# GULFSTAR GROUP I, LTD. X-17A-5 (2025-04-02) — Broker-dealer annual report - Company: GULFSTAR GROUP I, LTD. - Form: X-17A-5 - Filed: 2025-04-02 - Period: 2024-12-31 - Accession: 0000877810-25-000001 - CIK: 877810 - File #: 8-43999 - Type: Broker-dealer - Material weakness: No - Auditor: EEPB - Auditor location: Houston, TX - Contact: Alicia Neal - Phone: 713-300-2002 - Email: aneal@gulfstargroup.cm - Website: gulfstargroup.cm - Signed by: F.W. Luedde, III (President) Original filing: https://www.sec.gov/Archives/edgar/data/877810/000087781025000001/2024auditgulfstargroup-.pdf --- {0}------------------------------------------------ | UNITED STATES | | | | | | |------------------------------------|--|--|--|--|--| | SECURITIES AND EXCHANGE COMMISSION | | | | | | | Washington, D.C. 20S49 | | | | | | | OMB APPROVAL | | |---------------------------|--| | OMB Number:
3235-0123 | | | Expires: NOV. 30, 2026 | | | Estimated average burden | | | hours per response:
12 | | # **ANNUAL REPORTS FORM X-17A-5 PART III** **SEC FILE NUMBER** ### **FACING PAGE** | Information Required Pursuant to Rules 17a-S,17a-12,and 18a-7 under the Securities Exchange Act of 1934 | | | | | | | | |----------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------|--------------------------------------------------|-------------------------------------------|--|--|--|--| | FILING FOR THE PERIOD BEGINNING | 12/31/2024
01/01/2024
AND ENDING | | | | | | | | | MM/DD/YY | | MM/DD/YY | | | | | | REGISTRANT IDENTIFICATION
A. | | | | | | | | | GulfStar
Group
NAME OF FIRM: | Ltd
I, | | | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
EBroker-dealer
Check here if respondent is also an 0TC derivatives dealer | Security-based swap dealer | Major security-based swap participant | | | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS:(Do not use a P.O. box no.) | | | | | | | | | Street,
Louisiana
Ste
3800
700 | | | | | | | | | (No. andStreet) | | | | | | | | | Houston | TX | | | | | | | | (City) | (State) | | (2ip Code) | | | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | | | Alicia | Neal | aneal@gulfstargroup.cm | | | | | | | (Name) | | (Email Address)
(Area Code -Telephone Number) | | | | | | | B. | ACCOUNTANT IDENTIFICATION | | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | | | | | | | | EEPB | | | | | | | | | North
West
Loop
2950 | (Name-if Individual,state last,first,and middle name)
Houston | TX | 77092 | | | | | | (Address) | (City) | (State) | (Zip Code) | | | | | | ilk
/M23 | | 879 | | | | | | | (Date of Rejjlstratlnn
with PCAOB)(if appjlcable) | | | (PCAOB Registration Number,If applicable) | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | \* Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(l)(ii),if applicable, **Persons who are to respond to thecollection of Information contaIned in** this **form are notrequired to respond unless the form, displays a currently valid OMB controlnumber.** {1}------------------------------------------------ ## OATH OR AFFIRMATION I, F.W.Luedde.ill *.* swear {or affirm) that,to the best of my knowledge and belief,the financial report pertaining to the firm of fidSar Group!,Ltd. . ,as of *IS I\$ y* ,2024 .is true and correct. Ifurther swear (or affirm) that neither the company nor any partnerfofficer,director,or equivalent person,as the case may be,has any proprietary interest in any account classified solely as that of a customer. Aliqla O Neal My Commission Expires 5/5/2027 NotaryK&gt; 125792481 \* < -f' *y* Notary^Public" *i* t | Signature^
^ | | |-----------------|--| | Title: | | | President | | #### This filing\*\*contains (check all applicable boxes): - M(a) Statement of financial condition. - (b) Notes to consolidated statement of financial condition. - &lt;J (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). - S (d) Statement of cash flows. - £ (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. (f) Statement of changes in liabilities subordinated to claims of creditors, - «(g) Notes to consolidated financial statements. - 5»(h) Computation of net capital under 17 CFR 240.15c3-lor 17 CFR 240.l8a-l,as applicable. - (i) Computation of tangible net worth under 17 CFR 240.18a-2. - *St* (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - (k) Computation for determination of security-based swap reserve requirements pursuant toExhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4,as applicable. - (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3. - £ (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18aA as applicable. - (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 under 17 CFR 240,lSc3-3 or 17 CFR 240.18a-4, as applicable,if material differences exist,or a statement that no material differences exist. - (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - 3 (q) Oath or affirmation in accordance with 17 CFR 240.17a-5,17 CFR 240.17a-12,or 17 CFR 240.18a-7, as applicable. - (r) Compliance report in accordance with17 CFR 240.17a-5 or17 CFR 240.18a-7,as applicable. - *m* (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7,as applicable. t) Independent public accountant's report based on an examination of the statement of financial condition. - *WF* (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5,17 CFR 240.18a-7,or 17 CFR 240.17a-12,as applicable. - (v) independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7,as applicable. - B (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. - (x) Supplemental reportson applying agreed-upon procedures,in accordance with 17 CFR 240.15c3-leor 17 CFR 240.17a-12, as applicable. - (y) Report describing any material inadequacies found to exist or foundto have existed since the date of theprevious audit,or a statement that no material inadequacies exist,under 17 CFR 240.17a-12|k). - (z) Other: - *\*\* To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18o-7(d)(2), as applicable.* {2}------------------------------------------------ GULFSTAR GROUP I, LTD. FINANCIAL STATEMENTS DECEMBER 31, 2024 *t* {3}------------------------------------------------ # C O N T E N T S **Pages** | Report of Independent Registered Public Accounting Firm.
2 | |-----------------------------------------------------------------------------------| | Statement of Financial Condition
3 | | 4
Statement of Income | | 5
Statement of Changes in Partners'Capital | | 6
Statement of Cash Flows, | | 7 -9
Notes to Financial Statements | | 10
Schedule I, | | 11
Schedule n | | Report of Independent Registered Public Accounting Firm - Exemption Review,
12 | | 13
Exemption Report | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) ## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Partners of Gulfstar GroupI,Ltd. # **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Gulfstar Group I, Ltd. as of December 31, 2024,the related statements of income, changes in partners' capital, and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the "financial statements"). In our opinion,the financial statements present fairly, in all material respects, the financial position of Gulfstar Group I, Ltd. as of December 31, 2024, 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 Gulfstar Group 1, Ltd.'s management. Our responsibility Is to express an opinion on Gulfstar Group I, Ltd.'s financial statements 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 with respect to Gulfstar Group I, Ltd.in accordance with the U.S.federal securities laws and the applicable rules and regulations of the SecuritiesandExchange 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, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error of 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. ## **Auditor's Report on Supplemental Information** The Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission, and The Information Relating to Possession or Control Requirements Under Rule 15c3-3 (collectively the •supplemental Information") has been subjected to audit procedures performed in conjunction with the audit of Gulfstar Group I, Ltd.' s financial statements. The supplemental information is the responsibility of Gulfstar Group I, Ltd.'s management. Our audit procedures included determining whether the supplemental information 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 supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental Information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as Gulfstar GroupI, Ltd.'s auditor since 2D23. Houston, TX March 27, 2025 > 2950 North Loop West, Suite1200 [ Houston, TX 720921(p) 713.622.0010 [ (f) 713.622.5527 |wv/w.eepb.com An **Independent** Member bf **OPIC** International {5}------------------------------------------------ # STATEMENT OF FINANCIAL CCmSITION **DECEMBHl 31, 2024** # **ASSETS** | Cash and cash equivalents
Accounts receivable, affiliate
Notes receivable, affiliate | \$
596,338
246,711
502,800 | |--------------------------------------------------------------------------------------------|-------------------------------------| | TOTAL ASSETS | \$
1,345,849 | | LIABILITIES AND PARTNERS' CAPITAL | | | Accrued margin tax | \$
53,260 | | TOTAL UABILmES | 53,260 | | Partners' capital | 1,292,589 | | TOTAL UABILmES AND PARTNERS' CAPITAL | \$
1,345,849 | See accompanying notes. {6}------------------------------------------------ # GLUF5TAR GROUP I, LTD. STATEMENT OF INCOME TOR THE YEAR ENDED DECEMBER 31, 2024 | Revenues | | |----------------------------------|-----------------| | Management fee income, affiliate | \$
1,020,000 | | Commissions | 10,128,816 | | Total Revenues | 11,148,816 | | Expenses | | | Management fees | 1,380,000 | | Managing directors fees | 4,043,936 | | Referral fees | 44,206 | | Payroll taxes | 45,113 | | Professional fees | 84,153 | | Licenses and registrations | 33,282 | | Margin tax | 53,260 | | Other | 540 | | Total Expenses | 5,684,490 | | Income
Net | \$
5,464>326 | {7}------------------------------------------------ ### **GLLPSTAR GROUPI,LTD, STATEMENT OF CHANGES INPARTNERS' CAPITAL FOR THE YEAR EM3ED DECEMBER 31, 2024** | | General
Partner | Limited
Partners | Total | |---------------------------|--------------------|---------------------|-----------------| | Balance,December 31,2023 | 84,375
\$ | \$
1,243,888 | 1,328,263
\$ | | Distributions | (550) | (5,499,450) | (5,500,000) | | Net Income | 546 | 5,463,780 | 5,464,326 | | Balance, December 31,2024 | 84,371
\$ | 1,208,218
\$ | \$
1,292,589 | See accompanying notes. {8}------------------------------------------------ # **GULF5TAR GROUP** *1,***LTD. STATEMENT OFCASH FLOWS FOR THEYEAR ENDED DECPflBER 31, 2024** | CASH FLOW FROM OPERATING ACTIVITIES | | |-----------------------------------------------|-----------------| | Net Income | \$
5,464,326 | | Adjustmentsto reconcile NetIncome | | | to net cash provided by Operating Activities: | | | Increase in Accounts Receivable, affiliate | (179,984) | | Decrease in Accounts Payable, affiliate | (230,000) | | Decrease in Accrued Margin Tax | (22,147) | | Net cash provided by Operating Activities | 5,032,195 | | CASH FLOW FROM FINANCING ACTIVITIES | | | Distributions to Partners | (5,500,000) | | Net cash used In Financing Activities | (5,500,000) | | Net cash decrease for period | (467,805) | | Cash at beginning of period | lv064.143 | | Cash at end of period | \$
596,338 | See accompanying notes. {9}------------------------------------------------ ## **GULFSTAR GROUPI, LTD. NOTESTO FINANCIAL STATEMENTS DECEMBER 31, 2024** ### **NOTEA BASIS OF PRESENTATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** **GulfStar GroupI, Ltd.(aTexas limited partnership) (the Partnership)maintains its accounts on the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America (GAAP). Accounting principles followed by the Partnership and the methods of applying those principles which materially affect the determination of financial position,results of operations and cash flows are summarized below:** **Description of Business - The Partnership is located In Houston, Texas and is a private investment banking firm. Accordingly, the Company Is considered a Non-Covered Firm exempt from 17 C.F.R. § 240.15c3-3 relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5. The Company limits Its business activities exclusively to receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients. The Partnership is registered as a Broker-Dealer with the Securities and Exchange Commission and Is a member of the Financial Industry Regulation Authority (FINRA).** **Statement Presentation - The unclassified statement of financial condition Is presented in accordance with industry standards.** **Estimates - The preparation of the financial statements requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.** **Cash and Cash Equivalents - The Partnership considers ail highly liquid debt Instruments with an original maturity of three months or less to be cash equivalents.** **IncomeJax§s - The Partnership's income,losses,and tax credits will be inducted in the Income tax returns of the Partners. Accordingly, the Partnership does not record a provision for Federal income taxes. The Partnership accrues Texas Margin taxes if owed. For the year ended December 31, 2024, the partnership accrued Margin tax expense of \$53,260.** **The Partnership believes that all tax positions will more likely than not be sustained upon examination, As of December 31, 2024, the tax years that remain subject to examination by the major tax jurisdictions under the statute of limitations are from the year 2021forward (with limited exceptions). Tax penalties and Interest, If any, would be accrued as incurred and would be classified as tax expense in the statement of Income.** **Revenue Recognition - Revenue from contracts with customers indudes fees from Investment banking services. The recognition and measurement of revenue Is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point In time or overrime;how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Partnership's progress under the contract;and whether constraints on variable consideration should be applied due to uncertain future events.** {10}------------------------------------------------ ## **GULFSTAR GROUPI,LTD. NOTESTO FINANCIAL STATEMENTS DECEMBER 31, 2024** #### **BASIS OF PRESENTATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued) NOTEA** **Management fee income Is recorded in accordance with the terms of the respective contract when the service is complete, and the revenue Is reasonably determinable. Investment banking fees from securities related transactions are recognized when transactions close and receivables are recorded at that time.** **Subsequent Events - The Partnership has evaluated subsequent events through March XX, 2025, the date the financial statements were available to be issued. No subsequent events other than the item noted in Note F occurred, which required adjustment or disclosure to the financial statements at December 31, 2024.** ### **NOTE B ORGANIZATION** **The Partnership's general partner is GulfStar Group GP, LLC, owning a 0.01% interest.Through December 31, 2007, GulfStar Investment of Nevada Inc. (Nevada) and IBC Subsidiary Corporation (IBC) owned 29.997% and 69.993% in limited partnership interests,respectively. Effective January 1, 2008, the limited partnership interest was reallocated between Nevada and IBC to 49,995% and 49.995%, each. The Partnership can remain in existence until December 31, 2050.** **All Partnership profits,losses,and distributions are to be allocated to the partners In proportion to their respective percentage Interests.** #### **NOTEC RELATED PARTY TRANSACTIONS** **The Partnership utilizes the services of GulfStar II, Ltd. (GulfStar II) (a company affiliated by ownership) for the day-to-day operation and management of the Partnership's business, including financial services management, information systems, bookkeeping, recordkeeping, clerical services, furnishing office space,equipment, and supplies; assisting in compliance with all reporting and administrative obligations of the Partnership; assisting in preparation and updating of a business plan, preparation of budgets, providing marketing and sales support, obtaining research, analysis, and informational services; and arranging for monitoring of legal, accounting, and other professional services. Ascompensation for these services the Partnership paid GulfStar II management fees of \$115,000 per month for the year of 2024. The management fees are payable monthly in advance or at such other times as the parties may mutually agree. At December 31, 2024 there were no amount due to GulfStar II related to management fees. Total fees paid by the Partnership pursuant to the agreement were \$1,380,000 for the year ended December 31, 2024.** **At December 31, 2024, the Partnership had no prepaid management fees. In addition to management fees pursuant to the agreement, the Partnership also pays fees to managing directors based on a tiered percentage of the Partnership's success fee earned from closing a financing transaction. Managing Directors fees totaled \$4,043,936 for the year ended December 31, 2024. Effective January 2, 2009, GulfStar II agreed to pay the Partnership a management fee for professional services on a monthly basis.Total management fees received by the Partnership were \$1,020,000 for the year ended December 31, 2024. The Accounts Receivable, affiliate balance was \$246,711for the year ended December 31, 2024.** {11}------------------------------------------------ #### **NOTE D** NET CAPITAL REQUIREMENTS Pursuant to the net capital provisions of Rule 15c3-lof the Securities Exchange Act of 1934, the Partnership Is required to maintain a minimum net capital and comply with a ratio of aggregate indebtedness to net capita! as defined under such provisions. Net capital and the related ratio of aggregate indebtedness to net capital may fluctuate on a daily basis. At December 31, 2024 the Partnership had net capital of \$466,905 and a net capital requirement of \$5,000. The Partnership's ratio of aggregate indebtedness to net capital was .11 to 1at December 31, 2024. The Securities and Exchange Commission permits a ratio of aggregate Indebtedness to net capital for the Partnership at this time of no greater than 15 to **1.** #### NOTEE CONCENTRATIONS AND CREDIT RISK The Partnership has cash deposits in correspondent financial Institutions in excess of the amount insured by the FDIC In the amount of \$285,165 at December 31, 2024.It Is the Partnership's practice to utilize high net worth financial institutions to minimize credit risk. Additionally,the Partnership has credit risk related to the note receivable from GulfStarII. The Partnership's management does not believe significant credit risk exists In relation to this receivable and that no reserves are required. #### NOTES RECEIVABLE,AFFILIATE NOTEF The Partnership created Intercompany receivables for cash advances with Its affiliate GulfStar II on February 26, 2009 and October 1, 2011 in the amounts of \$270,000 and \$107,100, respectively. These Interest free notes were renewed and will mature on February 23, 2025 and October1,2025,respectively. On February 27,2012,the Partnership created an additional intercompany note receivable with its affiliate GulfStar IIIn the amount of \$125,700. This interest free note was renewed during 2024 and will mature on February 27, 2025. #### NOTEG SEGMENT REPORTING The Company adopted Accounting Standards Codification, ASC 280, *Segment Reporting* In 2024. The Company is engaged in a single line of business as a securities broker -dealer,which is comprised of [mergers and acquisitions].The Company has identified Its CEO as the chief operating decisions maker ( "CODM"), who uses net income to evaluate the results of the business,predominantly in the forecasting process,to manage the Company. Additionally,the CODM uses excess net capital,which Is not a measure of profit and loss,to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or to pay distributions. The Company' s operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. {12}------------------------------------------------ ### **GULF5TAR GROUP 1, LID. SCHEDULEI COMPUTATION OFNET CAPITAL LITOER RULE 15C3-1 OFTHE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31, 2024** | NET CAPITAL | | | |-------------------------------------------------------------------------------------------------------|----|-----------| | Total partners'
capital qualified for net capital | \$ | 1,292,589 | | Nonallowable assets: | | | | Cash and cash equivalents | | (61,173) | | Accounts receivable,affiliate | | (246,711) | | Notes receivable,affiliate | | (502,800) | | Total nonallowable assets | | (810,684) | | Excess Fidelity Bond Deductible | | (15,000) | | | | (825,684) | | Net capital | 1 | 466,905 | | COMPUTATIONOF BASIC NET CAPITAL REQUIREMENTS
Minimum net capital required (6.66%of total aggregate | | | | indebtedness) | A | 5,000 | | Minimum dollar net capital requirement | | 5,000 | | Net capital requirement(greater of above two minimum | | | | requirement amounts) | A | 5,000 | | Excess net capital | \$ | 461,905 | | Ratio:Aggregate indebtedness to net capital | | .11 to 1 | | | | | No material differences existed between the audited computation of net capital pursuant toRule 15c3- 1as of December 31, 2024 and the corresponding unaudited filing of part IIA of the FOCUS Report form X 17A-5 filed by GulfStar GroupI,Ltd. {13}------------------------------------------------ # Schedule II ### GULFSTAR GROUP I, LTD # Information Relating to the Possession or Control Requirements under Rule 15c3-3 #### December 31, 2024 #### Exemption Provision The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3. 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 receiving transactionbased compensation for identifying potential merger and acquisition opportunities for clients, and the Company, (1) drd not directly or Indirectly receive, hold, or otherwise owe funds or securities for or to customers; (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. See report of independent public accounting firm. {14}------------------------------------------------ ![](_page_14_Picture_0.jpeg) ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Partners of Gulfstar Group I, Ltd We have reviewed management's statements, Included In the accompanying Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, In which (1) Gulfstar Group I, Ltd (the "Compan/) 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 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) receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients. In addition, the Company 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; did not carry accounts of or for customers;and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. Gulfstar Group I, Ltd's management is responsible for compliance with the provisions contemplated by Footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 and related SEC Staff Frequently Asked Questions 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 Gulfstar Group I, Ltd.'s compliance with the exemption provision. 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 upon the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240,17a-5,and related SEC Staff Frequently Asked Questions. ESP'S- EEPB Houston, TX March 27, 2025 {15}------------------------------------------------ # **Gulfstar Group I, LTD.** 700 Lousiana Street, Suite 3800 / Houston,Texas77002 713-300-2010 # Exemption Report Gulfstar Group I, LTD. (the "Partnership") 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)(l) 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) receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients, and the Company,(1) did not directly or indirectly receive, hold, or otherwise owe funds orsecurities for or to customers;(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 recentfiscal year without exception. # Gulfstar Group I, LTD. I,F.W. Luedde, IQ,swear (or affirm)that, to my best knowledge and belief,thisExemptionReport is true and correct F.W. Luedde,III, President and Chief Compliance Officer March 13, 2025 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.