# SENTINEL BROKERS COMPANY, INC. X-17A-5 (2024-04-01) — Broker-dealer annual report - Company: SENTINEL BROKERS COMPANY, INC. - Form: X-17A-5 - Filed: 2024-04-01 - Period: 2023-12-31 - Accession: 0001007086-24-000002 - CIK: 1007086 - File #: 8-49005 - Type: Broker-dealer - Material weakness: No - Auditor: Assurance Dimensions - Auditor location: Margate, FL - Contact: Joseph Lawless - Phone: 5614062242 - Email: jlawless@sentinelbrokers.com - Website: sentinelbrokers.com - Signed by: Joseph Lawless (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1007086/000100708624000002/finalsec1.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 0MB APPROVAL 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 > SEC FILE NUMBER 8-49005 # **ANNUAL REPORTS FORM X-17A-5 PART** Ill **FACING PAGE** Information Required Pursuant to Rules 17a-S, 17a-12, and lSa-7 under the Securities Exchange Act of 1934 FILING FOR THE PERIOD BEGINNING **O 1 /Q 1 /2023** MM/00/YY AND ENDING **12/31/2023** MM/00/YY **A. REGISTRANT IDENTIFICATION** # NAME oF FIRM: Sentinel Brokers Company, Inc. TYPE OF REGISTRANT (check all applicable boxes): [!] Broker-dealer □ Security-based swap dealer □ Major security-based swap participant D Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) # 102 Xanadu Place | | | (No. and Street) | | | | |-------------------------------------------------------------------------------------|--------------|------------------------------------------------------------|------------------------------|--------------------------------------------|--| | Jupiter | | FL | | 33477 | | | {City) | (State) | | (Zip Code) | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | Joseph Lawless | 561-406-2242 | | jlawless@sentinelbrokers.com | | | | (Name) | | (Area Code - Telephone Number) | | (Email Address) | | | | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | B. ACCOUNTANT IDENTIFICATION | | | | | Assurance Dimensions | | (Name - If Individual, state last, first, and middle name) | | | | | 2000 Banks Road #218 | | Margate | FL | 33063 | | | 04/13/2010 | | (City) | (State)
5036 | (Zip Code) | | | r"
(Address)
of R,g;,t,atioo w;th PCAOB)(;f appUcable) FOR OFFICIAL USE ONL y | | | | (PCAOB Regl,t,atioo N•mbe,, ;f applicable) | | • 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-S(e)(l)(ii), 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 0MB control number. {1}------------------------------------------------ ### **OATH OR AFFIRMATION** I, Joseph Lawless swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Sentinel Brokers Company, Inc. as of **12/31** 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. Nptary Public v ,,./,,. \_ - ~ \$ I f'.S ~ ## **This filing•• contains (check all applicable boxes):** - **l!i!il** (a) Statement of financial condition. - D (b) Notes to consolidated statement of financial condition. ,\_\_ \_\_\_ \_\_ L.-.. - I\_,, - **l!i!il** (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). - **l!i!il** (d) Statement of cash flows. - **l!i!il** (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - D (f) Statement of changes in liabilities subordinated to claims of creditors. - **l!i!il** (g) Notes to consolidated financial statements. - **l!i!il** (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - D (i) Computation of tangible net worth under 17 CFR 240.18a-2. - D (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.1Sc3-3. - D (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.1Sc3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - D (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - D (m) Information relating to possession or control requirements for customers under 17 CFR 240.1Sc3-3. - D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.1Sc3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - D (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-l, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.1Sc3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - 0 (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - **l!i!il** (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. - D (r) Compliance report in accordance with 17 CFR 240.l 7a-S or 17 CFR 240.18a-7, as applicable. - **l!i!il** (s) Exemption report in accordance with 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable. - 0 (t) Independent public accountant's report based on an examination of the statement of financial condition. - D (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. - D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applica ble. - **l!i!il** (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.lSa-7, as applicable. - **l!i!il** (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.1Sc3-le or 17 CFR 240.l 7a-12, as applicable. - D (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). D (z) Other: \_ \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_ \_ - - \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-S(e)(3) or 17 CFR 240.18a-7(d}{2), as applicable. ~ CEO ![](_page_1_Picture_35.jpeg) {2}------------------------------------------------ Sentinel Brokers Company, Inc. Financial Statements and Supplemental Schedules Required by the U.S. Securities and Exchange Commission Including Independent Auditors' Report Thereon For the Year-Ended December 31, 2023 {3}------------------------------------------------ Sentinel Brokers Company, Inc. Financial Statements and Supplemental Schedules Required by the U.S. Securities and Exchange Commission Including Independent Auditors' Report Thereon For the Year-Ended December 31, 2023 {4}------------------------------------------------ | Contents | | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--| | Independent Auditors' Report | | | Financial Statements | | | Statement of Financial Condition | | | Statement of Operations | | | Statement of Cash Flows | | | | | | Notes to Financial Statements | | | | | | | | | | | | Report on SIPC Assessment Reconciliation | | | | | | Exemption Report Pursuant to SEA Rule 17a-5(d)(1)(i)(B)(2) | | | Statement of Changes in Stockholders' Equity
Supplementary Schedules Pursuant to SEA Rule 17a-5
Computation of Net Capital inder Rule 15e3-1 of the Securities and Exchange Commission of Aggregated Indencess
Statement Related to Exemptive Provision (Possession and Control)
Independent Auditors Report on Exemption Report | | {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) ASSURANCE DIMFNSIONS I #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Stockholders of Sentinel Brokers Company, Inc.: #### Opinion on the Financial Statements We have audited the accompanying s1a1emen1 of financial condition of Sentinel Brokers Company, Inc. (the "Company'') as of December 3 1, 2023. the related statements of operations. changes in stockholders· equity. and cash nows for the year then ended. and the related notes and schedules (collectively referred to as 1he " financ ial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 3 1, 2023, and the resuhs of its operations and its cash nows for the year then ended in conformity with accounting princ iples 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 10 express an opinion on the Company's financial statements based on our audit. We arc a public accounting finn registered with the Public Company Accounting Oversight Board (United States) ("'PCAOB") and are required 10 be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securi1ie and Exchange Commission and 1hc PCAOB. We conducted our audil in accordance with 1he standards of 1hc PCAOB. Those standards require that we plan and paform the audit 10 obtain reasonable assurance about whether the financial statements a re free of material misstatement, whether due 10 error or fraud. Our audit included perfonning procedures to assess the risks of materi al misstatement of the financial sratemen1s. whether due to error or fraud, and pcrfon11ing procedures thal respond 10 those risks. Such procedures included examining, on a Lest basis. evidence regarding 1hc amounts and disclosures in the financial statements. Our audit also included evaluating 1he accounting principles used and significam estimates made by management. as well as evaluating the overall presentation of 1he tinancial statements. We believe that our audit provides a reasonable basis for our opinion. #### Auditor's Report on Supplemental Information TI1e Computation of Net Capital under Rul e I 5c3-I of lhe Securities and Exchange Commission and Computation of Aggregated Indebtedness under Ruic I 5c3-I of the Securities and Exchange Commission and Supplementa l Schedules Required by Rule l 7a-5 Statement Related to Excmptive Provision (Possession and Control) as of December 3 1, 2023 have been subjected to audit procedures performed in conj unction with lhe audit of the Company's financial statements. The supplcmen1al information 1s the responsibility of the Company's managemen1. Our audit procedures included determining whether the supplemental information reconciles 10 1hc financial statements or 1he underlying accounting and other records, ns applicable, and performing procedures to tes1 the completeness and accuracy of 1he infonna1iun presented in 1he supplemental infom1ation. In forming our opinion on the supplemental information. we evaluated whether 1he supplemcn1al information, including its fonn and content, is presented in conformity with 17 C.F.R. §240. I 7a-5. In our opinion Compu1a1ion of Net Capital under Ruic l 5c3- I of 1hc Securities and Exchange Commission and Computation of Aggregated Indebtedness under Ruic l 5c3- I of the Securities and Exchange Commission and Supplemental Schedules Required by Rule 17a-5 Statement Related to Excmptive Provision (Possession and Control) as of Deccmhcr 3 1, 2023 are fairly staled, in all ma1cnal respects. in relation 10 the financial statements as a whole. We have served as Sentinel Brokers Company, Inc. 's auditor since 2018. Margate, Florida April I. 2024 > ASSURANCE DIMENSIONS CERTIFIED PUBLIC ACCOUNTANTS & ASSOCIATES also **d/b/a** McNAMARA ind ASSOCIATES, PLLC TAMPA BAY: 4920 W Cypress Street, Suite 102 I Tampa, Fl 33607 I Office: 813.443.5048 I Fax: 813.443.5053 JACKSONVILLE: 4 720 Salisbury Road, Suite 223 I Jacksonville, Fl 32256 I Office: 888.410.2323 I Fax: 813.443.5053 ORLANDO: 1 800 Pembrook D1ive, Suite 300 I Orlando, Fl 32810 I Office: 888.410.2323 I Fax: 813.443.5053 SOUTH FLORIDA: 2000 Banks Road, Suite 218 I Margate, Fl 33063 I Office: 7S4.800.3400 I Fax: 813.443.5053 v.,ww 1, LH 1ntrd1m1>n ,,on\ com {6}------------------------------------------------ # Sentinel Brokers Company, Inc. Financial Statements Statement of Financial Condition As of December 31, 2023 | ASSETS | | | |-------------------------------------------------------------------------------------------------------------------------|---|-------------| | Current assets: | | | | Cash | | 2,057,883 | | Receivable from clearing organization | | 61,360 | | Marketable securities at fair value | | 83,555 | | Prepaid expenses and other current assets | | 25,986 | | Total current assets | | 2,228,784 | | Property and equipment, net | | 3,668 | | Total assets | S | 2,232,452 | | LIABILITIES AND STOCKHOLDERS' EQUITY | | | | Current liabilities: | | | | Accounts payable and other accrued liabilities | | 307,801 | | Accrued payroll | | 83,628 | | Due to related parties | | 295,428 | | Securities on margin loan | | 48,280 | | Revolving line of credit, related party | | 280,340 | | Promissory note, related party | | 1,020,444 | | Total current liabilities | | 2,035,921 | | COMMITMENTS AND CONTINGENCIES (Note 5) | | | | Stockholders' equity | | | | Common stock, \$0.00 par, 1,000 shares authorized, 100 shares issued and outstanding on December 31, 2023 | | | | Preferred stock (no series), \$0.00 par, 985 shares issued and outstanding on December 31, 2023 | | | | Series A Preferred stock, \$0.00 par value; 15 shares authorized, 14 shares issued and outstanding on December 31, 2023 | | 1,364,412 | | Additional paid-in capital | | 1,564,724 | | Accumulated deficit | | (2,732,605) | | Total stockholders' equity | | 196,531 | | Total liabilities and stockholders' equity | A | 2,232,452 | | The accompanying notes are an integral part of this financial statement. | | | {7}------------------------------------------------ # Sentinel Brokers Company, Inc. Financial Statements Statement of Operations | S | 625,332 | |---|-------------| | | (1,614,486) | | | 1,016,120 | | | 26,966 | | | | | | 1,182,280 | | | 487,968 | | | 220,352 | | | 138,377 | | | 47,744 | | | 1,262 | | | 53,451 | | | 2,131,434 | | | (2,104,468) | | | | | | 23,114 | | | (38,866) | | | (103,394) | | | | | | (2,223,614) | | | | | | (4.859) | | | (2,228,473) | | | | The accompanying notes are an integral part of this financial statement. {8}------------------------------------------------ #### Sentinel Brokers Company, Inc. Financial Statements Statement or Cash Flows For the Year Ended December 31, 2023 | Cash nows from operating activities: | | | |-------------------------------------------------------------------------------|----|---------------| | 1c1 Loss | s | (2,228,473) | | Adjus1ments to reconcile ncl loss to nel cash used in operatini,: nclivilies: | | | | Dcprccia1ion | | 1,262 | | Provision for credit losses | | 38,866 | | (lncrcasc)/Dccrcase in Current assel | | | | Receivable from clearing organization | | 232,923 | | Prepaid expenses and 01her currcn1 asscls | | (14,666) | | Marketable securities | | (83,555) | | (Decrease) increase 111 Current liabilities: | | | | Accounts payable and other current liabilities | | 353,848 | | Accrued payroll | | (128,603) | | Income taxes payable | | (8 1, 136) | | Ne1 cash used in operating ac1ivities | | ( 1,909.534) | | Cash nows from investing activities: | | | | Purchases of property, plant, and equipment | | {4,359) | | Net cash used III inves1ing activities | | (4,359) | | Cash nows from financing activities: | | | | Payments of promissory note, related party | | (5,582) | | Net cash used 111 financing ac1ivitics | | (5,582) | | Net decrease in cash | | ( 1,91 9,475) | | Cash and cash equivalents at beginning of year | | 3,977 358 | | Cash and cash equivalents at end or year | \$ | 2.057.883 | | Supplemental Disclosure or Cash Flow Information | | | | Suppkmental cash no, infonnation for 1he years ended December 31, 2023: | | | | | | | | Cash paid for interest | s | 109.000 | |----------------------------|----------------------------------------------------------------------------|---------| | Cash paid for income taxes | s | Rl,136 | | | The accompanying no1es arc an integral part of this financial state men I. | | {9}------------------------------------------------ # Sentinel Brokers Company, Inc. Financial Statements Statement of Changes in Stockholders' Equity For the Year Ended December 31, 2023 | | Common Stock | | Preferred Stock | | Series A Preferred
Stock | | Additional
Paid-in | Accumulated | | |----------------------------|--------------|-----------------|-----------------|--------|-----------------------------|-----------|-----------------------|--------------------------------------------------|-------------| | | Shares | Amount | Shares | Amount | Shares | Amount | Capital | Deficit | Total | | Balance, December 31, 2022 | 100 | S S - - - - - - | | | | | | 14 1,364,412 S 1,564,724 S (504,132) S 2,425,004 | | | Net income | | | | | | | | (2,228,473) | (2,228,473) | | Balance, December 31, 2023 | 100 | | | | | 1,364,412 | \$ 1,564,724 | \$ (2,732,605) | \$ 196,531 | The accompanying notes are an integral part of this financial statement. {10}------------------------------------------------ #### **SENTINEL BROKERS COMPANY, INC. NOTES TO FINANCIAL STATEMENTS DECEMBER 31 , 2023** #### I. **SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** #### Of};alli:atio11 Sentinel Brokers Company, Inc. (the "Company") began business on January I, 1996. The Company is primarily engaged in acting as an intermediary facilitating the trading of Municipal Bonds and Preferred Stocks between institutions. The Company has no retail customer base. The Company is a brokerdealer registered with the Financial Industry Regulatory Authority (FINRA) and the Securities Exchange Commission. The Company, as a non-clearing broker, docs not handle customers· funds or securities. There were no liabilities subordinated 10 claims of general creditors during the year ended December 31, 2023. #### Basis of Prcse11tutio11 The accompanying financial statements have been prepared on the accrual basis of accounting, conforming to the predominant practices in the broker-dealer 111dustry and arc in accordance with accounting principles generally accepted in the United States. #### *Re,·euue Recognition* The provisions of the Financial Accounting Standards Board ("FASO") Aceourlling Standards Codification ASC Topic 606. Re,,e1111e from Co111racts ll'ith Cusrume,~' (''Topic 606"), using the modified, cumulative-effect approach wherein the guidance is applied only to existing contracts as of the date of initial application and to new contracts entered into thereufier. The new standard outlines a single comprehensive model for entities 10 depict the transfer of goods or services 10 customers in amounts that reflect the payment to which the company expects to be entitled in exchange for those goods or services. #### Commissio11s The Company has adopted ASC Topic 606, Reve1111efro111 Co11tracts with Customers ("Topic 606"), The Company buys and sells bond and equity securities on behalf of its customers. Each time a customer enters into a buy or sell transaction, the Company charges a commission. Commissions and related clearing expenses are recorded on the trade date (the date that the Company fills the trade order by finding and contracting with a counter pany and confinns the trade with the customer). The Company believes that the perfonnance obligation is satisfied on the trade dale because 1ha1 is when the underlying financial instrument or purchaser is identified and the pricing is agreed upon. #### Proprietary 11e1 trading gai11s 011d losses Proprietary securities transactions in trades arc recorded on the trade date. Profit and loss arising from all securities transactions entered into for the accounl and risk of the Company are recorded on the trade date basis. The net trading gain / (loss) is recorded under revenue in accordance wi1h ASC Topic 940. Financial Services-Brokers and Deniers, since it is not within scope of the new revenue recognition guidance ASC 606 ··Revenue from Cor11racts w11h Customers". #### Risk/e.,s pri11cipul trudi11g gui/L\' and /osse.,· Tiie Company generates revenue on a riskless principal transaction basis or municipal bond trades. The Company records this revenue on a trade dare ba is as securities transactions occur and are posted to Company ledgers monthly when the clearing broker remits its monthly stnlements. The net trading gain / (loss) is recorded under revenue in accordance with ASC Topic 940. Financial Services-Brokers and Deniers, since it is not within scope of 1he new revenue recognition guidance ASC 606 "Revenue from Contracts with Customers. #### Fumifllre. Equipment a11d Leasehold lmprr111,•111e111.,· Furniture and equipment are recorded at cosl. Depreciation is recorded on a straight-line basis nnd accelerated basis over the estimated useful life or the related assets. which range from three to five years. Leasehold improvements arc amortized over the lesser of the economic life of the improvements or the tem1 of the **lease.** ## Co11ce11trll//01Lf ,if Credit Risk ( Financial instruments that potentially subject the Company 10 concentration of credit risk consist primarily of cnsh nnd ca h equivalent and marketable securities. Tiic Company maintains cash balances wirh o commercial bunk ond cosh. money mnrkcl funds ond securities with a brokerage finn. At times amounts wilh the bank exceeded Federal Dcposil Insurance Corporation lrrnits. As of December 31, 2023, the Compnny has opproJ1irnatcly S 1,558,000 cash in excess of FDIC limi1. The amounts at the brokerage fim1 arc covered up to Seeuri1ies Investor Protection Corpomtion ("SIPC") limits. ![](_page_10_Picture_18.jpeg) {11}------------------------------------------------ #### **SENTINEL IJROK.EllS COMPANY, INC. NOTES TO FINANCIAL STATEMENTS DECEMBER 31 , 2023** The responsibility for processing customer activity rests with Hilltop Securities, Inc. ("Hilltop''). The Company's clearing and execution agreement provides that Hilltop's credit losses relating to unsecured margin accounts receivable or the Company's customers are charged back to the Company. In accordance with industry practice, Hilltop records customer transactions on a settlement date basis, which is generally two business days afler the trade date. Hilltop is therefore exposed to risk and loss on these transactions in the event of the customer's inability to meet the terms of its contracts, in which case Hilltop may have to purchase or ell the underlying financial instruments at prevailing market prices in order to satisfy its customer-related obligations. Any loss incurred by Hilltop is charged back 10 the Company. The Company, in conjunction with Hilltop, controls off-balance-sheet risk by monitoring the market va lue and marketing securities to market on a daily basis and by r~quiring adjustments of collateral levels. Hilltop establishes margin requirements and overall credit limits for such activities and monitors compliance with the applicable limits and industry regulations on a daily basis. #### *Estimates* Management of the Company uses estimates and assumptions in preparing financial statement in accordance with accounting principles generally accepted in the United States. Those estimates and assumptions affect the rcponcd amounts of assets and liabilities. the disclosure of contingent assets and liabilities, and the rcponed revenues and expenses and expenses. Actual rcsuhs could vary from the estimates management uses. #### *Casi, Eq11ivale11t.1·* TI1e Company has defined cash equivalents as highly liquid investments, purchased with original maturities of less than three months that are not held for sale in the ord inary course of business. No cash balances subject to withdrawal restrictions or held as compensating balance. #### /11come *Tcues* Effective May 12. 202 1, the Company elected 10 be taxed as an "C" Corporation for federal and state income tax purposes. The Company is subject to federal and state income taxes. The Company accounts for income taxes under the provisions of /\SC 740. "Accounting for Income Taxes," which requires the Company to recognize deferred tax assets and liabilities for the future tax consequences at1ribu1ablc to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. Deferred tax assets :ind liabilities ar~ dctennined based on the difference between the financial statement and tax bases of assets and liabilities as measured by the current enacted tax rates which will be in effect when these differences reverse. Deferred tax expense is the result of changes in deferred tax asset and liabilities. In accordance with ASC 740, Accounting for Income Taxes, the Company is required to disclose unrecognized tax benefits resulting from uncenam tax positions. The Company recognizes the accrual of any interest and penalties 10 recognized tax benefits in income tax expense. At December J I, 2023 1he Company did not have any unrecognized tax benefits or liabilities. No interest or penalties were recognized during the period. The Company operates in the United States and in state and local jurisdictions, and the previous three years remain subject 10 examination by tax authorities. There are presently no ongoing income tax examinations. #### **2. FAIR VALUE** FASB ASC 820 Fair Value Measurement, defines fair value, establishes a framework for measuring fair value. and establishes a hierarchy of fair value inpuls. Fair value is 1he price tha1 would be received 10 sell an asset or paid 10 lrJnsfcr a liabili1y in an orderly 1mnsac1ion between morkct participants at the measurement date. A fair value measuremenl assumes that the transaction 10 sell the asset or transfer the liability occurs m the principal market for 1he asset or liability or, in the absence of a principal markcl, the most advan1ageous market. Valuation techniques that arc consistent with the market, income or cos1 approach, as specified by FASB /\SC 820, arc used 10 measure fair value. ![](_page_11_Picture_14.jpeg) {12}------------------------------------------------ #### **SENTINEL UROK.ERS COMPANY, INC. NOTES TO FINANCIAL STATEMENTS DECEMBER JI, 2023** The fair value hierarchy prioritizes the inputs 10 valuation techniques used to measure fair value into three broad levels: • Level I , defined as observable inputs such as quoted prices for identical instruments in active markets. • Level 2, defined as inputs other than quoted prices in active markets that arc either directly or indirectly observable such as quoted prices for similar instruments in active markets or quoted prices for identical or similar instruments in markets that are not active; and • Level 3, defined as unobservable inputs in which little or no market data exists. therefore requiring an entity to develop its own assumptions, such as valuations derived from valuation techniques in which one or more significant inputs or signifi cant value drivers are unobservable. Fair value is a market-based measure considered from the perspective of a market participant rather than an equity-spcci lie measure. Therefore. even when market assumptions are not readily available, the Company's own observable, fa ir value is determined based on either benchmarking 10 similar instruments or cash flow models with yield curves, bonds, or single-name credit default swap spread and recovery rates as significant inputs. Municipal bonds are generally categorized in level 2 of the fair value hierarchy. Assumptions are set to reflect those that the Company believes market participants would use in pricing the asset or liability at the measurement date. A description of the valuation techniques applied to the Company's major categories of assets and liabilities measured at fair value on a recurring basis follows: *Excha11ge-Tradi11g Equity Securities* arc generally valued based on quoted prices from the exchange. To the extent these securities are acrively rraded valuation adjustments are nor applied, and they arc categorized in level I of the fair va lue hierarchy, otherwise. they are in level 2 of the fair val ue hierarchy. *Exchange-Traded Equity Securities* - *Securities 011 Margi11 l va11* Securities on margin loan are securities sold which arc borrowed from rhc clearing broker (Hilltop). Generally valued based on quoted prices from the exchange. To the extent these securities are actively traded valuation adjustments are 1101 applied, and they are categorized in level I of the fair value hierarchy, otherwise, 1hey are in level 2 of the fair value hierarchy. The following table presents information about the Company's financial assets and liabilities measured at fa ir value as of December 31. 2023 | | Level I | | Level 2 | | Level 3 | | Total | |-----------------------------------------------------------|--------------|----|---------|---|---------|---|----------| | Exchange-Traded Equity Securities Marketable Securities | \$
83,555 | \$ | | s | | s | 83,555 | | Securities on Margin Loan | (48,280) | | | | | | (48,280) | | Total Exchange-Traded Equity Securities, net | 35,275 | | | | | | 35,275 | | Long Positions | 83,555 | | | | | | 83,555 | | Short Positions | (48,280) | | | | | | (48,280) | | Total financial assets and liabilities at fair value, net | \$
35,275 | s | | s | | s | 35,275 | #### 3. **COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS FOR BROKERS AND DEALERS PURSUANT TO RULE** ISCJ-3 The Company is exempt from the provisions of Ruic I 5c3-3 under the Securities Exchange Acl of 1934 pursuant 10 Paragraph (k)(2)(ii). As an introducing broker, the Company clears customer transactions on a fully disclosed basis wilh llilltop. Hilltop carries all of the accounts of such customers and 111ain1ains and prcser\'cs such books and records. #### **4. NET CAPITAL REQUIREMENT** The Company is subject to the Securities and Exchange Commission Unifo rm Net Capitnl Rule ( 15c-3 -I), which requires the mainlenance of minimum nc1 capital and requires that the ratio of aggregate indebtedness to net capital, both ns defined, shall not exceed 15 to I (and that equity capital may nor b~ withdrawn, or cash dividends paid if the resulting net capita l ratio would exceed 10 lo I). At December 3 1, 2023, the Company had ncl capital of approximately *S* 150,235 which was approximately S 14,507 in excess of its required net capitol of\$ I 35,728. The Company had an approximate percentage indebtedness to net capita l of 1355. 16% as of December 3 1, 2023. {13}------------------------------------------------ #### **SENTINEL BROKERS COMPANY, INC. NOTES TO FINANCIAL STATEMENTS DECEMBER 31, 2023** #### **S. COMMITMENTS AND CONTENGICIES** The Company is exposed to various asse11ed and unasserted potential claims encounlered in the nonnal course of business. In the opinion of management. the resolution of these matters will not have a material effect on the Company's financial position or resulls of operations. #### **6. RELATED PARTY DEBT** On May 13, 202 1, and later amended in April 2022, the Company entered into a revolving credit promissory note ("Revolving Note") with Sentinel Brokers. LLC, a related party, secured by all assets of the Company. The revolving note has an aggregale principal balance up to \$3,000,000, lo be funded at request of the Company and incurs interesl at a rate of 6.65%, payable in areas until the principal is paid in full at 1he maturity dale of May 13. 2023. This revolving credit promissory note was later replaced by two promissory notes. The first promissory note ("Note I") was dated March *9,* 2022 in the amount of \$ 150,000 with interest at 8% per annum. maluring on March 9, 2024. The outslanding principal and inleresl as of December 31 , 2023 was \$ 150,000 and S3,067. respectively. The second promissory note ("Note 2") was dated June 17, 2022 in the amount of\$124,723 wilh interest at 8% per annum, maturing on June 17, 2024. The ou1standing principal and interesl as of December 3 1, 2023 was \$124,723 and \$2,550, respectively. On February 27, 2024, \$278,203 of the outstanding balance on the revolving line of credit, related party was convcrlcd lo 39.74 shares oflhe Company's common stock. On Oc1ober 20, 2022 the Company entered inlo a promissory nolc ("Promissory Note") with Senlinel Brokers, LLC, a relaled party, secured by all asse1s of 1he Company. The promissory nole has an aggregate principal balance up 10 \$ 1,000,000, and interest at 8% per annum. The promissory note is due o n demand and if no demand is made, all principal and unaccrued interest is due April 20, 2023, lalcr amended to extend 1hc maturity date lo July 17, 2024. As of December 3 1, 2023 and I here was \$1 ,000,000 of principal and approximately \$20,000 of unpaid interest outstanding. On January 22, 2024. 1he Board of Directors of the Company vo1ed 10 convcn \$ 1.003.557 of the promissory note, related party owed to Senlinel Brokers, LLC. into 143.36 shares of common stock of the Company. #### 7. **EQUITY** In September 2022, the Company amended is Certificate of lncorporalion 10 allow the Company to issue 1,200 shares, wilh no par value. consis1ing of 200 shares of Common Stock, with no par value, 985 shares of Preferred Stock, with no par value, and 15 shares of Series A Preferred Stock, no par value. The Series A Preferred Stock, in the case ofa Company liquidation evcnl shall be cn1i1led to be paid oul of the assels of the Corporation available for dis1ribu1ion to i1s stockholders before any payment shall be made to other holders. The Series A Preferred Stock docs not have voting rights. In 2022, the Company issued 14 preferred shares to Sentinel Brokers, LLC., a related party and majority shareholder, al a face value of \$ 100,000 per share for a to1al of \$ 1,364,412. On January 22, 2024, the Company amended its Ccnificate of Incorporation to increase the total number of authorized shares the Corporation shall have 1he au1hori1y 10 issue by amending lhe number of authorized shares of common slock from 200 shares to 1,000 shares of common stock. Therefore, the Company will have 2,000 shares of capilal stock, of which 1,000 shares arc designated as common stock, no par value and 1,000 shares are designated Preferred S1ock, wilh no par value, of which 15 shares are designated Series A Preferred S1ock. #### **8. INCOME TAXES** The Company recognizes deferred Lax assets and liabilities for the expected fu1ure tax consequences of temporary differences between the financial reponing and lax basis of assets and liabili1ics. Deferred lax assets arc reduced, if deemed necessary, by a va luaiion allowance for !he amount of tax benefi1s which arc not expec1ed 10 be rea lized. The following is a summary of lhc components giving rise 10 the income tax provision (benefit) for the year ended December 3 1, 2023: The expense for income 1axes consists of1hc fol lowing: | Current: | | |-------------------|-------------| | Federal | \$
4,859 | | State | | | To1al | 4,859 | | Deferred: | | | Federal | | | State | | | Total | | | Total Tax Expense | \$
4,859 | | | | {14}------------------------------------------------ #### **SENTINEL BROKERS COMPANY, INC. 'OTES TO FINANCIAL STATEMENTS DECEMBER 31 , 2023** Individual components of deferred tax assets and liabilities arc as follows: | Deferred lncomc Tax Assets | | | |------------------------------------------|----|-----------| | AIR allowance | s | 9,85 1 | | Unrealized Gain/Loss | | (8,940) | | Net Operating Loss & other Carryforwards | | 560,843 | | Gross Deferred Tax Assets | | 56 1,753 | | L.:ss: Valuation Allowance | | (560,823) | | Net DcfctTCd Tax Assets | \$ | 930 | | Defc1Tcd Tax Liabilities: | | | | FixcJ Assets | | (930) | | Total , on-Current Deferred | | (930) | | Net Deferred Income Tax Assets | s | | The Company recognizes interest accrued and penalties related to unrecognized tax benefits in tax expense. During the year ended December 3 1, 2023 the Company recognized no interest and penalties. At December 31 , 2023. the Company has \$2,212,835 in federal net operating loss carryforwards ("NOLs"), available to reduce future taxable income. Under the provisions of the Internal Revenue Code. the net operating losses arc subject to review and possible adjustment by the Internal Revenue Service and stale tax authorities. The Company tiles income tax returns in the U.S. federal jurisdiction and various st:,tcs. The tax years 2020-2023 generally remain open 10 examination by major taxing jurisdictions to which the Company is subjecl. #### **9. RELATED PARTY TRANSACTIONS** As of December 3 1. 2023, the Company was owed approximately \$38.865 from its CEO for items the Company purchased on his behalf. As of December J I, 2023, a provision for loan losses has been placed on this receivable. On May 13, 202 1, and later amended in April 2022, the Company entered into a revolving credit promissory note ("Revolving Note") with Sentinel Brokers, LLC. a related party, secured by all assets o r the Company. The revolving note has an aggregate principal balance up lo S3,000,000, 10 be funded at request of the Company and incurs interest at a rate of 6.65%, payable in areas until the principal is paid in full al the maturity date of May 13. 2023. This revolving credit promissory note was later replaced by two promissory notes. The first promissory note ("Note I") was dated March 9. 2022 in the amount of S 150,000 with interest al 8% per annum, maturing on March 9, 2024. The outstanding principal and interest as of December 31 , 2023 was S 150.000 and SJ.067. respectively. The second promissory note ("Note 2") was dated June 17, 2022 in the amount ofS124,723 with interest at 8% per annum, maruring on June 17, 2024. The outstanding principal and intere t as of December 3 1, 2023 was S 124,723 and S2,550, respectively. On February 27, 2024, \$278,203 of the outstanding balance on the revolving line of credit, related party was converted to 39.74 shares of the Company's common stock. On October 20. 2022 the Company entered *into* a promissory note ("Promissory Note") with Sentinel Brokers. LLC, a related party, secured by all assets of the Company. The promissory note has an aggregate principal balance up to \$1 ,000,000, and interest al 8% per annum. TI,c promissory note i due on demand and if no demand is made, all principal and unaccrued interest is due April 20, 2023, later amended 10 CIC tend the maturity dote to July 17. 2024. ;\s of December 3 1, 2023 and there was S 1,000,000 of principal and approximately S20,000 o r unpaid interest outslllnding. On January 22. 2024, the Board of Directors of the Company voted to convert S 1,003,557 of the promissory note, related party owed 10 Sentinel Brokers, LLC. imo 143.36 shar~s of common stock or the Company. In May of 2023, the Company transacted on 75,000 shares of Lucy Scientific Discovery Inc. (NADQ: LSDI). on bdmlf of LiquidYalue Development Pre. Ltd. ("LYD"), Al December 3 1, 2023, the Company owed LYD \$ 136,607 from the sale of these shnres and is recorded as Due 10 related parties on the accompanying balance sheet. Mr. Heng Fai Ambrose Chan serves on the board of directors of the Company nnd LVD. DSS, Inc., the majority shareholder of the Company 1•ia its subsidiary, D S Securities. Inc .. pcriodi ully throughout 2023 paid certain payroll and benefits related cost of 1he Company. As of December 3 1, 2023, the Company rccordcJ a liability of SI 5R,X2 I which is included in Due 10 related panics on the accompanying balance sheet as of December 3 1, 2023. #### 10. SUBSEQUE T EVE TS On January 22, 2024. the Boa rd of Directors of the Company voted 10 convert \$ 1,003,557 of the promissory note. related party owed to Sentinel Brokers. LLC. 11110 143.36 shares of common stock or the Company. On Fcbntary 27, 2024. S278,203 of the outstanding balance on the revolving line of credit, related party was converted 10 39.74 shares of the Company's common stock. On January 22, 2024, the Company amended its Certificate of lncorporntion 10 increase the total number ofuuthorized shares the Corpomtion shall have the authority 1o issue by amending the number of authorized shares of common tock from 200 shares to 1,000 shares of common stock. Therefore, the Company w,11 have 2,000 shares of capital stock, of which 1,000 shares arc designated as common stock, no par value and 1,000 shares ore designated Preferred Stock, with no par value, of which 15 shares arc dcsign111cd Serie A Preferred Stock. {15}------------------------------------------------ ### Supplementary ## Pursuant to rule 17a-5 of the ### Securities and Exchange Act of 1934 As of and for the Year Ended December 31, 2023 {16}------------------------------------------------ ## Sentinel Brokers Company, Inc. ## Supplemental Schedules Required by Rule 17a-5 # Computation of Net Capital under Rule 15change Commission and Computation and Computation of Aggregated Indebtedness As of and for the year ended December 31, 2023 | Total Stockholders' equity: | | | | |----------------------------------------------------------------------------------------------|--------|---|-----------| | | | | 196,531 | | Deduct stockholders' equity not allowable for Net Capital | | | | | Total capital and allowable subordinated liabilities
DEDUCT: | | | 196,531 | | Non-allowable asset - property, plant and equipment, net | 3.668 | | | | Non-allowable asset - prepaid expenses and other current assets | 25,986 | | | | Total | | | (29,654) | | Net Capital before haircuts on securities positions | | | 166,877 | | Haircuts on securities (computed where applicable pursuant to 15c3-1(f)) | | | (16,642 | | Net Capital | | | 150,235 | | Computation of Basic Net Capital Requirement | | | | | Minimum net capital required (6 2/3% of total aggregate indebtedness) | | S | 135.728 | | Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital | | | | | requirement of subsidiaries computed | | S | 100,000 | | Net capital requirement | | S | 135,728 | | Excess net capital | | S | 14,507 | | Net capital less greater of 10% of total aggregate indebtedness or 120% of net capital | | S | (53,357) | | Computation of Aggregate Indebtedness | | | | | Current liabilities from Balance Sheet | | | 2,035,921 | | Total aggregate indebtedness | | | 2.035.921 | | Percentage of aggregate indebtedness to net capital | | | 1355.16% | | Percentage of debt to debt-equity total computed in accordance with Rule 15c-3-1(d) | | | 0.00% | No material differences exist between the computation included in the Company's corresponding unaudied Form X-17A-5 Parl IIA amended focus report filed in April 1, 2024. {17}------------------------------------------------ #### Sentinel Brokers Company, Inc. S11p11lcmcntul Schedules Required by Ruic 17u-S Statement Related to Excmptivc Provision (Possession and Control) As of and for the ycnr ended December 31 , 2023 Compu1a1ion for the Dc1ennina1ion of the Reserve lnfonnalion Relating lo Possession or Control Requirements and Computation for Dc1ennination of the Reserve Requircmcn1s Pursuam 10 Ruic I 5c3-3 of1he Securities and Exchange Commission. The Company 1s exempl from Rule I 5c3-3 because all cus1omcr 1ransae1ions arc cleared lhrough another broker-dealer on a fully disclosed basis and is exempt from 1he compu13tion of a reserve requirement and the infonna1ion relating 10 lhc possession or control rcquirernenls. The name of the clearing finn is I-fill top Securities. ![](_page_17_Picture_3.jpeg) {18}------------------------------------------------ ### REPORT ON SIPC ASSESSMENT RECONCILIATION #### For lhe year ended December 31, 2023 #### SECURITIES INVESTOR PROTECTION CORPORATION #### **GENERAL ASSESSMENT .FORM** For lhe fiscal year ended 12/3 112023 | | Dctem1ina1ion of"SIPC NET Operating Revenues" and General Assessmcnl for:
MEMBER NAM£
SEC No. | | | |-------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|--------------| | | SENTINEL UllOKERS COMPANY INC
R-49005
For lhe fiscal period beginning 1/1/2023 and endin11. 12/3 1/2023 | | | | | Total Revenue (FOCUS Rcpon - Statement oflncomc (Loss) - Code 4030) | | \$72. 177.00 | | 2 | Additions: | | | | a
b | Total revenues from the securilics business of subsidiaries (cxccpl foreign subsidiaries) and predecessors nol
included above.
ct loss from principal transactions in securities in trading uccou nls. | | | | c
d
e | Net loss from principal transactions in commodilics in lrading accounls.
Interest and dividend expense deducted in detennining item I.
Net loss from management of or panicipalion in the underwriting or dis1ribu1ion of securilics. | \$ 12,230.00 | | | f
g | Expenses other lhan advertising, printing, registration fees and legal fees deduc1cd in delcrmining net pro fil
management of or panicipation in underwriting or distribution of securities.
Net loss from securities in investment accounts. | | | | h | Add lines 2a through 2g. This is your Iota I additions. | | | | 3 | Add lines I and 2h | | S 12.230.00 | | 4 | Deductions: | | SR4,407.00 | | a | Revenues from the distribution of shares of a rcgislered open end investment company or unit investmenl trust, from
the sale of variable annuities, from the business of insurance, from investmenl advisory services rendered lo
registered investment companies or insurance company separale accounts and from transactions in security futures
products. | | | | b | Revenues from commodity transactions. | | | | c | Commissions, Ooor brokerage and clearance paid to other SIPC members in connection with securities transactions. | S76,260.00 | | | d | Reimbursements for postage in connection with proxy solicitalions. | | | | e | Net gain from securities in investment accounts. | | | | f | I 00¾ commissions and markups earned from transactions in (I) cenificates of deposit and (ii) Treasury bills,
bankers acceptances or commercial paper that mature nine months or less from issuance date. | | | | g | Direct expenses of printing, adven ising, and legal fees incurred in connection with olhcr revenue related to 1he | | | | | securities business (revenue defined by Section l 6(9)(L) of the Act). | | | | h | Other revenue not related e ither directly or indirectly lo the securities business. | | | {19}------------------------------------------------ #### REPORT ON SIPC ASSESSMENT RECONCILIATION (continued) For the ycnr ended December 31 , 2023 #### SECURITIES INVESTOR PROTECTION CORPORATION #### **GENERAL ASSESSMENT FORM** For 1he fiscal year ended 12/31/2023 Ded11cri011s in e.\Tess *nfS/00,000* require d11c11111e11rnti<111 | S | a | | To1al in1ercs1 and dividend expense (FOCUS Report - S1a1c111cn1 of Income (Loss) - Code 4075 plus line 2d above) | | | | |---------|---------------------------------|----------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------|------------|--------|-------------| | | b | but not m excess of total in1crest and dividend income | 40% of margin in1ercs1 camed on customers securilics accounls (40% of FOCUS Report - S1a1cmcn1 of Income | | | | | | | (Loss) - Code 3960) | | | | | | | | Enter the greater of line Sa or Sb | | | S0.00 | | | 6 | | | Add Imes 4a through 4h and Sc. This is your total deductions. | | | \$76,260.00 | | 7 | | | Sub1ract lmc 6 from line 3. This is your SIPC Net Operating Revenues. | | | \$8. 147.00 | | 8 | | | Muhiply line 7 by .0015. This is your General Assessment. | | | S12.00 | | 9 | | Current overpayment/credit balance, if any | | | | \$0.00 | | 10 | | General assessment from last filed 2023 SIPC-6 or 6A | | | | Sl,011.00 | | II a | | Ovcrpaymcnl(s) applied on all 2023 SIPC-6 and 6A(s) | | | S0.00 | | | | b | Any 01her overpaymenls applied
All paymcn1s applied for 2023 SIPC-6 and 6A(s) | | S0.00 | | | | | C | | | Sl,011.00 | | | | | d | Add lines 11 a 1hrough 11 c | | | | S 1.01 1.00 | | 12 | | LESSER of line 10 or I Id. | | | | SI .0 11.00 | | 13 a | | Amounl from line 8 | | | S12.00 | | | | b | Amounl from line 9
Amounl from line 12 | | S0.00 | | | | | C | | | S1 ,011.00 | | | | | d | | Sub1rac1 lines 13b and 13c from 13a. This is your assessment balance due. | | | (S999.00) | | 14 | | | Interest (see instructions) for l days late at 20% per annum | | | S0.00 | | IS | | Amount ,·ou owe SIPC. Add lines 13d and 14. | | | | S0.00 | | 16 | | Overpayment/credit carried forward (if applicable) | | | | (\$999.00) | | ~EC No. | | | Desig11uretl Examining Authority | FYE | Mom/, | | | ~-49005 | | | DEA: FINRA | 2023 | Dec | | | | 'MEMBER NAME
MAILING ADDRESS | | SENTINEL BROKERS COMPANY INC | | | | | | | | 102 XANADU PLACE
JUPITER, FL 33477 | | | | Subsidiaric (S) and **predecessors** (P) included in 1hc fonn (give name and SEC number) 0 By checking this box, you cenify 1ha1 you have 1hc uu1hority of 1he SIPC member 10 sign this fom1: 1h01 nil infonnntion in th is fonn i. tni~ nnd comple1e; and *that* on behalf of 1he SIPC member, you arc authorized. and do hereby consent, 10 1he storage and handling by S IPC of the dam in accordance wi1h SIPC's Privacy Policy | SENTINEL BROKERS COMPANY I C | JOSEPII MATIIE\V LAWLESS
(Authorized Signatory) | | |------------------------------|----------------------------------------------------|--| | (Name ofSIPC Member) | | | | 3/1/2024 | jlnwlcss(11)scntinclbrokers.com | | | (Date) | (e-mail address) | | Completion of the .. Authorized Signa1ory" line will be deemed a signature. *Thi,s form a"'/ tht ,issessmt 11t payment are d11e 60 days t1fler the em/ of the jin·11/ J'l!llr.* {20}------------------------------------------------ #### REPORT ON BROKER DEALER EXEMPTION #### For lhe year ended December 31 , 2023 {21}------------------------------------------------ ### REPORT OF INDEPENDENT llEGISTEltEU PUBLIC ACCOUNTING FIRM - EXEMPTION REPORT REVIEW To the S1ockholdcrs of Sentinel Brokers Company, Inc.: We have reviewed managcmcn1 ·s s1a1cmen1s, included in lhc accompanying exemption report, in which (I) Sentinel **Brokers** Company, Jnc. identified 1hc following provisions of 17 C.F.R. *§* I 5c3-3(k) under which Sentinel Drokers Company, Inc. claimed an exemption from 17 C.F.R. §240. I 5c3-3:(k)(2)(i1) (exemption provisions) and (2) Sentinel Brokers Company, Inc. slated 1h01 Senlincl Brokers Company, Jnc. mcl 1he idcnlificd excmplion provisions 1hroughou1 1hc most rcccnl fiscal year withoul exception. Sentinel Brokers Compuny, Jnc.'s management is responsible for compliance wi1h 1he exemption provisions and its statements. TI,c Company is also filing this Excmplion Report because the Company"s other busmcss aclivi1ies contcmplaled by Foo11101e 74 of the SEC Release No. 34-70073 adopling amcndmcnls 10 17 C.F.R. *§* 240. I 7a-5 arc limilcd 10 propriernry lrading. In addition, the Company did not directly or indirectly receive, hold. or othcrwis~ owe funds or sccurilies for or 10 cuslomcrs. other limn money or 01her considcra1ion received and promp1ly 1rans111i1ted in compliance wi1h paragraph (a) or (b)(2) or Ruic l 5c2-4 ancVor funds received and promptly transmitted for effecting transac1ions via subscriplions on a subscription way basis where lhe funds are payable 10 1hc issuer or i1s agenl and 110110 Sentinel Brokers Company, Inc.; did nol carry accounls of or for cus1omcrs; and did nol carry PAB accounls (as defined in Ruic l 5c3-3) 1hroughou1 1hc mosl rcccnl fiscal year withou1 exccp1ion. Sentinel Brokers Com11any, Inc. 's management is responsible for compliance with 1he provisions conlcmplalcd by Foolnolc 74 of SEC Release No. 34-70073 adopting amcndmenlS 10 17 C.F.R. § 240.17a-5 and relaled SEC S1aff Frequently Asked Qucslions and ilS stalements. Our review \\.lS conduc1cd in accordance with 1he s1andards oflhc Public Company Accounling Oversight Board (Uni1cd Stales) and. accordingly, included mquirics and 01her required procedures to obtain evidence aboul Sentinel Drokcrs Company, lnc.'s compliance wi1h 1he exemp1ion provisions. A review ,s substantially less in scope lhan an cxnrnina1ion, 1hc objec1ive of which is the expression ofnn opinion on managcmcn1"s s1atcmenls. Accordingly, we do nol express such an opinion. Based on our review. we arc nol aware of any material modifications 1hat should be made 10 managemem's stalcmcnts referred 10 above for 1hem 10 be fairly staled. in all ma1enal respects, based on the provisions sci forth in paragraph (k)(2){ii) of Ruic l 5c3-3 under 1hc Securities Exchange Acl of 1934 and lhe Company"s 01her business ac1iv1t1es conlcmplated by Footno1e 74 of the SEC Release No. 34-70073 ndopling amcndmcnls 10 17 C.F.R. *§* 240. I 7a-5. and rcla1cd SEC Slaff Frequently Asked Ques1 ions. Assurance Dime11sions Margalc. Florida Apnl I. 2024 > ASSURANCE DIMENSIONS CERTIFIED PUBLIC ACCOUNTANTS & ASSOCIATES **also d/b/a** McNAMARA and ASSOCIATES, PLLC TAMPA BAY: 4920 W Cypress *Street,* Suite 102 I Tampa, Fl 33607 I Office: 813.443.5048 I f ax: 813.443.5053 JACKSONVIUE: 4720 Salisbury Road. Suite 223 I Jacksonville, Fl 32256 I Office: 888.410.2323 I Fax: 813.443.5053 ORLANDO: 1800 Pembrook Drive, Suite 300 I Orlando, Fl 32810 I Office: 888.410.2323 I Fax: 813.443.5053 SOUTH FLORIDA: 2000 Banks Road, Suite 218 I Margate, Fl 33063 I Office: 754.800.3400 I Fax: 813.443.S0S3 ' .•, J ll· I 11 {22}------------------------------------------------ #### Sentinel Brokers Company, Inc. #### Financial Statements and Supplemental Schedules Required by the U.S. Securities and Exchange Commission For the Year-Ended December 31, 2023 April 01, 2024 To Whom it May Concern: # Sentinel Brokers Company, Inc.'s: EXEMPTION REPORT Sentinel Brokers Company, Inc. (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R., 240, 17a-5, "Reports to be made by certain broked-ders"). belief the Company was made as required by 17 C.F.R., 240.17a-S(d) (1) and (4). To the best of its knowledge and belief, the Company states the following: - 1) The Company claimed an exemption from 17 C.F.R., 240.15c3-3 under the provisions of 17 C.F.R., 240.15c3-3( k)(2)(ii): - 2) The Company met the identified exemption provision in 17 C.F.R. 240.15c3-3(k)(2)(ii) throughout the most recent fiscal year without exception. - 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: ( ) proprietary trading and the Company ( 1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers. (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promply transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15e3-3) throughout the most recent fiscal year without exception. I. Joseph Lawless, sweathat, to the best of my knowledge and belief: this Exemption Report is true and correct. Ogg 2 Joseph Jawless, President 19 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.