# PTI SECURITIES & FUTURES L.P. X-17A-5 (2022-02-28) — Broker-dealer annual report

- Company: PTI SECURITIES & FUTURES L.P.
- Form: X-17A-5
- Filed: 2022-02-28
- Period: 2021-12-31
- Accession: 0000882308-22-000002
- CIK: 882308
- File #: 8-44412
- Type: Broker-dealer
- Material weakness: No
- Auditor: Ryan & Juraska
- Auditor location: Chicago, IL
- Contact: Daniel J Haugh
- Phone: 3126633052
- Email: dan@ptisecurities.com
- Website: ptisecurities.com
- Signed by: Daniel J. Haugh (President)

Original filing: https://www.sec.gov/Archives/edgar/data/882308/000088230822000002/pticonfidential.pdf

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#### FINANCIAL STATEMENTS AND SUPPLEMENTAL SCHEDULES PURSUANT TO SEC RULE 17a-5(d) AND REGULATION 1.10 UNDER THE COMMODITY EXCHANGE ACT

December 31, 2021 CONFIDENTIAL

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lnformation Required Pursuant to Rules L7a-5, L7a-L2, and 18a-7 under the Securities Exchange Act of 1934 FTLTNG FoR rHE pERroD BEGTNNTNG 01101121 AND ENDTNG <sup>12131121</sup> UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 ANNUAL REPORTS FORM X-17A-5 PART III FACING PAGE OMB APPROVAL OMB Number: 3235-0123 Expires: Oct. 3L,2023 Estimated average burden hours per response: <sup>12</sup> SEC FILE NUMBER 8-44412 M M/DD/YY MM/DD/YY A. REGISTRANT IDENTI FICATION NAMEoFFTRM: PTI Securities & Futures L.P. and Subsidiary TYPE OF REGISTRANT (check all applicable boxes): E Broker-dealer n Security-based swap dealer E Vtajor security-based swap participant E Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) 41 1 South Wells Street Suite 900 60607 (city) (state) r (Zip code) PERSON TO CONTACT WITH REGARD TO THIS FILING Daniel J. Haugh 312-663-3052 dan@ptisecurities.com (Name) (Area Code - Telephone Number) (Email Address) Chicago (No.and Street) IL B. ACCOUNTANT IDENTI FICATION INDEPENDENT PUBLIC ACCOUNTANT whose reports ard contained in this filing\* Ryan & Juraska LLP - Certified Public Accountants (Name - if individual, state last, first, and middle name) <sup>141</sup>\Nest Jackson Chicago lL <sup>60604</sup> (Add ress) 312412009 (City) (state) (Zip code) 3407 (Date of Registration with PCAOB)(if applicable) (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

accountantmustbesupportedbyastatementoffactsandcircumstancesreliedonasthebasisoftheexemption. See17 CFR 240.17a-5(e}(lXii), if applicable.

Persons 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

l, Daiel J Haugh

, swear (or affirm) that, to the best of my knowledge and belief, the report pertaining to the firm of PTI Securities & Futures L.P. and Subsidiary as of

> NOTARY PUBLIC . STATE OF ILLINOIS MY COMMISSTON EXP|RES :O4BOnz

financial 12t31t2021 2\_, is true and correct. I further swear (or affirm) that neither the company nor any partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer.

Sign atu re: Title: OFFICIAL SEAL GREGG M RZEPCANSKI

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

- E (a) Statement of financial condition.
- tl (b) Notes to consolidated statement of financial condition.
- = (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 5 210.1-02 of Regulation S-X).
- (d) Statement of cash flows.
- = E (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- E (f) Statement of changes in liabilities subordinated to claims of creditors.
- E (g) Notes to consolidated financial stitements,
- (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.\8a-L, as applicable.
- = D (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- E [) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- tr (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.t8a-4, as applicable.
- tr (l) Computation for Determination of PAB Requirements under Exhibit A to 5 240.15c3-3,
- E (m) lnformation relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- tr (n) lnformation relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(21 or !7 CFR 240.18a-4, as applicable.
- = (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under t7 CFR 241.t5c3-t, !7 CFR 240.18a-1, or !7 CFR 240.!8a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3 -3 or t7 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- tr (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- E (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 24O.t7a-!2, or 17 CFR 240.!8a-7, as applicable,
- n (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 24Q.!8a-7, as applicable.
- E (s) Exemption report in accordance with 17 CFR24O.77a-5 or t7 CFR 240.18a-7, as applicable.
- n (t) lndependent public accountant's report based on an examination of the statement of financial condition.
- = (u) lndependdnt public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 24o.l8a-7, or 17 CFR 240.17a-12, as applicable,
- tr (v) lndependent public accountant's report based on an examination of certain statements in the compliance report under <sup>17</sup> CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- = (w) lndependent public accou nta nt's report based on a review of the exemption report u nder 17 CFR 240.t7a-5 or t7 CFR 240.18a-7, as applicable.
- tr (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-7e or !7 CFR24O.17a-12, as applicable.
- tl (y) Report describing a ny material inadeq uacies fou nd to exist or found to have existed since the date of the previous a udit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-t?lk).
- = (z) Other: lndependent Auditors Report on lNternal Control
- \*\*To request confidentiol treotment of certoin portions of this filing, see 77 CFR 240.17a-5(e)(3) or 77 CFR 240.18o-7(d)(2), as opplicoble.

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![](_page_3_Picture_0.jpeg)

RYAIV &JURASKA LLP Certifiecl Publ ic Accountants

141 West lacl<son Boulevard Chicago, Illinois 60604

Tel: 312..922.0062 Fax: 312.922.0672

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Partners of PTI Securities & Futures L.P. and Subsidiary

#### Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of PTI Securities & Futures L.P. and Subsidiary (the Company) as of December 31,2021, the related statements of operations, changes in partners' capital, changes in liabilities subordinated to claims of general creditors, and cash flows for the year then ended that you are filing pursuant to Rule 17a-5 under the Securities Exchange Act of 1934 and Regulation 1.10 under the Commodity Exchange Act (CEAct), and the related notes and supplemental schedules (collectively referred to as the financial statements). ln our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31,2021, and ihe 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 firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Cqmpany. 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 have served as the Company's auditor since '1999.

We conducted iur 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. 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 purpbse 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 of 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.

#### Auditor's Report on Supplemental lnformation

The Supplemental Schedules (the "supplemental information") have been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company'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. ln forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformitywith 17 C.F.R. \$240.17a-5 and pursuant to Regulation 1.10 under the CEAct. ln our opinion, the Supplemental Schedules are fairly stated, in all material respects, in relation to the financial statements as a whole.

fifr\*t ru"r4/4 /L/

Chicago, Illinois Februa ry 21 , 2022

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#### Statement of Financial Condition

#### December 31, 2021

#### Assets

| Cash<br>Receivable from broker-dealers<br>Commissions receivable<br>Receivable from affiliates | 111 ,445<br>100,000<br>12,734<br>1 1,033 |
|------------------------------------------------------------------------------------------------|------------------------------------------|
|                                                                                                | \$<br>np2n                               |
| Liabilities and Partners' Capital                                                              |                                          |
| Liabilities                                                                                    |                                          |
| Accounts payable and accrued expenses                                                          | 141,91 I                                 |
| Deferred revenue<br>Subordinated Loan                                                          | 43,856<br>125,000                        |
|                                                                                                | 310,??5                                  |
|                                                                                                |                                          |
| Partners' capital<br>General partner                                                           |                                          |
| Limited partners                                                                               | (33 ,129)<br>(42,434)<br>_               |
|                                                                                                | (75,563)                                 |
|                                                                                                | 235212                                   |

=

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#### Statement of Operations

#### Year Ended December 31, 2021

| Revenues<br>Commissions<br>Retention Bonus<br>I nvestment Advisor Fees<br>Other lncome<br>lnterest                                                                                                                |  | 281 ,411<br>22,848<br>21 ,042<br>41 ,000<br>2,111<br>368 ,412                                      |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|----------------------------------------------------------------------------------------------------|
| Expenses<br>Employee compensation and benefits<br>Commissions<br>Marketing<br>Occupancy<br>Communications and quotations<br>Professional fees,<br>Regulatory fees<br>Subordinated Loan lnterest<br>Other expenses |  | 103 ,422<br>83,740<br>2,400<br>32,749<br>27,441<br>25,000<br>22,514<br>7,500<br>7,01 I<br>311 ,785 |
| Net lncome                                                                                                                                                                                                        |  | 56,627                                                                                             |

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#### Statement of Changes in Partners' Capital

#### Year Ended December 31, 2021

|                                             | General<br>Partner          | Limited<br>Partners  | Total               |
|---------------------------------------------|-----------------------------|----------------------|---------------------|
| Balance, January 1,2021<br>Capital Addition | \$<br>(66,896) \$<br>18,000 | (87,294) \$<br>4,000 | (154,190)<br>22,000 |
| Net lncome                                  | 15,767                      | 40,860               | 56,627              |
| Balance, December 31,2021                   | \$<br>(33,129) \$           | (42,434) \$          | (75,563)            |

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#### Statement of Cash Flows

#### Year Ended December 31, 2021

| Cash flow from operating activities<br>Net income                                                                                                          |    | 56,627               |
|------------------------------------------------------------------------------------------------------------------------------------------------------------|----|----------------------|
| Adjustments to reconcile net income to net cash<br>Provided by operating activities:<br>(lncrease) decrease in operating assets:<br>Commissions receivable |    | 911                  |
| Increase (decrease)in operating liabilities:                                                                                                               |    |                      |
| Accounts payable and accrued expenses<br>Deferred Revenue                                                                                                  |    | (31,934)<br>(22,848) |
| Net cash provided by operating activities                                                                                                                  |    | 2,756                |
| Cash flow from financing activity                                                                                                                          |    | 22,000               |
| Capital Addition<br>PPP Loan Foregiveness                                                                                                                  |    | (30,500)             |
| *Net cash used in financing activities                                                                                                                     |    | (8,500)              |
|                                                                                                                                                            |    |                      |
| Net decrease in cash                                                                                                                                       |    | (5,7 44)             |
| Cash, beginning of year                                                                                                                                    |    | 117,1 89             |
| Cash, e nd of year                                                                                                                                         | \$ | 1 1 1,a1?            |
| Cash Paid for lnterest                                                                                                                                     |    | \$ 7,500             |

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#### Statement of Chages in Liabilities Subordinated to the Claims of General Creditors

Year Ended December 31 , 2021

| Balance at December 31, 2020 |     | \$ 125,000 |
|------------------------------|-----|------------|
| lncreases                    | \$0 |            |
| Decreases                    |     | E9         |
| Balance at December 31. 2021 |     | \$ 125,000 |

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#### Notes to Financial Statements

#### December 31, 2021

#### 1. Organization and Business

PTI SECURITIES & FUTURES L.P. AND SUBSIDIARY (the "Partnership") was formed on December 11, 1991, pursuant to the Revised Uniform Limited Partnership Act of the State of lllinois. The Partnership is a single class limited partnership. The Partnership is a registered securities broker-dealer with the Securities and Exchange Commission and is a member of the Financial lndustry Regulatory Authority. The Partnership is also registered with the Commodity Futures Trading Commission as a non-guaranteed lntroducing Broker and is a member of the "National Futures Association. The Partnership solicits and accepts orders to buy or sell equity transactions and futures contracts or options on futures while not accepting or holding customer margin deposits. These assets are held by the respective clearing broker.

The Partnership's general partner shall have exclusive authority to manage, conduct, administer and control the Partnership's business.

PTI Securities & Futures L.P. has one wholly owned subsidiary, Wells Streeet Advisors, which is a Registered lnvestment Advisor registered with the State of lllinois. Curently, Wells Street Advisors manages funds as a sub-advisor for a Chicago based RIA.

# 2. Summary of Significant Accounting Policies

The Partnership's financial statements have been prepared in accordance with accounting principles generally accepted in the United States of America and are stated in U.S. dollars. The following is a summary of the significant accounting policies used in preparing the financial statements:

#### Princioals of Consolidaation

The consolidated financial statements include the accounts of PTI Securities & Futures L.P. and Wells Street Advisors, (collectively, the "Partnership"). All significant intercompany balances have been eliminated.

#### Revenue Recoqnition

Commission revenue and related expenses on futures and futures options contracts are recorded on a "half-turn" basis, which is the date when the futures contracts are bpened or closed and when futures options contracts are purchased or sold. Commission revenue and related expenses on transactions cleared through lnteractive Brokers are recorded on a trade date basis. Commission revenue and related expenses on transactions cleared through RBC Capital Markets are recorded on a settlement basis, and this has not changed from the prior year and Management determined this does not have a material effect on these statements.

The Partnership recognized revenue in accordance with the Financial Accounting Standards Board Accounting Standards Codification ('FASB ASC') Topic 606, Revenue from Contracts with Customers, effective January 1,2018. There were

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Notes to Financial Statements, Gontinued

#### December 31, 2021

# 2. Summary of Significant Accounting Policies continued

no material changes in its revenue recognition policies and no material impact on the financial statements as a result of the new standard.

#### Use of Estimates

The preparation of financial statements in conformity with United States Generally Accepted Accounting Principles ('U.S. GAAP") requires management to make estimates and assumptions that affect the amounts reported in the financial statements and the accompanying notes. Management determines that the estimates utilized in preparing its financial statements are reasonable and prudent. Actual results could differ from these estimates.

#### lncome Taxes

The Partnership is a limited partnership with all taxable income or loss recorded in the income tax returns.of the partners. Accordingly, no provision for income taxes has been made in the accompanying financial statements,

ln accordance with U.S. GAAP, the Partnership is required to determine whether its tax positions are more likely than not to be sustained upon examination by the applicable taxing authority, based on the technical merits of the position. Generally, the Partnership is no longer subject to income tax examinations by major taxing authorities for the years before 2018. Based on its analysis, there wdre no tax positions identified by management which did not meet the "more likely than not" standard as of and for the year ended December 31, 2021

#### Financial lnstruments Credit Losses 3.

ln June 2016 the FASB issued ASU 2016-13 Financial lnstruments - Credit Losses (Topic 326) ("ASU 2016-13"). This ASU amends several aspects of the measurement of credit losses on financial instruments including replacing the existing incurred credit loss model and other models with the Currbnt Expected Credit Losses model ('CECL'). Under CECL, the allowance for losses reflects management's estimate of credit losses over the remaining expected life of the financial assets and expected credit losses for newly recognized financial assets, as well as changes to the expected credit losses buring the period, would be recognized in earnings. Expected credit losses will be measured based on historical experience, current conditions, and forecasts that affect the collectability of the reported amount, and will be generally recognized earlier than under current standards. The standard is effective for the Partnership for fiscal years beginning after December 15, 2019. The standard does not have a material impact on the Partnership's consolidated fi nancial statements.

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Notes to Financial Statements, Continued

December 31, 2021

#### 4. Financial lnstrument Valuation

Accounting Standards Codification 820 defines fair value, establishes a framework for measuring fair value, and establishes a fair value hierarchy which prioritizes the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.

ln determining fair value, the Partnership uses various valuation approaches. A fair value hierarchy for inputs is used in measuring fair value that maximizes the use of observable inputs and minimizes the use of unobservable inputs by requiring that most observable inputs be used when available. Observable inputs are those that market participants would use in pricing the asset or liability based on market data obtained from sources independent of the Partnership.

Unobservable inputs reflects the Partnership's assumption about participants would use in pricing the asset or liability developed information available in the circumstances. the inputs market based on the best

The fair value hierarchy prioritizes is categorized into three levels information available in the circumstances. based on the best

- Level 1 Valuation is based on quoted prices iA active markets for identical assets or liabilities as the reporting date.
- Level 2 Valuation is based on other than quoted prices included in Level <sup>1</sup> that are observable for substantially the full term of the asset or liability, either directly or indirectly.
- Level 3 Valuation is based on unobservable inputs for value of the asset or liability. Level 3 assets include investments for which there is little, if any, market activity. These inputs require significant management judgment or estimation.

fh" availability of valuation techniques and observable inputs can vary from investment to investment and is affected by a wade variety of factors, including, the type of investment, whether the investment is new and not yet established in the marketplace, and other characteristics particular to the transaction. To the extent that the valuation is based on models or inputs that are less unobservable or unobservable in the market, the determination of fair value requires more judgment. Those estimated values do not necessarily represent the amounts that may be ultimately realized due to the occurrence of future circumstances that cannot be reasonably determined. Because of the inherent uncertainty of valuation, those estimated values may be materially higher or lower than the values that would have been used had a ready market for the investments existed. Accordingly, the degree of judgment exercised by the Partnership in determining fair value is greatest for investments

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Notes to Financial Statements, Continued

#### December 31, 2021

# 4. Financial lnstrument Valuation continued

categorized in Level 3. ln certain cases, the inputs used to measure fair value may fall into different levels in the fair value hierarchy within which the fair value measurement in its entirety falls is determined based on the lowest level input that is significant to the fair value measurement.

At December 31, 2021 the Partnership held no Level 1, Level 2 or Level 3 investments.

# 5. Clearing Agreements

The Partnership has entered into fully disclosed clearing agreements with RBC Capital Markets ("RBC") and Interactive Brokers LLC ("lB').

The Partnership, under Rule 15c3-3(kX2Xii), is exempt from the reserve and possession or control iequirements of Rule 15c3-3 of the Securities and Exchange Commission. The Partnership does not carry or clear customer accounts. Accordingly, all customer transactions are executed and cleared on behalf of the Partnership by its clearing brokers on a fully disclosed basis. The Partnership's agreement by it's clearing brokers provide that as clearing brokers, the firms will make and keep such records of the transactions effected and cleared in the customer accounts as are customarily made and kept by a clearing broker pursuant to the requirements of Rules 17a-3 and 17a-4 of the Securities and Exchange Act of 1934, as amended (the "ACT"). They also perform all services eustomarily incident thereon, including the preparation and distribution of customer's confirmation and statements and maintenance margin requirements under the Act and the rules of the Self-Regulatory Organizations of which the Partnership is a member.

#### Employee Benefit Plan 6.

The Partnership has established a Simple IRA plan for qualified employees. The Partnership matches employees' contributions, subject to certain limitations as set forth in the plan agreement. There were'no employee contributions made to the plan during the year ended December 31, 2021. The Partnership paid \$6,080 during the calendar year of 2021.

#### " Guarantees 7.

Accounting Standards Codification 460 ("ASC 460'), Guarantees, requires the Partnership to disclose information about its obligations under certain guarantee arrangements. ASC 460, defines guarantees as contracts and indemnification agreements that contingently require a guarantor to make payments to the guaranteed party based on changes in underlying (such as an interest or foreign exchange rate, security or commodity price, an index or the occurrence or nonoccurrence of a specified event) related to an asset, liability or equity security of a guaranteed party. This guidance also defines guarantees as contracts that contingently require the guarantor to make payments to the guaranteed party

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Notes to Financial Statements, Continued

#### December 31, 2021

# 7. Guaranteescontinued

based on another entity's failure to perform under an agreement, as well as indirect guarantees of the indebtedness of others.

#### Other Guarantees

Customer transactions are introduced to and cleared through the Partnership's brokers on a fully disclosed basis. Under the terms of its clearing agreements, the Partnership is required to guarantee the performance of its customers in meeting contracted obligations. ln conjunction with the broker, the Partnership seeks to control the risks associated with its customer activities by requiring customers to maintain collateral in compliance with various regulatory and internal guidelines and, pursuant to such guidelines, customers may be required to deposit additional collateral, or reduce positions, where necessary. The maximum potential amount of future payments that the Partnership could be required to make under these guarantees cannot be estimated. However, the Partnership believes that it is unlikely it will have to make material payments under these arrangements and has not recorded any contingent liability in the financial statements.

#### 8. Credit Risk

Commissions receivable represent a concentration of credil risk. The Partnership does not anticipate nonperformance by its customers or brokers. ln addition, the Partnership has a policy of reviewing, as considered necessary, the creditworthiness of the brokers with which it conducts business.

#### Related Party Transactions 9.

As of December 31 ,2021there was \$11,033 of receivables from affiliated companies. This amount represents \$9,049 from NKH lnc. and \$1,984 from Haugh lnc. of expenses that were paid by the Partnership on behalf of these affiliated companies. As of December 31 ,2021there was also a payable to the president of the Partnership totaling \$1,000 which is included in the accounts payable and accrued expenses on the statement of financial condition. The Partnership also had a \$125,000 eubordinated loan with one of the limited partners (see note 15).

## 10. Net Capital Requirements

Pursuant to the net capital provisions of Rule 15c3-1 of the Securities Exchange Act of 1934, the Partnership is required to maintain minimum net capital, as defined, equalto the greater of \$5,000 or 6 2l3o/o of aggregate indebtedness (superseded by the NFA minimum of \$45,000). At December 31, 2Q21 lhe Partnership had net capital of \$75,568, which was \$30,568 in excess of the required minimum net capital. The Partnership's net capital ratio (aggregate indebtedness to net capital) was 2.45 to 1. The Partnership is also subject to the net capital rules of the NFA. The Partnership is

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#### Notes to Financial Statements, Continued

#### December 31, 2021

#### 10. Net Capital Requirements continued

required to maintain a minimum net capital under the NFA rules of \$45,000. Under these rules, the Partnership had excess net capital of \$30,568.

#### Uncertainty - Going Concern 11.

On February 27,2020 the Partnership received an adverse FINRA arbitration award of \$144,787 including FINRA fees. This award exceeded the Partnership's excess net capital at that time, placing the Partnership in a het capital deficiency as of that date. The Partnership remained in a capital deficiency until the Partnership received <sup>a</sup> \$25,000 capital addition and a \$125,000 subordinated loan agreement approved by the regulatory authorities in early March, 2020.

As was highlighted in the previous year's financial statements, during December 2016 PTI signed an agreemeht to extend the clearing agreement with RBC Capital Markets and received a signing bonus. The Partnership was required to account for this bonus as a liability to be amortized over the life of this contract extension and this treatment resulted in the Partnership being placed into a negative equity position as of the date of that agreement. For the year ended December 31,2021, despite the gain of \$56,627 for the calendar year 2021, the Partnership remains in a negative equity position of (\$75,563) as of December 31. 2021. Although the Partnership is in compliance with the net capital rule (see note 10), regulatory authorities are rather arbitrary with negative equity situations and may require the Partnership to contribute additional capital if the firm was to experience losses for any period of time.

#### Contingency 12.

The Partnership has one litigation pending with the Partnership appealing the adverse FINRA arbitration award (see note 11) in circuit court of Cook County lllinois. Not only does the Partnership allege that the arbitration should not have been found for the claimant but also the distribution of the damages between the broker and the Partnership as well as the fact that a counterclaim was found against the claimant but awarded to the broker only and not the Partnership were all completely out of the industry standard and should be reversed. This appeal is in the process and there currently is no determination as to when it will be completed.

#### SUbsequent Events 13.

The Partnership's management has evaluated all events and transactions through February 21,2022, the date the financial statements were available to be issued, noting no material events requiring disclosure in the Partnership's financial statements.

## 14 Paycheck Protection Program Loan

ln late January 2021 lhe Partnership was notified of the official SBA foregiveness of the \$30,500 loan through BMO Harris Bank subject to the provisions of the Paycheck Protection Program (PPP). This amount was included in the 2021 financial statements as other income on the Statement of Operations.

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Notes to Financial Statements, Continued

#### December 31, 2021

## 15. Subordinated Loan

On March 5,2020, the Partnership entered into a subordinated loan agreement with one of the Partners in the amountof \$125,000. This loan matures March 6,2023 and carries an annual interest rate of 6%. lnterest paid on this subordinated loan during the calendar year 2021was \$7,500.

Pursuant to the terms of the agreement, the note renews for one year upon maturity, unless notified otherwise in andvance by the note holder. Notification by the note holder not to renew must be made thirteen months in advance of a maturity date. At December 31,2021 the balance was \$125,000 and is included on the statement of financial condition.

The subordinated borrowing is covered by an agreement approved by FINRA and thus available in computing net capital. Under certain circumstances and with prior permission from FINRA; the Partnership may, at its option, make a payment of all or any portion of the principal amount prior to the maturity date at any time subsequent to one year from the effective date of the agreement.

#### 16. Lease Commitment

The Partnership conducts its operations in leased office facilities and annual rentals are charged to current operations. Rent expense for the year ended December 31, 2021 totaled approximately \$32,749, and is included in ocoupancy on the statement of operations.

The Partnership also sublets office space to a third party on a month to month basis Sublet income earned for the year ended December 31, 2021 totaled approximately \$10,500 and is included in other income on the Statement of Operations.

ln June 2021, lhe Partnership signed a lease extension until May 31, 2022 and as of December 31 ,2021 remaining lease obligations until lease termination were \$16,91 <sup>1</sup>.

The Partnership recognizes leases in accordance wth Financial Accounting Standards Codification ('FASB ASC) Topic 842, Leases. This guidance requires public business entities to recognize a right-of-use asset and a lease liability in the statement of financial condition. The Partnership has elected an exemption to this guidance for its short term office lease of less than twelve months and recognizes the lease payment on a straight-line basis over the remaiing life. Management believes the impact of Topic 842 and the election of the exemption has no material impact on its financial statements.

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#### Notes to Financial Statements, Continued

#### December 31, 2021

#### 17. Note ERC

The Partnership received Employee Retention Credits (ERC) under the CARES Act during the calendar year ended December 31,2021. The Partnership applied the International Accounting Standards (IAS) 20 model in accounting for this government grant since the accounting is not specified in FASB ASC.

IAS 20 provides guidance on government grants for business entities but is considered nonauthoritative in the FASB ASC. While it is not part of the FASB ASC, FASB ASC 105, Generally Accepted Accounting Principals, and more specifically, FASB ASC 105-10-05-2, does permit considering an non authoritatative source (such as IAS) when accounting for the transaction is not specified in the FASB ASC or the accounting for similar transaction is not specified in the FASB ASC.

The Partnership received \$46,500 in ERC for the year ended December 31,2021 and the amounts are inctuded within employee compensation and benefits on the Statement of Operations. The ERC effectively reduces the related compensation and benefits expense a's permitted by IAS 20.

{17}------------------------------------------------

SUPPLEMENTAL SCHEDU LES

{18}------------------------------------------------

#### FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT PART III

BROKER OR DEALER: PTTSECURTTTES & FUTURES L.P. AND SUBSTDTARY as of December 31, 2021

### COMPUTATION OF NET CAPITAL

| 1.       | Total ownership equity (from Statement of Financial Condition - item 1800)                                |   | \$ (75,563\ [3480]     |         |
|----------|-----------------------------------------------------------------------------------------------------------|---|------------------------|---------|
| 2.       | Deduct Ownership equity not allowable for net capital ,                                                   |   |                        | [34e0]  |
| 3.<br>4. | Total ownership equity qualified for net capital                                                          |   | \$(zssos t3sool        |         |
|          | Add:<br>A. Liabilities subordinated to claims of general creditors allowable in computation of net capita |   | 125,000 [3520]         |         |
|          | B. Other (deductions) or allowable credits (List)                                                         |   | 43,856 [3525]          |         |
| 5.       | Total capital and allowable subordinated liabilities                                                      |   | \$<br>93,293 [3530]    |         |
| 6.       | Deductions and/or charges:                                                                                |   |                        |         |
|          | A. Total non-allowable assets from Statement of Financial Condition                                       |   |                        |         |
|          | \$ 1T ,T2S<br>(See detail below)<br>[3540]                                                                |   |                        |         |
|          | 1. Additional charges for customers' and non-customers' security accounts.                                |   |                        |         |
|          | [3550]                                                                                                    |   |                        |         |
|          | 2. Additional charges for customers' and non-customers' commodity<br>accounts.<br>[3560]                  |   |                        |         |
|          | B. Aged fail-to-deliver                                                                                   |   |                        |         |
|          | [3570]<br>1. Number of items                                                                              |   |                        |         |
|          | t34501<br>C. Aged shorl security differences-less reserved of<br>[3580]                                   |   |                        |         |
|          | t34701<br>number of items<br>                                                                             |   |                        |         |
|          | 134701<br>D. Secured demand note deficiency<br>[35e0]                                                     |   |                        |         |
|          | E. Commodity futures contracts and spot commodities proprietary capital<br>[3600]                         |   |                        |         |
|          |                                                                                                           |   |                        |         |
|          | F. Other deductions and/or charges .,.<br>[361 0]                                                         |   |                        |         |
|          | G. Deductions for accounts carried under Rule 15c3-1(a)(7) and (cX2)(x).<br>[s61 5]                       |   |                        |         |
|          | H. Total deduction and/or charges.                                                                        |   | \$<br>(17 ,725) [3620] |         |
| 7.       | Other additions and/or allowable credits (List)                                                           |   |                        | [3630]  |
| 8.       | Net Capital before haircuts on securities positions<br>i:                                                 |   | \$zssoa t364ol         |         |
| 9.       | Haircuts on securities : (computed, where applicable pursuant to 15c3-1 (0):                              |   |                        |         |
|          | A. Contractual securities commitments<br>[3660]                                                           |   |                        |         |
|          | B. Subordinated securities borrowings<br>[3670]                                                           |   |                        |         |
|          | C. frading and lnvestment securities                                                                      |   |                        |         |
|          | 1 . Bankers' acceptances, certificates of deposit and commercial paper<br>[3680]                          |   |                        |         |
|          | 2. U.S. and Canadian government obligations<br>[36e0]                                                     |   |                        |         |
|          | 3. State and municipal government obligations<br>[3700]                                                   |   |                        |         |
|          | 4. Corporate obligations<br>[3710]                                                                        |   |                        |         |
|          | 5. Stocks and warrants<br>137201                                                                          |   |                        |         |
|          | 6. Options<br>[3730]<br>'                                                                                 |   |                        |         |
|          | 7. Arbitrage<br>137321                                                                                    |   |                        |         |
|          | 8. Other securities<br>137341                                                                             |   |                        |         |
|          | D. Undue concentration<br>[3650]                                                                          |   |                        |         |
|          | E. Other (MoneV Market) .<br>[3736]                                                                       |   |                        | [371 0] |
| 10.      |                                                                                                           |   | \$<br>?5,?68 [3750]    |         |
|          |                                                                                                           | " | OMIT PENNIES           |         |
|          | Non-Al f owahle Asgets (! i ne. 9.A).:                                                                    |   |                        |         |

| Receivable from affiliates | \$<br>1 1,033 |
|----------------------------|---------------|
| Cash                       | \$e3          |
| Commission Receivable      | 6,599         |
|                            | \$<br>1?,?25  |

-

{19}------------------------------------------------

### FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT PART III

| BROKER OR DEALER. | PTTSECURTTTES & FUTURES L.P. AND SUBSTDTARY | as of December 31, 2021 |
|-------------------|---------------------------------------------|-------------------------|
|                   |                                             |                         |

COMPUTATION OF BASIC NET CAPITAL REQUIREMENT

#### Part A 11. 12. 12,385 [3756 I Minimum net capital required (6-2130/0 of line 19) Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital requirement of subsidiary computed in accordance with Note (A) . . . . Net capital requirement (greater of line 1 1 or 12) Excess net capital (line 10 less 13) ...................:. Net capital less greater ol 1Oo/o of line 19 or 120o/o of line 12....... 45,000 [3758 I 13. 14. 15. 45,000 [3760 l 30,569 <sup>13770</sup> I 21,568 [3780

### COMPUTATION OF AGGREGATE INDEBTEDNESS

I

|      | 16. Total A.l. liabilities from Statement of Financial Condition                             |         | 1 g5 ,77 5      | [3790] |
|------|----------------------------------------------------------------------------------------------|---------|-----------------|--------|
|      | 17. Add:                                                                                     |         |                 |        |
|      | A. Drafts for immediate credit.<br>:r.                                                       | [3800]  |                 |        |
|      | B. Fair value of securities borrowed for which no equivalent<br>value is paid or credited    | [381 0] |                 |        |
|      | C. Other unrecorded amounts (List)                                                           | [3820]  |                 | [3830] |
| 18.  | Deduct Adjustment based on deposits in Special Reserve Bank Accounts (15c3-1 (c) (1) (vii)). |         |                 | [3838] |
| 19.  | Total aggregate indebtedness                                                                 |         | 185 ,775 [3840] |        |
| 20.  | Percentage of aggregate indebtedness to net capital (line 19 + by line 10)                   |         | 245.84% [3850]  |        |
| 21 . | Percentage of debt to debt-equity total computed in accordance with Rule 15c3-1(d) .,        |         |                 | [3860] |

COMPUTATION OF ALTERNATE NET CAPITAL REQUIREMENT

#### Part B

| 22.    | 2% of combined aggregate debit items as shown in Formula for Reserve Requirements pursuant                                                                              |         |
|--------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|
|        | to Rule 15c3-3 prepared as of the date of the net capital computation including both brokers or                                                                         |         |
|        | dealers and consolidated subsidiary debits                                                                                                                              | [3870]  |
| 23.    | Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital<br>requirement of subsidiary computed in accordance with Note (A) .<br>. . | [3880]  |
| 24.    | Net capital requirement (greater of line 22 or 23)   .                                                                                                                  | [3760]  |
| 25.    | Excess net capital (line 10 less 24)                                                                                                                                    | [3e10]  |
| 26.    | Percentage of Net Capitalto Aggregate Debits (line 10 - by line 17 page 8)                                                                                              | [3851 ] |
| 27.    | Percentage of Net Capital, after anticipated capital withdrawals, to Aggregate Debits                                                                                   |         |
|        | (line 10less item 4880 page 11 + by line 17 page 8)                                                                                                                     | [3854]  |
| 28.    | Net capital in exiess of: the greater of: A. 5% of combined aggregate debit items or \$120,000                                                                          | [3e20]  |
|        | OTHER RATIOS                                                                                                                                                            |         |
| Part C |                                                                                                                                                                         |         |
|        | 29. Percentage of debt to debt-equity totalcomputed in accordance with Rule 15c3-1(d)                                                                                   | [3860]  |
|        | 30. Options deductions/Net Capital ratio (1000% test) total deductions exclusive of liquidating equity<br>under Rule 15c3-1(aX6), (a)(7) and (cX2Xx) * Net Capital      | [3852]  |

- NOTES: A. The minimum net capital requirement should be computed by adding the minimum dollar net capital requirement of the reporting broker dealer and, for each subsidiary to be consolidated, the greater of:
	- 1. Minimum dollar net capital requirement, or
	- 2.6-2130/o of aggregate indebtedness or 2oh of aggregate debits if alternate method is used.
- B. Do not deduct the value of securities borrowed under subordination agreements or secured demand notes covered by subordination agreements not in satisfactory form and the fair values of memberships in exchanges contributed for use of Partnership (contra to item 1740) and partners securities which were included in non-allowable assets.
- C. For reports filed pursuant to paragraph (d) of Rule 17a-5, respondent should provide a list of material non-allowable assets
- Note: There are no material differences between the audited computation of net capital and the Partnership's unaudited FOCUS report as filed

{20}------------------------------------------------

### Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3

December 31,2021

The Partnership did not handle any customer cash or securities during the year ended December 31,2021 and does not have any customer accounts. The Partnership is exempt from the provisions of the rule15c3-3 of the Securities Exchange Act of 1934 under paragraph (k)(2xii). Accordingly, there are no items to report under the requirements of this rule.

### PTISECURITIES & FUTURES L.P, AND SUBSIDIARY

lnformation Relating to Possession or Control Requirements pursuant to Rule 15c3-3

## December 91,2O2a'

The Partnership did not handle any customer cash or securities during the ylar ended December 31 , 2021and does not have any customer accounts. The Partnership is exempt from the provisions of the rule15c3-3 of the Securities Exchange Act of 1934 under paragraph (k)(2xii). Accordingly, there are no items to report under the requirements of this rule.

{21}------------------------------------------------

|    | NAME OF PARTNERSHIP                                                                                                                                                                                                                                                               |              | I EMPLOYER lD NO:                   |                            | I NFA lD NO: |                            |                        |                  |
|----|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|-------------------------------------|----------------------------|--------------|----------------------------|------------------------|------------------|
|    | PTI SECURITIES & FUTURES L,P. AND<br>SUBSIDIARY                                                                                                                                                                                                                                   | I 36-3797795 |                                     |                            | 0244522      |                            |                        |                  |
|    | STATEMENT OF THE COMPUTATION OF THE MINIMUM CAPITAL REQUIREMENTS                                                                                                                                                                                                                  |              | CFTC FORM 1.FR-IB<br>AS OF 12t31t21 |                            |              |                            |                        |                  |
| 1. | Current assets                                                                                                                                                                                                                                                                    |              |                                     |                            |              |                            | \$217 ,487 [30001      |                  |
|    |                                                                                                                                                                                                                                                                                   |              |                                     |                            |              |                            |                        |                  |
| 3. | Deductions from total liabilities<br>A. Liabilities subject to satisfactory<br>Subordinated agreements<br>(page 3, line 19.A)                                                                                                                                                     |              | 125,000 [3040]                      |                            |              |                            |                        |                  |
|    | B. Deferred lncome                                                                                                                                                                                                                                                                |              | 43,8q6_ "[3050]                     |                            |              |                            |                        |                  |
|    | C.                                                                                                                                                                                                                                                                                |              |                                     | [3060]                     |              |                            |                        |                  |
|    | D. Long term debt pursuant to<br>Regulation 1 .17 (c)(aXvi)<br>E. Total deductions<br>F. Adjusted liabilities                                                                                                                                                                     |              |                                     | [3070]                     |              | 169,956 [3080]             | . \$ (141 ,919) [3oeo] |                  |
| 4. | Net capital (subtract line 3.F. from.line 1)                                                                                                                                                                                                                                      |              |                                     |                            |              |                            | \$75,568 [3100]        |                  |
| 5. | Charqes Aoainst Net Capital (see regulation 1.17(c)(5))<br>Charges against inventories held, fixed price commitments, and advances<br>against cash commodity contracts (see regulation 1 .1 7(c)(5)(i) and (ii)<br>for specific charge. lf charge is applicable, attach statement |              |                                     |                            |              |                            |                        |                  |
|    | Showing calculation of charge)                                                                                                                                                                                                                                                    |              |                                     |                            |              |                            |                        | [31 55]          |
| 6. | Charges as specified in section 240.15c3-1(c)92)(vi) and (vii)<br>against securities owned by firm:                                                                                                                                                                               |              |                                     |                            | ir           |                            |                        |                  |
|    |                                                                                                                                                                                                                                                                                   |              | FAIR<br>VALUE                       |                            | CHARGE       |                            |                        |                  |
|    | A. U.S. and Canadian government obligations<br>B. State and Municipal government obligations<br>C. Certificates of deposit, commercial paper<br>and bankers' acceptances .<br>D. Corporate obligations                                                                            |              |                                     | [3160]<br>[3180]<br>[3200] |              | [3170]<br>[31e0]<br>[3210] |                        |                  |
|    | E. Stocks and warrants<br>F. Other securities (money market)<br>G. Total charges (add lines 6.A. - 6 F)                                                                                                                                                                           |              |                                     | [3240]<br>[3260]           |              | [:;;3]<br>13270)           |                        | [3280]           |
| 7. | Charges as specified in section 240.15c3-'l (c)(2)(iv)(F)<br>A. Against securities purchased under agreements to rese  <br>B. Against securities sold under agreements to repurchase                                                                                              |              |                                     |                            |              |                            |                        | [32e0]<br>[3300] |
| 8. | Charges on securities options as specified in section 240.15c3-1. Appendix A                                                                                                                                                                                                      |              |                                     |                            |              |                            |                        | [3310]           |
|    | Current Assets:<br>Cash<br>Receivable from broker-dealers<br>Commissions receivable                                                                                                                                                                                               | \$           | 1 11,352<br>100,000<br>6,135        |                            |              |                            |                        |                  |

\$ 217,487

{22}------------------------------------------------

|                                                                                                                    | NAME OF PARTNERSHIP                                                                                                                                                                                                                                                                                            | I EMPLOYER ID NO: | I NFA ID NO: |                     |         |  |
|--------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|--------------|---------------------|---------|--|
|                                                                                                                    | PTISECURITIES & FUTURES L.P. AND<br>SUBSIDIARY                                                                                                                                                                                                                                                                 | I 36.3797795      | I 0244522    |                     |         |  |
| CFTC FORM 1.FR.!B<br>STATEMENT OF THE COMPUTATION OF THE MINIMUM CAPITAL REQUIREMENTS<br>AS OF 12131121, Gontinued |                                                                                                                                                                                                                                                                                                                |                   |              |                     |         |  |
| I                                                                                                                  | Charges against open commodity in the lB's account<br>A. Uncovered exchange{raded futures and granted options contracts -<br>percentage of margin requirements applicable to such contracts                                                                                                                    |                   |              |                     | [3350]  |  |
|                                                                                                                    | B. Ten percent (10%) of the fair value of commodities which<br>underlie commodity options not traded on a contract market<br>carried long by the applicant or registrant which has value<br>and such value increased adjusted net capital (this charge.<br>is limited to the value attributed to such options) |                   |              |                     |         |  |
|                                                                                                                    | C. Commodity options which are traded on contract markets and<br>carried long in proprietary accounts. Charge is the same as<br>would be applied if applicant or registrant was the grantor<br>of the options (this charge is limited to the value attributed<br>to such options)                              |                   |              |                     | [33e0]  |  |
| 10.                                                                                                                | Five percent (5%) of all unsgcured receivables from unregistered<br>futures commission merchants or securities brokers or dealers                                                                                                                                                                              |                   |              |                     | [341 0] |  |
| 11.                                                                                                                | Deficiency in collateral for secured demand                                                                                                                                                                                                                                                                    |                   |              |                     | 134201  |  |
| 12.                                                                                                                | Adjustment to eliminate benefits of consolidation (explain in separate page)                                                                                                                                                                                                                                   |                   | :.           |                     | [3430]  |  |
| 13.                                                                                                                | Totalcharges (add lines 5 through 12)                                                                                                                                                                                                                                                                          | <br>ii            |              |                     | [3440]  |  |
|                                                                                                                    | Net Capital Computation                                                                                                                                                                                                                                                                                        |                   |              |                     |         |  |
|                                                                                                                    | 14. Adjusted net capital (subtract line 13 from line                                                                                                                                                                                                                                                           |                   |              | \$<br>75,568 [3500] |         |  |
|                                                                                                                    | 15. Net capital                                                                                                                                                                                                                                                                                                |                   |              | 45,000              | [3600]  |  |
| 16.                                                                                                                | Excess net capital (subtract line 15 from line                                                                                                                                                                                                                                                                 |                   |              | \$ 30,568           | [361 0] |  |

Note: There are no material differences between the audited computation of net capital and the Partnership's unaudited FOCUS report as filed.

{23}------------------------------------------------

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RYAN&JURA,SKA LLP Certifiecl Public Accountants

141 West Jacl<son Boulevard Chicago, lllinois 60604

Tel: 312.922.0062 Fax: 312.922.0672

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Partners of PTI Securities & Futures L.P. and Subsidiary

We have reviewed management's statements, included in the accompanying "The Exemption Report", in which (1) PTI Securities & Futures L.P. and Subsidiary (the Partnership) claimed an exemption from 17 C.F.R 240.15c3-3 under the following provisions of 17 C.F.R. 240.15c3-3 (kX2Xii);. and (2) The Partnership met the identified exemption provision in 17 C.F.R. 240.15c3-3(k) throughout the most recent fiscal year ended December 31,2021 , without exception. The Partnership'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 the Partnership'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 in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934.

%fr\*t f,'ua4/4 /L?

Chicago, Illinois February 21 ,2022

{24}------------------------------------------------

## The Exemption Report

PTI Securities & Futures L.P. and Subsidiary (the Partnership) is a registered broker-dealer subject to Rule l7a-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 (a). To the best of its knowledge and belief, the Partnership states the following:

- The Partnership claimed an exemption from 17 C.F.R 240.15c3-3 under the following provisions of 17 C.F.R. 240.15c3-3 (kx2xii). 1.
- The Partnership met the identified exemption provision in 17 C.F.R. 240.15c3-3(k) throughout the most recent fiscal year ended December 3I, 2021, without exception. 2.

PTI Securities & Futures L.P. and Subsidiary

I, Daniel J. Haugh, swear that, to my best knowledge and belief this Exemption Report is true and correct.

/4/

ugh Daniel J. President

212U2022 Date

{25}------------------------------------------------

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RYArV &JIJRASKA LtP Certifi ecl Public Accountants

141 West facl<son Boulevarcl Chicago, lllinois 60604

Tel: 312.922.0062 Fax: 312.922.0672

#### INDEPENDENT AUDITOR'S REPORT ON INTERNAL CONTROL

To Management and the Partners OF PTI Securities & Futures L.P. and Subsidiary,

ln planning and performing our audit of the financial statements of PTI Securities & Futures L.P. and Subsidiary (the "Company"), as of and for the year ended December 31,2021, in accordance with auditing standards of the Public Company Accounting Oversight Board (United States) (PCAOB), our audit included consideration of internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we do not express an opinion on the effectiveness of the Company's internal control.

Also, as required by Regulation 1.16 of the Commodity Futures Trading Commission (CFTC), we have made a study of the practices and procedures followed by the Company including consideration of control activities for safeguarding customer and firm assets. This study included tests of such practices and procedures that we considered relevant to the objectives stated in Regulation 1.16 in making the periodic computations of minimum financial requirements pursuant to Regulation 1.17. Because the Company is an introducing broker (as defined by CFTC Regulation 1.3(mm)), we did not review the practices and procedures followed by the Company in making the following:

- 1. The daily computations of the segregation requirements of Sectiofis 4d(a)(2) and 4d(f)(2) of the Commodity Exchange Act and the regulations thereunder, and the segregation of funds based on such computations;
- 2. The daily computations of the foreign futures and foreign options secured amount requirements pursuant to Regulation 30.7 of the CFTC

The management of the Company is responsible for establishing and maintaining internal control and the practices and procedures referred to in the preceding paragraph. ln fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls and of the practices and procedures referred to in the preceding paragraph and to assess whether those practices and procedures can be expected to achieve the CFTC's previously mentioned objectives. Two of the objectives of internal control and the practices and procedures are to provide management with reasonable but not absolute assurance that assets for which the Company has responsibility are safeguarded pgainst loss from unauthorized use or disposition, and that transactions are executed in accordance with management's authorization and recorded properly to permit preparation of financial statements in conformity with U.S. generally accepted accounting principles. Regulation 1.16(d)(2) list additional objectives of the practices and procedures listed in the preceding paragraph.

Because of inherent limitations in internal control and the practices and procedures referred to above, error or fraud may occur and not be detected. Also, projection of any evaluation of them to future periods is subject to the risk that they may become inadequate because of changes in conditions or that the effectiveness of their design and operation may deteriorate.

{26}------------------------------------------------

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A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the Company's financial statements will not be prevented, or detected and corrected, on a timely basis.

Our consideration of internal control was for the limited purpose described in the preceding paragraphs and would not necessarily identify all deficiencies in internal control that might be material weaknesses. Given these limitations during our audit, we did not identify any deficiencies in internal control and control activities for safeguarding customer and firm assets that we consider to be material weaknesses.

We understand that practices and procedures that accomplish the objectives referred to in the second paragraph of this report are considered by the CFTC to be adbquate for its purposes in accordance with the Commodity Exchange Act, and related regulations, and that practices and procedures that do not accomplish such objectives in all material respects indicate a material inadequacy for such purposes. Based on this understanding and on our study, we believe that the Company's practices and procedures were adequate at December 31, 2021, to meet the CFTC's objectives.

This report is intended solely for the information and use of management and the partners, the CFTC, the National Futures Association, and other regulatory agencies that rely on Regulation 1.16 of the CFTC in their regulation of registered introducing brokers, and is not intended to be and should not be used by anyone other than these specified parties.

fifr\*t f,'ui4\*4 /LP

Chicago, lllinois Februa ry 21 , 2022


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