 days written notice. Additionally, the Company may Live Date (as defined in the agreement) upon 90 days written notice or (ii) during any automatic renewal The Company may terminate its agreement with Apex without cause (i) at the end of two years from the

condition. These deposits are included in the balance of deposits with clearing firm in the statement of financial

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### **NOTE 3 - FAIR VALUE**

fair values: market participants on the measurement date. There are three levels of inputs that may be used to measure in the principal or most advantageous market for the asset or liability in an orderly transaction between Fair value is the exchange price that would be received for an asset or paid to transfer a liability (exit price)

has the ability to access as of the measurement date. Level 1: Quoted prices (unadjusted) for identical assets or liabilities in active markets that the entity

observable or can be corroborated by observable market data. similar assets or liabilities; quoted prices in markets that are not active; or other inputs that are Level 2: Significant other observable inputs other than Level 1 prices such as quoted prices for

assumptions that market participants would use in pricing an asset or liability. Level 3: Significant unobservable inputs that reflect a reporting entity's own assumptions about the

prices and are cash. amounting to \$13,152,095 at December 31, 2024 are not considered Level 1 as they do not have quoted fair value because of their short maturity. Cash and due from banks and deposits with clearing firms The carrying amounts of financial assets in the statement of financial condition approximate their estimated

### **NOTE 4 - INCOME TAXES**

As of December 31, 2024, the Company had a deferred tax asset as follow:

| Deferred tax asset | Other, net | Depreciation Expense | Deferred Compensation |
|--------------------|------------|----------------------|-----------------------|
| \$                 |            |                      | \$                    |
| 400,057            | 6,149      | 38,277               | 355,631               |

No valuation allowance was considered necessary at December 31, 2024.

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### **NOTE 5 - RELATED PARTIES**

at and for the year ended December 31, 2024: Balances with related parties included in the Statement of financial condition and Statement of operations

|           | Due to affiliates | Accounts payable and accrued expenses | Liabilities |         | Deferred tax asset | Due from affiliates | Cash and due from banks | Assets |
|-----------|-------------------|---------------------------------------|-------------|---------|--------------------|---------------------|-------------------------|--------|
| \$        |                   | \$                                    |             | \$      |                    |                     | \$                      |        |
| 1,792,696 | 1,106,000         | 686,<br>697                           |             | 909,851 | 400,057            | 53,462              | 456,<br>332             |        |

Cash and due from banks represents cash maintained in a demand deposit account with the Parent.

the Company from Its Parent Company or affiliates for such services per these service agreements. Company owes its Parent Company and/or affiliates and due from affiliates represents amounts owed to based on the benefit provided to each of the affiliates involved. Due to affiliates represents amounts the costs such as salaries and benefits, and occupancy. Changes in the allocation of service fees were made pays fees or receives allocation reimbursements from its Parent Company and/or affiliates, which cover that may exist if the Company operated as a stand-alone entity. In exchange for services, the Company Company is a wholly owned subsidiary of its Parent Company and operating results may differ from those The Company has entered into reciprocal service agreements with its Parent Company and affiliates. The

the consolidated tax return and tax overpayment which the Company is entitled to. Deferred tax asset consists primarily of balances related to tax benefits used by the Parent Company on

# **NOTE 6 – RESERVE AND POSSESSION OR CONTROL REQUIREMENTS**

January 1, 2024 to December 31, 2024 without exception. "the exemption provisions" and met the exemption provisions throughout the most recent fiscal year The Company claims an exemption from 17 C.F.R.240.15c3-3(k) under Rule 15c3-3, paragraph (k)(2)(ii)

## **NOTE 7 - NET CAPITAL REQUIREMENTS**

\$252,598. The Company's aggregate indebtedness to net capital ratio was .40 to 1 at December 31, 2024. 15c3-1(a)(2)(iii) totaled \$9,379,347 which was \$9,126,749 in excess of its net capital requirement of net capital requirement for 2024. At December 31, 2024, the Company's net capital as defined by SEA Rule indebtedness to net capital, both as defined, shall not exceed 15 to 1. The Company was above its minimum 15c3-1), which requires the maintenance of minimum net capital and requires that the ratio of aggregate The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC rule

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### **NOTE 8 - LEASES**

commencement date of the lease. the lease up to 10 years and an option to terminate the lease within 7 years from the contract Company's lease has a remaining term of approximately 11 years, which includes renewal option to extend The Company enters into leases in the normal course of business primarily for its operating premises. The

the least term. recognized at the lease commencement date based on the estimated present value of lease payment over our obligation to make lease payments arising from the lease. Right-of-use assets and lease liabilities are use assets represent our right to use an underlying asset for the lease term and lease liabilities represent operating leases and short-term leases is recognized on a straight-line basis over the lease term. Right-of-Leases are classified as operating or finance leases at the lease commencement date. Lease expense for

term and other factors. borrowing rate is based on the Federal Home Loan Bank advance offering rates, adjusted for the lease value of lease payments when the rate implicit in a lease is not known. The Company's incremental The Company uses its incremental borrowing rate at lease commencement date to calculate the present

classifications, are as follows: Right-of-use assets and lease liabilities by lease type, and the associated statement of financial condition

| Total lease liabilities | Operating leases<br>Lease liabilities: | Total right-of use assets | Operating leases<br>Right-of-use assets: |                   |
|-------------------------|----------------------------------------|---------------------------|------------------------------------------|-------------------|
| 808,129                 | 808,129                                | 784,091                   | 784,091                                  | December 31, 2024 |

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### **NOTE 8 – LEASES** (continued)

Lease Obligations

December 31, 2024 are as follows: Future undiscounted lease payments for operating leases with initial terms of one year or more as of

|                                   | Operating Leases |
|-----------------------------------|------------------|
| 2025                              | 85,472           |
| 2026                              | 88,038           |
| 2027                              | 90,680           |
| 2028                              | 93,397           |
| Thereafter                        | 698,488          |
| Total undiscounted lease payments | 1,056,075        |
| Less: imputed interest            | (247,946)        |
| Net lease liabilities             | 808,129          |
|                                   |                  |

Supplemental Lease Information

| Operating lease weighted average discount rate | Operating lease weighted average remaining lease term (years) |
|------------------------------------------------|---------------------------------------------------------------|
| 4.95%                                          | 10.7                                                          |

## **NOTE – SUBSEQUENT EVENTS**

identified. the date the financial statements were available for issuance. No material subsequent events were The Company has evaluated subsequent events for recognition and disclosure through March 14, 2025,


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