# BLOOMBERG TRADEBOOK LLC X-17A-5 (2025-02-27) — Broker-dealer annual report - Company: BLOOMBERG TRADEBOOK LLC - Form: X-17A-5 - Filed: 2025-02-27 - Period: 2024-12-31 - Accession: 0001012061-25-000002 - CIK: 1012061 - File #: 8-49219 - Type: Broker-dealer - Material weakness: No - Auditor: PricewaterhouseCoopers LLC - Auditor location: New York, NY - Contact: Christopher Milham - Phone: (212) 617-3382 - Email: cmilham3@bloomberg.net - Website: bloomberg.net - Signed by: Christopher Milham (FINOP) Original filing: https://www.sec.gov/Archives/edgar/data/1012061/000101206125000002/2024tbllcbs.pdf --- {0}------------------------------------------------ # Bloomberg Tradebook LLC Statement of Financial Condition December 31, 2024 {1}------------------------------------------------ UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 | ANNUAL REPORTS | |----------------| | FORM X-17A-5 | | PART Ill | 0MB APPROVAL 0MB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 # SEC FILE NUMBER 8-49219 | | FACING PAGE | | | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|------------------------------------------| | | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | | | | FILING FOR THE PERIOD BEGINNING 01/01/2024 | | AND ENDING 12/31/2024 | | | | MM/DD/YY | | MM/DD/YY | | | A. REGISTRANT IDENTIFICATION | | | | NAME oF FIRM: Bloomberg Tradebook LLC | | | | | TYPE OF REGISTRANT (check all applicable boxes):
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D Check here if respondent is also an OTC derivatives dealer | □ Security-based swap dealer | D Major security-based swap participant | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | 731 Lexington Avenue | | | | | | (No. and Street) | | | | New York | New York | | 10022 | | (City) | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | Christopher Milham | 212-617-3382 | cmilham3@bloomberg.net | | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | | | | Pricewaterhouse Coopers LLC | | | | | | (Name-if individual, state last, first, and middle name) | | | | 300 Madison Avenue | New York | NY | 10017 | | (Address) | (City) | (State) | (Zip Code) | | 10/20/2003 | | 238 | | | l"
of R,gbatraUoo w;th PCAOBJI• appUcable) | | | {PCAOB Reg;~rat;oo Norn bee,• appUcable) | | | FOR OFFICIAL USE ONLY | | | | * Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public
CFR 240.17a-S(e)(l)(ii), if applicable. | accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 | | | **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. {2}------------------------------------------------ #### **OATH OR AFFIRMATION** | | swear (or affirm) that, to the best of my knowledge and belief, the
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~ (a) Statement of financial condition. | | | | | | | | ~ (b) Notes to consolidated statement of financial conditicMY Com!'(lission Expires | | | | | | | D | (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). | | | | | | | D | (d) Statement of cash flows. | | | | | | | D | (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. | | | | | | | D | (g) Notes to consolidated financial statements. | | | | | | | D | (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.l&a-1, as applicable. | | | | | | | D | (i) Computation of tangible net worth under 17 CFR 240.18a-2. | | | | | | | | D U) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. | | | | | | | D | (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.l&a-4, as applicable. | | | | | | | D | (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.1Sc3-3. | | | | | | | 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.l&a-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.l &a-4, as applicable, if material differences exist, or a statement that no material differences | | | | | | | | exist. | | | | | | | D | (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. | | | | | | | !!!!I | (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 240.17a-S or 17 CFR 240.18a-7, as applicable. | | | | | | | D | (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | | | | | | | | ~ (t) Independent public accountant's report based on an examination of the statement of financial condition. | | | | | | | D | (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 | | | | | | | | CFR 240.17a-S, 17 CFR 240.l&a-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.l &a-7, as applicable. | | | | | | | D | (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-S or 17 | | | | | | | | CFR 240.l&a-7, as applicable. | | | | | | - D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.1Sc3-le or 17 CFR 240.17a-12, as applicable. - D (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a 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-5(e}(3} or 17 CFR 240.18a-7(d}(2}, as applicable. {3}------------------------------------------------ # **Bloomberg Tradebook LLC** - **Confidential Index December 31, 2024** # **Page(s)** | Report of Independent Registered Public Accounting Firm | 1 | |---------------------------------------------------------|-----| | Financial Statement | | | Statement of Financial Condition
| 2 | | Notes to the Statement of Financial Condition | 3-8 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) # **Report of Independent Regist ered Public Accounting Firm** To the Board of Directors and Members of Bloomberg Tradebook LLC # *Opinion on the Financial Statement* **-** *Statement of Financial Condition* We have audited the accompanying statement of financial condition of Bloomberg Tradebook LLC (the "Company") as of December 31, 2024, including the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2024 in conformity with accounting principles generally acceple42,465,556 | | Receivables from broker-dealers, net of allowance of \$82,486 | 11,974,902 | | Deferred tax assets | 2,612,792 | | Other assets | 624,344 | | Total assets | \$
57,677,594 | | Liabilities and Members' Equity | | | Liabilities | | | Payables to affiliates | \$
8,651,555 | | Accounts payable and accrued expenses | 7,304,059 | | Other liabilities | 645,893 | | Total liabilities | \$
16,601,507 | | Contingencies, guarantees and other (Note 7) | | | Members' equity | 41,076,087 | | Total liabilities and members' equity | \$
57,677,594 | The accompanying notes are an integral part of this Statement of Financial Condition. {6}------------------------------------------------ # **1. Organization and Nature of Business** Bloomberg Tradebook LLC (the "Company"), a Delaware Limited Liability Company, was established on March 28, 1996, and commenced operations on December 12, 1996. Bloomberg LP ("Bloomberg"), a Delaware Limited Partnership, is the managing member and owns 99% of the Company. Bloomberg T-Book Inc., a Delaware Corporation, is also a member and owns 1 % of the Company, collectively (the "Members"). The Company is a broker-dealer registered with the U.S. Securities and Exchange Commission ("SEC"), is a member of the Financial Industry Regulatory Authority ("FINRA"), the Municipal Securities Rulemaking Board ("MSRB") and the Securities Investor Protection Corporation ("SIPC"). The Company was formed to provide customers of the Bloomberg Financial Information Network ("Bloomberg Professional"), which is owned and operated by Bloomberg, with automated trade and negotiation systems ("Systems") for equities, futures, options, and fixed income transactions. Commissions and fees revenues are earned on customer transactions and for providing customers analytics, technology functionality and support, connectivity services and market place access. The Company has broker arrangements with third parties who provide the execution and clearing services for equity and option securities transactions. The Company, along with three non-US domiciled affiliates, also provides access to a system that facilities specific Chinese fixed income securities transactions. # **2. Significant Accounting Policies** # **Basis of Presentation** The Statement of Financial Condition is presented in conformity with generally accepted accounting principles in the United States of America ("US GAAP"). The U.S. Dollar is the functional and presentational currency of the Company. ## **Use of Estimates** The preparation of Statement of Financial Condition in conformity with US GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the Statement of Financial Condition. Actual results could differ from those estimates. # **Cash and Cash Equivalents** The Company considers all highly liquid investments with original maturities of three months or less to be cash equivalents. The Company maintains cash and cash equivalents with a major, high-credit quality, financial institution. At December 31, 2024, the Company has cash balances at such financial institution that exceeded the Federal Deposit Insurance Corporation ("FDIC") limit of \$250,000. The Company does not expect to incur any loss from the amount in excess of the FDIC limit. #### **Receivables from Broker-Dealers** Receivables from broker-dealers primarily relate to commIssIons. Receivables from brokerdealers relate to contracts with third-party brokers and are recognized when the performance obligation is satisfied, and the Company has an unconditional right to recognize the revenue. {7}------------------------------------------------ # **2. Significant Accounting Policies** (continued) # **Revenue from Contracts with Customers** As part of the Company's agreement with the third-party brokers, trades entered by the Company's customers by way of its trade negotiation and automated actions systems are routed to and serviced by the third-party brokers for execution, clearing and settlement. The Company is entitled to receive Commissions revenue from the volume of executed trades on a trade date basis, which is when the performance obligations are met. In accordance with ASC 606 (Revenue from Contracts with Customers), the Company records these revenues on a net basis (including net of incentives). In addition, the Company provides connectivity services and market access to the customers based on an agreed upon flat rate or a specified rate on the trading volume, with the performance obligations being satisfied over time when earned and on a trade date basis, respectively. #### **3. Fair Value Measurement** ASC 820 (Fair Value Measurements and Disclosure) defines fair value, establishes a framework for measuring fair value, establishes a fair value hierarchy based on the quality of inputs used to measure fair value, and enhances disclosure requirements for fair value measurements. In accordance with ASC 820, the Company has categorized its financial instruments, based on the priority of the inputs to the valuation technique, into a three-level fair value hierarchy. The fair value hierarchy gives the highest priority to unadjusted quoted prices in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). Financial assets and liabilities recorded on the Statement of Financial Condition are categorized based on the inputs to the valuation techniques as follows: - Level 1 Financial assets and liabilities whose values are based on unadjusted quoted prices for identical assets or liabilities in an active market that the Company has the ability to access at the measurement date for identical assets or liabilities. - Level 2 Financial assets and liabilities whose values are based on quoted prices in markets that are not active or model inputs that are observable either directly or indirectly for substantially the full term of the asset or liability. Level 2 inputs include the following: - a. Quoted prices for identical or similar assets or liabilities in active or nonactive markets; and - b. Pricing models whose inputs are observable for substantially the full term of the asset or **liability.** - Level 3 Financial assets and liabilities whose values are based on prices or valuation techniques that require inputs that are both unobservable and significant to the overall fair value measurement. These inputs reflect management's own assumptions about the assumptions a market participant would use in pricing the asset or liability. As required by ASC 820, when the inputs used to measure fair value fall within different levels of the hierarchy, the level within which the fair value measurement is categorized is based on the lowest level input that is significant to the fair value measurement in its entirety. Thus, a Level 3 fair value measurement may include inputs that are observable (Levels 1 and 2) and unobservable (Level 3). {8}------------------------------------------------ # **3. Fair Value Measurement** (continued) A review of fair value hierarchy classifications is conducted on a quarterly basis. Changes in the observability of valuation inputs may result in a reclassification of certain financial assets or liabilities. Cash equivalents consists of a money market fund, which is considered Level 1 financial assets as it is based on a published net asset value for the money market fund. There are no Level 2 or Level 3 financial assets at fair value, nor transfers between levels during the year. US GAAP requires disclosure of the estimated fair value of certain financial instruments that are not measured at fair value on the Statement of Financial Condition and the methods and significant assumptions used to estimate their fair values. The Company has no such financial instruments. #### **4. Receivables from Broker-Dealers** The following is a summary of receivables from broker-dealers at December 31, 2024: | Receivables from Broker-dealers | \$
12,057,388 | |---------------------------------|------------------| | Allowance for credit losses | (82,486) | | Total | \$
11,974,902 | The Company periodically monitors collections on receivables and maintains an allowance for credit losses. The allowance for credit losses is based upon the historical collection experience, specific collection issues that have been identified and the age of the outstanding receivables. The Company is exposed to the concentration of credit risk with one third-party broker who provides services for execution, clearing and settlement of trades. As of December 31, 2024, approximately 36% of receivables was with one third-party broker. #### **5. Income Taxes** The Company is a limited liability company, which is treated as a partnership for tax purposes. As a result, the income or loss of the Company is included in the federal and state tax returns of the respective members of the Company. However, the Company is subject to the New York City ("NYC") Unincorporated Business Tax ("UBT") and the Connecticut ("CT") Pass-Through Entity Tax ("PET"). UBT and PET are accounted for using the asset and liability method pursuant to ASC 740 (Income Taxes). Deferred taxes are recognized for the tax consequences of "temporary differences" by applying enacted statutory tax rates applicable to future year's differences between the Statement of Financial Condition carrying amounts and the tax bases of existing assets and liabilities. The Company has a UBT tax benefit due to its cumulative net operating losses carried forward from prior years. {9}------------------------------------------------ # **5. Income Taxes** (continued) The components of the deferred tax asset are as follows: | Net operating losses | \$
1,466,997 | |-----------------------------------|-----------------| | Section 174 | 1,070,229 | | Loss contingency | 141,835 | | Unrealized losses on FX and other | (76,665) | | Deferred compensation | 4,662 | | Sales tax reserve | 3,134 | | Allowance for credit losses | 2,600 | | | \$
2,612,792 | The deferred tax asset amounting to \$2,612,792 as of December 31, 2024 is the result of temporary differences primarily arising from net operating losses in prior years and capitalization of research and development costs ("U.S. Tax Code Section 174"). The Company has gross loss carryforwards of \$85,602,872, of which \$36,674,944 relate to its New York City UBT apportionment that begin to expire in 2037. Management believes that it is more likely than not that the Company's deferred tax asset will be realized. The effective tax rate varies from the statutory rate of 4.00% NYC and 6.99% CT based on the amount of total income apportioned to NYC and CT. The Company reviews the benefits associated with tax positions periodically, and records benefits based on a recognition threshold of more-likely-than-not to be sustained upon audit by the relevant taxing authority. Management has analyzed the Company's tax positions, and has concluded that no liability should be recorded related to uncertain tax positions taken on returns filed for open tax years or expected to be taken in the Company's current year tax return. The Company is currently not under UBT or PET examinations by the NYC or CT taxing authority. Tax years prior to 2021 are closed to examinations. #### **6. Related Party Transactions** #### License and Services Agreement Bloomberg licenses the use of the Bloomberg Professional Service to the Company. In consideration, the fee paid equals the product of Bloomberg's total cost incurred during the year for maintaining and hosting the Systems and the allocated Tradebook development costs of new software relating to the Systems multiplied by mark-ups (as defined in the license and services agreement in effect). Under this agreement, the license fee is payable unless it reduces the Company's net capital below the minimum net capital required by FINRA. Bloomberg also provides management and administrative services pursuant to this agreement, for which the Company pays a service fee. These services include management and operation of the Systems, administration, management, office space, and other services including, but not limited to, management information systems, telecommunications, accounting and financial services, legal and other support. In consideration, the fee paid equals 110% of the operating costs. In addition, {10}------------------------------------------------ # **6. Related Party Transactions** (continued) Bloomberg supplies employees by the way of secondment, and compensation costs. The Company also incurred travel and entertainment expenses related to these secondees. The Company also pays a service fee to its affiliates for introduction of business and support services received. The service fee paid equals between 105% to 110% of the operating costs incurred by the affiliates in accordance with the respective service agreements between the Company and the affiliates. At December 31, 2024, \$5,031,830 is included in Payables to affiliates on the Statement of Financial Condition related to the license and services agreements. # Terminal Rebate Fees The Company, under agreements with Bloomberg, must pay Bloomberg a terminal rebate fee, equal to credits received by customers on Bloomberg products that are earned based on trade executions, settlements and clearing provided by third-party brokers. At December 31, 2024, \$3,622,725 is included in Payables to affiliates on the Statement of Financial Condition. #### Other Under an amended intercompany agreement, effective January 1, 2023, the Company acts as an agent, in accordance with Rule 15a-6(a)(4)(i), to facilitate access to a non-US domiciled affiliate's trading functionality to participants located in the US. At December 31, 2024, \$3,000 is included in Payable to affiliates on the Statement of Financial Condition. Certain members of the Board of Directors of a Bloomberg affiliate provide consulting and administrative services to Bloomberg, either individually or through professional services firms, of which they are members. As of November 1, 2024, the consulting and administrative services provided to Bloomberg ended. #### **7. Contingencies, Guarantees and Other** ASC 460 (Guarantees) requires the Company to disclose information about its obligations under certain guarantee arrangements. #### Contingencies In the ordinary course of business, the Company is involved, from time to time, in reviews, examinations, investigations, and proceedings (formal and informal) by governmental and selfregulatory organizations regarding the Company's business, operations, reporting, or other matters. The Company recognizes liabilities for contingencies it considers probable and estimable and accrues the related costs it believes are sufficient to meet the exposure, however, the outcome of such items cannot be determined with certainty. In 2024, the Company accrued \$4,500,000 for a matter relating to a regulatory authority's investigation. The amount is included as a component of Accounts payable and accrued expenses on the Statement of Financial Condition as of December 31, 2024. The Company believes that, based on currently available information, the final outcome of this current pending matter will not have a material adverse effect on the Company's financial position. {11}------------------------------------------------ # **7. Contingencies, Guarantees and Other** (continued) #### Indemnifications The Company's liability is limited by the terms stated in the customer agreement. The Company maintains an insurance policy that provides protection against certain losses incurred in connection with the Company's normal business activities. The Company provides representations and warranties to other counterparties in connection with a variety of commercial transactions and has potential exposure for losses caused by the breach of those representations and warranties. The Company's maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Company that have not occurred. However, based on experience, the Company expects the risk of loss to be remote. As such, the Company believes that the fair value of such warranties is not material. #### **8. Segment Information** The Company is engaged in a single line of business and provides customers of Bloomberg Professional, which is owned and operated by Bloomberg, with Systems for equities, futures, options and fixed income transactions. As a result, the Company has only one reportable segment. Commissions and fees revenues are earned on customer transactions and for providing customers analytics, technology functionality and support, connectivity services and market place access. The Company derives revenue from customers in various regions, pays affiliate service fees for introduction of business and support services, and manages the business activities on a consolidated basis. The accounting policies of this segment are the same as those described in the Significant Accounting Policies. The chief operating decision maker ("CODM") is the President and CEO of the Company. The CODM assesses performance for this segment and decides how to allocate resources based on net income. The measure of segment assets is reported on the Statement of Financial Condition as Total assets. #### **9. Regulatory Requirements** As a registered broker-dealer and member of FINRA, the Company is subject to the Securities and Exchange Act's Uniform Net Capital Rule 15c3-1. The Company computes net capital under the alternative method, permitted by the SEC rule, which requires that the maintenance of net capital, as defined, equal to \$250,000. At December 31, 2024, the Company had net capital of \$25,182,090 and excess net capital of \$24,932,090. A computation of the reserve requirement under Rule 15c3-3 is not applicable to the Company as the Company has no possession or control obligations under SEA Rule 15c3-3(b) or reserve deposit obligations under SEA Rule 15c3-3(e) because its business activities are contemplated by Footnote 74 of the SEC Release No 34-70073 adopting amendments to 17.C.F.R. 240.17a-5. #### **10. Subsequent Events** The Company evaluated whether any events or transactions occurred subsequent to the date of its Statement of Financial Condition until February 26, 2025 and determined that there were no additional material events or transactions that would require recognition or disclosure in the Statement of Financial Condition. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.