# ACTINVER SECURITIES, INC. X-17A-5 (2020-03-16) — Broker-dealer annual report - Company: ACTINVER SECURITIES, INC. - Form: X-17A-5 - Filed: 2020-03-16 - Period: 2019-12-31 - Accession: 0001015017-20-000001 - CIK: 1015017 - File #: 8-49311 - Material weakness: No - Auditor: EEPB, P.C. - Auditor location: Houston, TX - Contact: Xavier Maza - Phone: 7138859843 - Signed by: Xavier Maza (President) Original filing: https://www.sec.gov/Archives/edgar/data/1015017/000101501720000001/img016.pdf --- {0}------------------------------------------------ uNrrEDSTATEs SECURITIESANI)EXCHANGECOMMISSION Washington, D.C. 20S49 | OMB APPROVAL | | |--------------------------|-----------------| | OMB Number: | 3235-0123 | | Expires: | August 31, 2020 | | Estimated average burden | | | | onse" 12.00 | SEC FILE NUMBEB 8-49311 ## ANNUAL AUDITED F}EPOFiT FORM X-17A-5 PART Ill |nformationRequiredofBrokeFrsca]nNdGDpeAafeErspursuanttosec|ion|7oft|ie Securities Exchange Act of 1934 and Rule l7a-5 There+nder | REPORT FOR THE PERIOD BEGINN NG01/01/2019 | AND ENDING 12/31 /2019 | | | |-----------------------------------------------------------------------------------|------------------------|--------------------------------------------------|--| | MM/DD/YY | | MM/DD/YY | | | A. REGISTRANT IDENTIFICATION | | | | | NAME oF BROKER-DEALER: Actinver Securities, lnc. | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not i`se P.O. Box No.) | | | | | 5075 Westheim.er, ,Suite 650 | | | | | -.(No alid streel)
H`ou§t^o`n
Texas
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` | | (Zip code) | | | NAME AND TELEPHONE Nuv[BEk OF -PER.s6-ri`.+.6. coi\TTACT iN REGARD TO THls kepoRT | | | | | Xavler Maze | | (713) 885-9843
(Area Code -Telephoiic Number) | | | 8. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT wliose opinion is contained in this Report* | | | | | EEPB, P.C. | | | | | (N`amc ~ i . individtial. slate last, fil.sl. middle name) | | | | | 2950 North Loop west, Suite ` Houston | Te(xas | 77092 | | | (Cl'ty)
(Address) | (Stat!) | (Zip Code) | | | CHECK ONE: | | | | | Gel-tified Public Accountant | | | | | I'ublic Accountant | | | | | Accountant not resident in United States or any of its possessions. | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | \*n:t[t:t'mbsefs°urpepxo:I(nepd"[,,0):afrs°t:'tet:nee::qouf`;aec:se':`ntdh%,.(c!b:mas'%:sr::;,':tdboenca°:%dbba:,'shfeo:r;net°e:e:]f,jft:o'nn`des%nsdeecn,t}o%b2!:Co.a]C7Ca°.t:;;;(n2t) Potential persons who are to respond to the collection of Lnnf,°ersms?i{:fnocr:n5a#Fadyjsnat:jusri:iftyat:,Td°8rfiqBu::enirto°,rneusfg:rq. SEC 1410 (06-02) {1}------------------------------------------------ ### OATH 0R AFFERMATION | Xav'ier Maza | swcai. (or aft`irm) that, to the best of | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | my knowledge and belief the accompanying financial slatelTicnt and supporting scheclulcs pFrtaining to the firm of
Actinver Securities, Inc. | | | of December 31
_ 2019 | , arc triie aiid correct.
I furthe`. swear (or affirm) tllat | | classified solely as that of a cuslomcr, except as r`ollows: | ncilhcr thc company nor any pttrtner, pi.opriotoL principc`l officcr or dit.ectol. has any propr!ptary intei.est in ally account | | | /r
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--;y,¥L-=-ng | | | Sig`nature | | | President | | Notary Public,
is report ** contains (check all applicable boxes):
(a) Facing page.
(b) Statement of Financial Condition.
(c)
Statemeiit of Income (Loss). | | | (d) Statenicnt of changes in Financial Condition.
(e)
Statement of changes in Stocl(holdei-s' Equit.v oi. Partners' cii. Sole Proprietors' Capital.
(D
Statement of changes in L,iabilitics Siibordinated to Claims of creditors.
(g) Computation of Net Capital.
(h) Computation for Determination of Rcscrve Requirements Pursuant to Rule 15c3-3.
(i)
Information Relating to the Possession or Control Requirements l,indei. Rule 15c3-3.
a)
Computation for Detei`minatictn of the Reserve Requirements Uiider Exhibit A of Rule 15c3-3.
conso I i dation . | A Reconciliation, including appropriate explanation of the Computation of Net Capital Uilder Rule 15c3-I and the
(k) A Recoliciliation between the audited and uiiaudited Statcmeiits of Fincincial Condition with respect lo incthods of | | (1)
An Oatli c)r Affirmation`
H
(in) A copy of the SIPC Supplemental Report.
E
**For condil.Ions of conJ`ldenlial lrecllnienl o./. certain porlions ()f lhi`s fill.Ing. see .secl.ic)a 240.17a-5(e)(3). | (n) /\ report describing any material in2tdequacies found lo exist or f`ound t() h€`ve existed since tlie date ol`thc previous audit | {2}------------------------------------------------ # ACTINVER SECURITIES, lNC. FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION DECEMBER 31, 2019 {3}------------------------------------------------ ## CONTENTS | REPORT OF INDEPENDENT REGISTERED PUBLIC FIRM
FINANCIAL STATEMENTS
STATEMENT OF FINANCIAL CONDITION
STATEMENT OF INCOME
STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY
STATEMENT OF CASH FLOWS
NOTES TO FINANCIAL STATEMENTS
SuPPLEMENTAL INFORMATION
COMPUTATION OF NET CAPITAL UNDER RULE 15C3-10F THE SECURITIES
AND EXCHANGE COMMISSION
ACTINVER SECURITIES, INC. EXEMPTION REPORT , "." "".
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM 22
INDEPENDENT ACCOUNTANTS' REPORT ON APPLYING AGREED-UPON
PROCEDURES
RELATED
TO AN
ENTITY'S
SIPC ASSESSMENT
RECONCILIATION
GENERAL ASSESSMENT RECONCILIATION | | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 24-25 | {4}------------------------------------------------ ### \_REPORT OjilNDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Stockholder of Actinver Securities, lnc. ### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Actinver Securities, lnc. as of December 31, 2019, and the related statements of income, changes ln stockholder's equity, and cash flows for the year then ended, and the related notes and supplemental information (collectively referred to as the flnancial statements). In our opinion. the financial statements present fairly, in all material respects, the financial position of Actinver Securitles, lnc. as of December 31, 2019, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. ### Basis for Opinion These financial statements are the responsibility of Actinver Securities, lnc.'s management. Our responslblllty ls to express an opinion on these 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 Actinver Securities, Inc. 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 conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error 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 Information The computation of net capital has been subjected to audit procedures performed in conjunction with the audit of Actinver Securities, lnc.'s financial statements. The supplemental information is the responsibility of Actinver Securities, lnc.'s management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the computation of net capital is fairly stated, in all material respects, in relation to the financial statements as a whole. -t=.E\7r(£-- EEPB We have served as Actinver Securities, lnc.'s auditor since 2013. Houston, TX March 12, 2020 {5}------------------------------------------------ #### .ACTINVER SECURITIES INC. #### STATEMENT OF FINANCIAL CONDITION #### DECEMBER 31, 2019 #### ASSETS | CURRENT ASSETS | | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------| | Cash and cash equivalents
Commissions receivable
Receivable from related parties
Other receivable
Deposits held by clearing brokers, restrictecl
Security deposits
Prepaid and other
Federal income tax receivable
Marketable securities, at fair value
TOTAL CURRENT ASSETS | \$
8,607,169
1,200, 000
3,486,089
140,522
100,000
6,414
191,857
17,156
150.000
13,959,207 | | LONG TERM ASSETS | | | Property and equipment, net
Operating lease, right-of-use-asset
Deferred tax asset
TOTAL LONG TERM ASSETS | 125,115
714,251
28,334
867,700 | | TOTAL ASSETS | | #### LIABILITIES AND STOCKHOLDER'S EQUITY \$ 14,826,907 | CURRENT LIABILITIES | | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------| | Securities sold, not yet purchased, at fair value
Accounts payable and accrued liabilities
Revenue sharing payable
Revenue sharing payable, related party
Related party payable
Commissions payable
Current portion of operating lease liability
State income tax payable | \$
1,682,250
1,403, 370
66,830
465,521
305,982
347,253
213,024
55,434 | | TOTAL CuRRENT UABILITIES | 4,539,664 | | LONG TERM LIABILITIES
Long term operating lease liability
TOTAL LONG TERM LIABILITIES | 569,592
569,592 | | TOTAL LIABILITIES | 5,109,256 | | STOCKHOLDER'S EQUITY
Common stctck,100 shares authorized, issued, outstanding,
\$0.01 par value
Additional paid-in capital
Retained earnings
TOTAL STOCKHOLDER'S EQUITY | 1
1,567,799
8,149,851
9,717,651 | | TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY | \$ 14,826,907 | {6}------------------------------------------------ #### ACTINVER SECURITIES` lNC. ### STATEMENT OF INCOME ### FOR THE YEAR ENDED DECEMBER 31. 2019 #### F`EVENUES | Com in issions
Investment banking income
Interest income
Other income | \$
10,610,845
487,739
358,526
306,632 | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------| | TOTAL REVENUES | 11,763,742 | | EXPENSES | | | Employee compensation and benefits
clearing, execution and commission fees
Revenue sharing expense
Occupancy
Communications
Professional fees
Other expenses | 4,328,707
783,670
1,154,656
235,373
93,246
754,149
1,869,554 | | TOTAL EXPENSES | 9,219,355 | | INCOME BEFORE INCOME TAXES | 2,544,387 | | INCOME TAX EXPENSE | 570,242 | | NET INCOME | \$
1,974,145 | {7}------------------------------------------------ ### ACTINVER SECURITIES, lNC. STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY FOR THE YEAR ENDEDDECEMBER 31. 2019 | | Shares | Common
Stock | ,_ | Additional
Paid-in capital | | Retained
s | | Total | |------------------------------|--------|-----------------|----|-------------------------------|---|-----------------|---|-----------------| | BALANCEATDECEMBEF`31,2018 | 100 | \$
1 | | \$
1,567,799 | | \$
6,175,706 | | \$
7,743,506 | | Net income | | | | | | 1,974,145 | | 1,974,145 | | BALANCE AT DECEMBER 31, 2019 | 100 | | | 1\$1
567,799 | S | 8,149,851 | S | 9,717,651 | {8}------------------------------------------------ #### ALCTINVERSECURITIES,l±±!j± ### STATEMENTOFCASHFLOWLS ### FOR THE YEAR ENDED DECEMBER 31. 2019 | CASH FLOWS FROM OPERATING ACTIVITIES
Net Income | \$ | 1,974,145 | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|-----------------------------------------------------------------------------------------------------------------------------------------| | Adjustments to reconcile net income to net cash
Provided by operating activities:
Depreciation ancl amortization
Unrealized gain on marketable securities | | 49,993
(60,566) | | Net increase or decrease in assets and liabilities
Commissions receivable
Receivable from related party
Other receivable
Prepaid and other
Security deposit
Accounts payable and accrued expenses
Revenue sharing payable
Revenue sharing payable, related party
Related party payable
Commissions payable
Income tax payable
Deferred tax liability | | (315,000)
(3,154,793)
(87,055)
(20,031 )
(249)
569,109
29,185
322,434
125,703
130 ,183
(388,334)
6,764 | | NET CASH USED IN OPERATING ACTIVITIES | _ | (818,512 | | CASH FLOWS FROM INVESTING ACTIVITIES
Purchase of property and equipment
Purchase of marketable securities
Proceeds from sale of securities | | (11,002)
(2,958,564)
1,404,714 | | NET CASH USED IN INVESTING ACTIVITIES | _ | (1,564,852)_ | | CASH FLOWS FROM FINANCING ACTIVITIES | | | | NET DECREASE IN CASH AND
CASH EQUIVALENTS | | (2,383,364) | | CASH AND CASH EQUIVALENTS, beginning of year | | 11,050,533 | | CASH AND CASH EQUIVALENTS, end of year | \$ | 8,667,169 | | SUPPLEMENTAL DISCLOSURE OF CASH FLOW INFORMATION:
Income taxes paid
Interest paid | \$ | 627,000 | {9}------------------------------------------------ ## ACTINVER SECURITIES. INC. NOTES TO FINANCIAL STATEMENTS \_DECEMBER 31 , 2Ono ## NOTE 1: SUMMARY OF SIGNIFICANTACCOUNTING POLICIES ### Oraanization ACTINVER SECURITIES, lNC. (the "Company"), a Delaware corporation, is a wholly-owned subsidiary of Actinver Holdings, lnc. (the "Parent"). The Company is registered as a broker-dealer with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority (FINRA). The Company's management and administrative operations are located in Texas and related sales activities are conducted primarily in Mexico. The Company's customers are primarily individuals and institutions located throughout Mexico. The financial statements have been prepared in accordance with generally accepted accounting principles in the United States of America ("US GAAP"). The Company operates under the provisions of Paragraph (k)(2)(ii) of Rule 15c3-3 of the SEC and, accordingly, is exempt from the remaining provisions of that Rule. Essentially, the requirements of Paragraph (k)(2)(ii) provide that the Company clear all transactions on behalf of customers on a fully disclosed basis with a clearing broker-dealer, and promptly transmit all customer funds and securities to the clearing brokerldealer. The clearlng broker-dealer carries all of the accounts of the customers and maintains and preserves all related books and records as are customarily kept by a clearing broker-dealer. ### Use of Estimates The preparation of financial statements in conformity with US GAAP requires management to make estimates and assumptions that affect the reported amounts of the assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. ## Foreian Currency TransactiQj]§ As an agent, in the normal course of business, the Company enters into securities transactions which are denominated in forelgn currencies, primarily the Mexican peso. Realized and unrealized foreign currency gains and losses on such transactions are recorded in income in the period they are incurred. There is no net realized and unrealized foreign currency loss recorded in 2019. For the purposes of reporting cash flows, the Company has determined that the effect of exchange rate changes on foreign currency transactions is immaterial. ## Cash and Cash E uivalents Money market funds and highly liquid investments, generally government obligations and commercial paper, with an original maturity of three months or less that are not held for sale in the ordinary course of business, if any, are reflected as cash equivalents in the accompanying statement of financial condition and for purposes of the statement of cash flows. From time to time, cash balances exceed federally insured limits at certain financial institutions. The Company has not incurred any losses to date regarding these balances. {10}------------------------------------------------ ## ACTINVER SECURITIES, lNC. NOTES TO FINANCIAL STATEMENTS ## NOTE 1: SUMMARY OF SIGNIFICANTACCOUNTING POLICIES (Confinuec/) ### Receivables During the year, the Company received commissions for various trades of securities. Historically, the Company's management has not experienced losses collecting these commissions and believes the remainder is collectable, thus no allowance has been recorded. ### Marketable Securities Marketable securities and marketable securities sold, not yet purchased held for trading purposes are recorded at fair value. Realized and unrealized gains and losses, determined by the first-in, first-out method, are included in earnings and are presented in other income on the consolidated statements of income. ### Property and Equipmgiv Property and equipment are carried at cost less accumulated depreciation. Depreciation is provided for using the straight-line method over the estimated useful lives of five to seven years. Leasehold improvements are amortized over the lesser of the economic useful life of the improvement or the term of the lease. Maintenance and repairs are charged to operations as incurred. ### Advertising CQde The Company expenses advertising and marketing costs as the expenses are incurred. For the year ended December 31, 2019, the Company did not incur advertising expenses. ### SeiuritvTransactionL£ Securities transactions and related income and expense are recorded on the trade date. Realized gains and losses from sales of securities are computed using the first-in, first-out method. ### Income Taxes The Company files consolidated Federal and combined state and local tax returns with its Parent company. Federal income taxes are calculated as if the company filed as a separate return basis, and the amount of current tax or benefit calculated is either remitted to or received from the Parent, The Company uses the asset and liability method of accounting for income taxes that requires the recognition of deferred tax assets and liabilities for the expected future tax consequences of events that have been recognized in the Company's financial statements. In estimating future tax consequences, aH expected future events are considered other than enactment of changes in the tax law or rates. The Company provides a valuation allowance, if necessary, to reduce deferred tax assets to amounts that are not likely to be realized. The Company's deferred tax asset represents the tax effects of taxable temporary differences in book and tax reporting. The taxable temporary differences consist of depreciation methods and lives and the timing of the deduction for certain expenses. {11}------------------------------------------------ ## ACTINVER SECURITIES, lNC. NOTES TO FINANCIAL STATEMENTS ## NOTE 1: SUMMARY OF SIGNIFICANTACCOUNTING POLICIES (Conf/.nued) ### Lease Accountina ln February 2016, the FASB issued ASC 842, Leases ("ASC 842"), which requires substantially all leases (with the exception of leases with a term of one year or less) to be recorded on the balance sheet using a method referred to as the right-of-use ("ROU") asset approach. The company adopted the new standard on January 1, 2019 using the modified retrospective method described within ASC 842. The adoption did not have a material effect on the Company's beginning retained earnings but did have a material impact on the way leases are recorded, presented and disclosed on the Company's financial statements. The new standard introduces two lease accounting models, which result in a lease being classified as either a "finance" or "operating" lease on the basis of whether the lessee effectively obtains control of the underlying asset during the lease term. A lease is classified as a finance lease if it meets one of five classification criteria, four of which are generally consistent with current lease accounting guidance. By default, a lease that does not meet the criteria to be classified as a finance lease will be deemed an operating lease. Regardless of classification, the initial measurement of both lease types will result in the balance sheet recognition of a ROU asset representing the Company's right to use the underlying asset for a specified period of time and a corresponding lease liability. The lease liability is recognized at the present value of the future lease payments, and the ROu asset equals the lease liability adjusted for any prepaid rent, lease incentives provided by the lessor, and any indirect costs. Leases classified as a finance lease will be accounted for using the effective interest method. The lessee will amortize the ROU asset (generally on a straight-line basis in a manner similar to depreciation) and the discount on the lease liability (as a component of interest expense). Leases classified as an operating lease will result in the recognition of a single lease expense amount that is recorded on a straight-line basis (or another systematic basis, if more appropriate). ### a\_ecent Accounting Pronouncements\_ ln August 2018, the FASB issued ASU 2018-13, Fair Value Measurement (Topic 820): Disclosure Framework-Changes to the Disclosure Requirements for Fair Value Measurement. ASU 2018-13 removes or modifies certain current disclosures, and adds additional disclosures. The changes are meant to provide more relevant information regarding valuation techniques and inputs used to arrive at measures of fair value, uncertainty in the fair value measurements, and how changes in fair value measurements impact an entity's performance and cash flows. Certain disclosures in ASU 2018-13 will need to be applied on a retrospective basis and others on a prospective basis. The Company adopted the provisions of this guidance on January 1, 2020. {12}------------------------------------------------ ## ACTINVER SECURITIES NOTES TO FINANCIAL STATEMENTS ### NOTE 2: REVENUE RECOGNITION ### Revenue Recoanition Revenues are recognized when control of the promised services is transferred to customers, in an amount that reflects the consideration the Company expects to be entitled to in exchange for those services. Revenues are analyzed to determine whether the Company is the principal (i.e., reports revenues on a gross basis) or agent (i.e., reports revenues on a net basis) in the contract. Principal or agent designations depend primarily on the control an entity has over the product or service before control is transferred to a customer, The indicators of which party exercises control include primary responsibility over performance obligations, inventory risk before the good or service is transferred and discretion in establishing the price. ### Commissions Commission revenue represents sales commissions generated by advisors for their clients' purchases and sales of securities on exchanges and over-the-counter ("OTC"), as well as purchases of other investment products. The Company views the selling, distribution and marketing, or any combination thereof, of investment products to such clients as a single performance obligation to the product sponsors. The Company is the principal for commission revenue, as it is responsible for the execution of the clients' purchases and sales, and maintains relationships with the product sponsors. Advisors assist the Company in performing its obligations. Accordingly, total commission revenues are reported on a gross basis. The following table presents the Company's total commission revenue disaggregated by investment product category for the year ended December 31, 2019: | Equities | \$
2,293,261 | |-------------------------|------------------| | Options | 46,927 | | Foreign Exchange | 179,302 | | Mutual Funds | 6,853,178 | | OTC Stocks | 1,113,692 | | Alternative Investments | 124,485 | | Commission Income | \$
10,610,845 | The Company generates two types of commission revenue: sales-based commission revenue that is recognized at the point of sale on the trade date and trailing commission revenue that is recognized over time as earned. Sales-based commission revenue varies by investment product and is based on a percentage of an investment product's current market value at the time of purchase. Trailing commission revenue is generally based on a percentage of the current market value of clients' investment holdings in trail-eligible assets, and is recognized over the period during which services, such as on-going support, are performed. As trailing commission revenue is based on the market value of clients' investment holdings, this variable consideration is constrained until the market value is determinable. {13}------------------------------------------------ ## ACTINVER SECURITIES NOTES TO FINANCIAL STATEMENTS ### NOTE 2: REVENUE RECOGNITION (Continued) The following table presents the Company's sales-based and trailing commission revenues disaggregated by product category: | Sales based | | |---------------------------|------------------| | Equities | \$
2,293,261 | | Options | 46,927 | | Foreign exchange | 179,302 | | Mutual funds | 295,343 | | OTC stocks | 1,113,692 | | Alternative investments | 124,485 | | Total sales-based revenue | 4,053,010 | | Tra"ing | | | Mutual funds | \$
6,557,835 | | Total trailing revenue | 6,557,835 | | Total commission revenue | \$
10,610,845 | Investment banking income includes revenue generated from a private placement offering which is recognized at the closing of the offering. Interest income is earned from margin accounts and cash equivalents. Other income primarily includes firm account revenue ancl gains and losses on firm investments. ## NOTE 3: TRANSACTIONS WITH CLEARING BROKER-DEALER The Company's clearing broker-dealer is a national United States clearing broker-dealer. The agreement with the clearing broker-dealer provides for clearing charges at a fixed rate multiplied by the number of tickets traded by the Company. The agreement also requires the Company to maintain a minimum of \$100,000 as a deposit in an account with the clearing broker-dealer. ### NOTE 4: NET CAPITAL REQUIREMENTS The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule 15c3-1), which requires the maintenance of a minimum amount of net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. Rule 15c3-1 also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1. At December 31, 2019, the Company had net capital and net capital requirements of \$4,090,999 and \$158,697 respectively. The Company's net capital ratio was 0.58 to 1. {14}------------------------------------------------ ## ACTINVER SECURITIES. INC. NOTES TO FINANCIAL STATEMENTS ### NOTE 5: PROPERTYAND EQUIPMENT, NET Property and equipment, net consist of the following at December 31, 2019: | Leasehold improvements | \$
217,578 | |-------------------------------------------|---------------| | Telephone equipment | 74,446 | | Computer equipment | 322,815 | | Office furniture | 235,279 | | Office equipment | 19,493 | | | 869,611 | | Accumulated depreciation and amortization | (744,496) | | Property and equipment, net | \$
125,115 | Depreciation and amortization expense for the year ended December 31, 2019 was \$49,993. ### NOTE 6: RELATED PARTY TRANSACTIONS On January 1, 2005, the Company entered into a revenue sharing agreement (the Agreement) with Actinver Casa de Bolsa, SA de CV ("Actinver Casa de Bolsa"), the sole owner of the Parent. The Agreement requires the Actinver Casa de Bolsa to receive 200/o of commissions charged and received, net of reasonable expenses, to the referred clients accounts for the handling and execution of securities transactions by the Company. The total amount incurred under the Agreement for the year ended December 31, 2019 was \$1,154,656, of which \$465,521 is payable as of December 31, 2019. From time to time the Company advances money to and receives advances from related entities. At December 31, 2019, the Company was owed \$3,486,089 from certain related entities and owed \$305,982 to other related entities. ### NOTE 7: INCOME TAXES The provision for income taxes for the year ended December 31, 2019 is as follows: | Federal | | |----------------------|---------------| | Current tax expense | \$
522,526 | | Deferred tax expense | 6,764 | | | 529,290 | | State | | | Current tax expense | 40,952 | | Tax expense | \$
570,242 | {15}------------------------------------------------ ## ACTINVER SECURITIES NOTES TO FINANCIAL STATEMENTS ### NOTE 7: INCOME TAXES /Cor)£/.nued/ The Company aooountg for uno©rtainty in income taxes in accordance with FA§B ASC 740-10, which prescribes a recognition threshold and measurement attribute for the financial statement recognition and measurement of a tax position taken or expected to be taken in a tax return. The Company did not have unrecognized tax benefits as of December 31, 2019 and does not expect this to change significantly over the next 12 months. The Company recognizes interest and penalties accrued on any unrecognized tax benefits as a component of income tax expense in accordance with ASC 740-10-25. As of December 31, 2019, the Company had not accrued interest or penalties relating to uncertain tax provisions. The Company files consolidated income tax returns with its Parent in the U.S. federal jurisdiction and state of Texas. The Company's federal income tax returns for tax years 2016 and beyond remain subject to examination by the Internal Revenue Service. The Company's Texas Gross Margin tax returns for the tax years 2016 and beyond remain subject to examination by the state of Texas. ### NOTE 8: COMMITMENTS AND CONTINGENCIES ### Security Transactions The Company executes securities transactions on behalf of its customers. If either the customer or the counterparty fails to perform, the Company may be required to discharge the obligation of the nonperforming party. In such circumstances, the Company may sustain a loss if the market value of the security contract is different from the contract value of the transaction. The Company does not expect nonperformance by customers or counterparties. The Company clears all of its securities transactions through its clearing broker on a fully disclosed basis. Pursuant to the terms of the agreements between the Company and the clearing broker, the clearing broker has the right to charge the Company for losses that result from a counterparty's failure to fulfill its contractual obligations. As the right to charge the Company has no maximum amount and applies to all trades executed through the clearing broker, the Company believes there is no maximum amount assignable to this right. At December 31, 2019, the Company has not recorded liabilities with regard to the right. During 2019, the Company did not pay the clearing brokers any amounts related to these guarantees. The Cc>mpany's policy is to monitor its market exposure, customer risk, and counterparty risk through the use of a variety of credit exposure reporting and control procedures, including marking-to-market securities and any related collateral as well as requiring adjustments of collateral levels as necessary. In addition, the Company has a policy of reviewing, as considered necessary, the credit standing of each counterparty and customer with which it conducts business. {16}------------------------------------------------ ## ACTINVER SECURITIES. INC. NOTES TO FINANCIAL STATEMENTS ### NOTE 8: COMMITMENTS AND CONTINGENCIES /Cor}fy'r)Wed/ ### Leaal Matters and Continaencies The Company is subject to claims, lawsuits and other contingencies that arise primarily in the ordinary course of business.The Company has evaluated such claims including consultation with its legal counsel. For remote or reasonably possible claims, no accrual has been recorded or reflected in the accompanying financial statements. When the Company believes the claims are probable and estimable, an accrual is recorded based on the information available and guidance from legal counsel in accordance with FASB ASC 450-20-25. The company has accrued for \$150,000 of contingencies at December 31, 2019. ### Other During the normal course of business, the Company enters into contracts that contain a variety of representation and warranties and which provide general indemnifications. 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 yet occurred. However, based on experience, the Company expects the risk of loss to be remote. ### NOTE 9: LEASES Upon adoption of ASC 842 on January 1, 2019, the Company recognized a ROU asset and a corresponding lease liability based on the present value of then existing operating lease obligation of \$782,616 on the Company's statement of financial condition for its main office spaces, ROU assets represent the Company's right to use an underlying asset for the lease term and lease liabilities represent the Company's obligation to make lease payments arising from the lease. ROU assets and liabilities are recognized at the lease commencement date based on the present value of lease payments over the lease term. For determining the present value of lease payments, we use the discount rate implicit in the lease when readily determinable. As most of the Company's leases do not provide an implicit rate, we use an incremental borrowing rate in determining the present value of lease payments that approximates the rate of interest we would have to pay to borrow on a collateralized basis over a similar term. The ROU measurement was calculated using the fixed scheduled rent payments up to the maturity date of July 2021 for the office space in San Antonio and December 2024 for the office space in Houston. The lease agreement does not contain any material residual value guarantees, renewal options or material restrictive covenants. {17}------------------------------------------------ ## ACTINVER SECURITIES NOTES TO FINANCIAL STATEMENTS ### NOTE 9: LEASES /Cor}f/.r}uedJ The Company determines if an agreement is a lease at inception. A lease is defined as a contract, or part of a contract, that conveys the right to control the use of identified property, plant or equipment (an identified asset) for a period of time in exchange for consideration. ### Lease EXDense The following table presents the lease expenses as of December 31, 2019: | Operating lease expense | \$
196,672 | |--------------------------|---------------| | Short-term lease expense | 10,522 | | Total lease expense | \$
207,194 | ### Other Information The following table presents supplemental cash flow information and the weighted average rate and term for the operating leases: | Cash paid for amounts included in measurement of the lease liability: | | |-----------------------------------------------------------------------|---------------| | Operating cash flows from the operating lease | \$
212,930 | | | | | ROU asset obtained in exchange for the operating lease liability | \$
714,251 | | Weighted-average remaining lease term (years) | 3.5 | | Weighted-average discount rate | 50/o | ### Maturities The maturity of the lease liability on an undiscounted cash flow basis and a reconciliation to the operating lease liability recognized on the statement of financial condition as of December 31, 2019: | 2020
2021
2022
2023
2024
Total lease payments
Less: Interest
Present value of the lease liability | \$
__
\$ | 227,627
192,494
142,056
143,798
144,152
850,127
(67,511)
782,616 | |------------------------------------------------------------------------------------------------------------------------|----------------|---------------------------------------------------------------------------------------| | Current portion of lease obligation
Long-term lease obligation
Total operating lease liability | \$
\$ | 213,024
569,592
782,616 | {18}------------------------------------------------ ## ACTINVER SECURITIES, INQ= NOTES TO, FINANCIAL STATEMENTS ### NOTE 10: DEFINEDCONTRIBUTION EMPLOYEE BENEFITPLAN The Company participates in a qualified 401(k) plan which covers all compensated employees. Employer contributions are in accordance to the "Safe Harbor" provision of the law. For the year ended December 31, 2019, the Company incurred expenses of \$94,930 relating to the plan. ### NOTE 11: SUBORDINATED LIABILITIES The Company had no subordinated liabilities at any time during the year ended December 31, 2019. Therefore, the statement of changes in liabilities subordinated to claims of general creditors has not been presented for the year ended December 31, 2019. ### NOTE 12: MARKETABLESECURITIES The Company accounts for its investments in marketable securities under FASB Accounting Standards Codification Topic 820-10, "Fair Value Measurements". ASC 820-10 provides standards and disclosures for assets and liabilities that are measured and reported at fair value. As defined in ASC 820-10, 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 (exit price). ASC 820-10 requires disclosure that establishes a framework for measuring fair value and expands disclosure about fair value measurements. The statement requires fair value measurements be classified and disclosed in one of the following categories: Level 1: Unadj.usted quoted prices in active markets that are accessible at the measurement date for identical, unrestricted assets or liabilities. An active market for the asset or liability is a market in which transactions for the asset or liability occur with sufficient frequency and volume to provide pricing information on an ongoing basis. Level 2: Measured based upon inputs that are observable, either directly or indirectly, for the asset or liability other than quoted market prlces Included in Level 1. These inputs include: a) quoted prices for similar asset or liabilities in active markets b) quoted prices for identical or similar assets or liabilities in markets that are not active c) inputs other than quoted market prices that are observable and d) inputs that are derived primarily from or corroborated by observable market data by correlation or other means. Level 3: Measured based on unobservable inputs for the asset or liability for which there is little, if any, market activity for the asset or liability at the measurement date. This input includes in:nagement's own assumptions about the assumptions that market participants would use ln pricing the asset or liability. The inputs are developed based on the best information available in the circumstances, which might include management's own data. {19}------------------------------------------------ ## ACTINVER SECURITIES NOTES TO FINANCIAL STATEMENTS ### NOTE 12: MARKETABLE SECURITIES /Con fr.nuedJ As required by ASC 820-10, financial assets and liabilities are classified based on the lowest level of input that is significant to the fair value measurement. The Company's assessment of the significance of a particular input to the fair value measurement requires judgment, and may affect the valuation of the fair value of assets and liabilities and their placement within the fair value hierarchy levels. The following is a description of the valuation methodologies used for assets measured at fair value. There have been no changes in the methodologies used at December 31, 2019: Fore;.gn corporate ant/ govemmenf bonds: Valued using various techniques which may consider recently executed transactions of the issue or comparable Issues, market price quotations (where observable), bond spreads, and fundamental date relating to issuer. The following table summarizes the valuation of the Company's financial instruments by ASC 820-10 pricing levels as of December 31, 2019: | | Quoted prices in
active markets for
identical assets
Level 1 | Other observable
Inputs
Level 2 | | Unobservable
Inputs
Level 3 | | Fair value at
December 31,
2019 | | |---------------------------|-----------------------------------------------------------------------|---------------------------------------|-------------|-----------------------------------|--|---------------------------------------|-------------| | Assets: | | | | | | | | | Argentina | | | | | | | | | Government Bond | S | \$ | 150,000 | S | | \$ | 150,000 | | | | \$ | 150,000 | S | | \$ | 150,000 | | Liabilities:
Argentina | | | | | | | | | Government Bond | | \$ | 1,204,575 | \$ | | \$ | 1,204,575 | | Corporate Bond | | | 4;J7 ,Srf 5 | | | | 4J 7 ,Srf 5 | | | | | | | | | | | | | \$ | 1,682,250 | S | | \$ | 1,682,250 | The bonds mature at various dates, ranging from April 2021 to April 2046. ## NOTE 13: SECURTIES OWNEDANDSECURITIES SOLD, NOTYETPURCHASED Marketable trading securities owned and trading securities sold, not yet purchased at December 31, 2019 consist of the following at fair value: | | Owned | | Sold, Not Yet
Purchased | | | |---------------------------------------------------------|-------|---------|----------------------------|------------------------|--| | Foreign Securities
Government Bond
Corporate Bond | \$ | 150,000 | \$ | 1,204,575
4;J7 ,SJ5 | | | | \$ | 150,000 | \$ | 1,682,250 | | {20}------------------------------------------------ ## ACTINVER SECURITIES, lNC. NOTES TO FINANCIAL STATEMENTS ## NOTE 14: SUBSEQUENTEVENTS Subsequent events were evaluated from January 1, 2020 through March 12, 2020, which is the date the financial statements were available to be issued. No reportable subsequent events were noted. {21}------------------------------------------------ ## S u P P L E M E N TA L INFORMATION {22}------------------------------------------------ #### ACTINVER SECURITIES. INC. #### SUPPLEMENTAL SCHEDULE I #### COMPUTATION OF NET CAPITAL UNDER RULE 15C3-10F THE SECURITIES AND EXCHANGE COMMISSION #### DECEMBER 31. 2019 | Net capital: | | | |-------------------------------------------------------|----|--------------------| | Total stockholder's equity | \$ | 9,717,651 | | Reductions and charges: | | | | Nonallowable assets: | | | | Commissions receivable | | 1,200,000 | | F`eceivable from affiliate | | 3,486,089 | | Security deposit | | 6,414 | | Deferred taxes | | 199,444 | | Federal income tax receivable | | 17,156 | | Other | | 332,379 | | Property and equipment, net | | | | | | | | Total nonallowable assets and charges, net | | 5,366,597 | | Net capital before haircuts on security positions | | 4.351.054 | | | | | | Haircuts on non-security positions | | 260,055 | | Net capital | \$ | 4,090,999 | | Aggregate indebtedness | | | | Accounts payable and accrued expenses | | | | Com missic>ns payable | \$ | 968,320
347,253 | | Revenue sharing payable | | | | Revenue sharing payable, related party | | 66,830 | | Related party payable | | 465,521 | | Deferred tax liability | | 305,982 | | | | 171,110 | | State taxes payable | | | | Total aggregate indebtedness | \$ | 2,380,450 | | Ratic) ctf aggregate indebtedness to net capital | | | | | | 0.58 to 1 | | Computation of basic net capital requirement | | | | Minimum net capital requirement (greater of 6 2/3% of | | | | aggregate indebtedness or \$100,000) | | \$158
697 | | Excess net capital | \$ | 3,932.302 | #### STATEMENT PURSUANT TO PARAGRAPH (d)(4) OF RULE 17a=§ #### Reconciliation of net capital to unaudited FOCUS There ls a difference Of \$ 184,638 between the computation of net capital under net capital SEC Rule 15c3-1 and the corresponding unaudited Focus part 11 A. | Net capital per unaudited schedule | | 3,906,361 | | |------------------------------------|----|-----------|--| | Adjustments: | \$ | | | | Final closing adjustments | | | | | Net capital per audited schedule | \$ | 4,090,999 | | #### STATEMENT OF OMITTED SUPPLEMENTAL DATA The Computation for Determinatic>n of Reserve Requirements Pursuant to Rule 15c3-3 and the Information Relating to Possession or Control Requirements Under Rule 15c3-3 have been omitted because Actinver Securities, lnc. is exempt from the requirements of Rule 15c3-3 under condition (k)(2)(ii). The conditions of the exemption were being complied with as of December 31, 2019 and no facts came to our attention to indicate that the exemption had not been Complled wlth during the fiscal year ended December 31, 2019. {23}------------------------------------------------ #### ACTINVER SECURITIES, lNC. ### EXEMPTION REPORT For the year ended December 31, 2019 I, as a member of management of Actinver Securities, lnc. (the "Company"), am responsible for complying with 17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers" and complying with 17 C.F.R. §240.15c3-3(k)(2)(ii), (the "exemption provisions"). To the best of my knowledge and belief I state the following: (1) I identified the exemption provisions and (2) I met the identified exemption provisions throughout the year ended December 31, 2019 without exception. I, Xavier Maza, affirm that, to the best of my knowledge and belief, this Exemption Report is true and correct. Title: President Date: 3/12/2020 {24}------------------------------------------------ ![](_page_24_Picture_0.jpeg) ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Stockholder of Actinver Securities, lnc. We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Actinver Securities, lnc. identified the following provisions of 17 C.F.R. §15c3-3(k) under which Actinver Securities, lnc. claimed an exemption from 17 C.F,R. §240.15c3-3: (k)(2)(ii) (the "exemption provisions") and (2) Actinver Securities, lnc. stated that Actinver Securities, Inc. met the identified exemption provisions throughout the most recent fiscal year without exception. Actinver Securities, lnc.'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 Actinver Securities, lnc.'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. ELE; Ffa~ Houston, TX March 12, 2020 > 295`u` North Looi} Wec`t. Suite 120il i HC.i!s!oi`. TX 7709? i (i)} 7 i 3 ts?.2 00 'f> I {:t`; 713 622 :i:~>2 J I \`.i..J'`'t eepb ct)in An li`cj¢por`cJcin( i'vlcri`!)cr of OFl{ ln!cm+itioi``1l -22. {25}------------------------------------------------ ![](_page_25_Picture_0.jpeg) ### BEPORT OF INDEPE,N\_DENT REGISTERED PUBLIC ACCOUNTING FIRM # QA!APP±¥lA!GAGREED-UPONPROCERDEU6R6ENsdFLF;STOENDT°ALj±!I±I¥isjire± To the Board of Directors and Stockholder of Actinver Securities, lnc. We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and with the Securities lnvestor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below, and were agreed to by Actinver Securities, lnc. and the SIPC, solely to assist you and the other specified parties in evaluating Actinver Securities, lnc.'s compllance with the applicable instructions of Form SIPC-7 for the year ended December 31, 2019. Actinver Securities, lnc.'s management is responsible for Actinver Securities, lnc.'s SIPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with attestation standards established by the Public Company Accounting Oversight Board (United States) and in accordance with the attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows: - 1) Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement record entries and check copies, noting no differences; - 2) Compared the amounts reported on the audited Form XL17A-5 Part Ill (FOCUS Report) for the year ended December 31, 2019, with the total revenue amounts reported in Form SIPC-7 for the year ended December 31, 2019, noting no differences; - 3) Compared any adjustments reported in Form SIPC-7 with supportlng schedules and working papers, noting no differences; - 4) Proved the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments, noting no differences. We were not engaged to, and did not conduct an examination or review, the objective of which would be the expression of an opinion on or conclusion, respectively, on the Company's compllance with the applicable instructions of the Form SIPC-7 for the year ended December 31, 2019. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. This report is intended solely for the information and use of the specified parties listed above and is not intended to be and should not be used by anyone other than these specified parties. -t-E,PT#¥-.' Houston, TX March 12, 2020 -23- Z95'J Norlll loop \i\'t:i;t. Suilc 1200 : Hl.Just,On. I X 77097 i (,t}} /' ; -j t322 0r71{; I ``(i 713 ft22 :k,:->? / I \t,ww i;ep[t cttm An lIIcjcpcr`d(jr`! WCJt`l)C.r o( D=l{ ln!-3r(``itloi``1l {26}------------------------------------------------ | AMENDED | | | | | | |-----------------|--|--|--|--|--| | •: ` `
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i-:t{}`:``,;ft i | ,At,))i, ,-i | | | \ ' , I '` | | 129 | | ### Actinver Securities lnc. i h{» ir}i'in ii{`(i {ii`t:i `,1.SS`.f!S`Si`ri€`i\§ i`ifi.}i"}f" L`; {!ije (L`{j d€Fy;t, ;i?{€"-(it&``} a':t!8h! tj{ liii,i !{t%€;{ai ¥{>;3i I?Og43;Ft t}``<,i \,'#f'iri`i?}{,i c;fj!?'¥ {}{ {}\AJ {f;i :3 ;)t9i(}fi f)i i\{)i l{`;``;{t Sh{ir` {`! y;h}<^!r`t, ti`r} lt}!t+`S! ? y{?(,Hc; in ;i;? ()€!:^`;L/ ;!{.`{:€5;{';!bit? i){{!(:!` | ් ප්‍රධාන | 도 Dates 로 | Received | Reviewed | | |-----------|---------------------------------|----------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------| | | | | Documenta(101 ---------------------------------------------------------------------------------------------------------------------------------------------------------------- | Forward Copy -------------- | | | Exceptions | | | | | | లాన్ Disposition of exceptions: | | | | {27}------------------------------------------------ ## DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT Amounts tor lne fiscal period beginning 1/1/2019 and ending 12/31/2019 Item NO. 2a. Total r8v8nue (FOCUS Line 12/Pan llA Line 9, Code 4030) 2b. Addi!jons; (1) Tolal rev8nues l/om me secur!lies bLlsifles§ o1 subsidiaries (excepl (oreign subsidiaries) and predecessors not incluoeo above. (2) Net loss lrom principal transactions in securities in trading accoullts. (3) Nel loss lrom principal transac(ions in commodities in lradjng accounts. (4) Interest and a.lvidend expense deducted in determining item 2a. (5) Net loss trom management o( or parlicipation in the underwriting or distribution ol securities. (6) Expenses olher lhan adv8rlising, prinling, registration 'ees and legal (8es decluo(ed in delermining nel prolit lrom managemenl ol or par`ic}pation in underwf iting or dislrit)ulion of securities. (7) Net loss I/om securities in inve§lmenl accoun(s. Total addi`ions 2c. Deductions: (1} Revenues lrom the dislribution o1 shares of a registered open end investmenl company or unit investmenl `Jusl, from the sale o` variable annuilios` f ron the business ol insurance, I/om inves(menl advisory services r8nd8red to r8gislered inveslmenl companies oJ insurance company separate accoun`s, and lrom lfansaclions in securily lu`ures producls. (2} Revenues (ron commodily transactions. (3) Commissions, floo/ brokerage and clearaflce paid (o othe/ SIPC members jn connec`ion with secu/i`ies lransaclioris. (4) Reimbuisements for postage in comection with proxy solici{@tion. (5) Net gain lrom securities in investment accounts. (6) 100¢/a o{ commissions and markups earned lrom transac{jons in (i) ce/liticates o( deposit and (ii) Treasury bills, barikers aoc8plances or commercial paper lha! mature i}ine monlhs or less (ron issuanoe dale, (7) Direct expenses of p/inting adverlising and legal fees incurred in connection y,in o(her reveniie related to the securities business (revenue delined by Seolion 16(9)(L) a( the Act). (8) other revenue not related either clirec`ly or indiieolly to the securilie§ business. (See lns(rLiclion C): (Deductions in excess of \$100,000 require documenlation) I inlefe§t and dividend expense (FOCUS Line 22/PART llA Line t3, e 4075 plus line 2b(4) above) but not in excess o!al inl8rest and dividend incbme. (ii) 40% of margin inteJes( earned on cuslomefs securities accounls (40% of FOCUS line 5, Code 3960). Enter the greater ol line (i) or (ii) Tolal deductions 2d. SIPC Net Operating Revenues 2e, General Assessment @ .0015 56,797 Elimiriate cents \$ 11,763,743 773,050 56,797 7,683,024 \$ 4,080,719 \$6,121 (Io page 1, line 2.A,) Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.