# COMHAR CAPITAL MARKETS, LLC X-17A-5 (2024-02-28) — Broker-dealer annual report - Company: COMHAR CAPITAL MARKETS, LLC - Form: X-17A-5 - Filed: 2024-02-28 - Period: 2023-12-31 - Accession: 0001091947-24-000001 - CIK: 1091947 - File #: 8-51969 - Type: Broker-dealer - Material weakness: No - Auditor: Ryan & Juraska - Auditor location: Chicago, IL - Contact: Mark DeRolf - Phone: 8722050187 - Email: kristen@acsexecution.com - Website: acsexecution.com - Signed by: Mark DeRolf (Chief Compliance Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1091947/000109194724000001/ccm20231231p1.pdf --- {0}------------------------------------------------ **STATEMENT OF FINANCIAL CONDITION AND SUPPLEMENTAL SCHEDULES PURSUANT TO SEC RULE 17a-5(d)** **December 31, 2023 AVAILABLE FOR PUBLIC INSPECTION** {1}------------------------------------------------ # **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** OMB Number: 3235Ͳ0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 OMB APPROVAL # **ANNUAL REPORTS FORM XͲ17AͲ5 PART III** 8-51969 SEC FILE NUMBER | FACING | PAGE | | |--------|------|--| | | | | **Information Required Pursuant to Rules 17aͲ5, 17aͲ12, and 18aͲ7 under the Securities Exchange Act of 1934** | FILING
FOR
THE
PERIOD
BEGINNING | 01/01/2023 | AND
ENDING | 12/31/2023 | | |--------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|--------------------------|-----------------|--------------------------------------------| | | MM/DD/YY | | | MM/DD/YY | | | A.
REGISTRANT | IDENTIFICATION | | | | NAME
OF
FIRM: | Comhar Capital Markets, LLC | | | | | TYPE
OF
REGISTRANT
(check
all
ڦ܆ BrokerͲdealer
܆SecurityͲbased
܆ Check here if respondent is also an OTC derivatives dealer | applicable
boxes):
swap
dealer | ܆MajorsecurityͲbased | swap | participant | | ADDRESS
OF
PRINCIPAL
PLACE
OF | BUSINESS:
(Do
not
use | a
P.O.
box
no.) | | | | 1000 Skokie Blvd, Suite LL33 | | | | | | | (No. and Street) | | | | | Wilmette | | Illinois | | 60091 | | (City) | | (State) | | (Zip Code) | | PERSON
TO
CONTACT
WITH
REGARD | TO
THIS
FILING | | | | | Kristen Murphy | (872) 205-0181 | | | kristen@acsexecution.com | | (Name) | (Area Code – Telephone Number) | | (Email Address) | | | | B.
ACCOUNTANT | IDENTIFICATION | | | | INDEPENDENT
PUBLIC
ACCOUNTANT
Ryan & Juraska, LLP Certified Public Accountants | whose
reports
are | contained
in
this | filing* | | | | (Name – if individual, state last, first, and middle name) | | | | | 141 West Jackson Blvd | Chicago | | Illinois | 60604 | | (Address) | (City) | | (State) | (Zip Code) | | 03/24/2009 | 3407 | | | | | (Date of Registration with PCAOB)(if applicable) | FOR
OFFICIAL | USE
ONLY | | (PCAOB Registration Number, if 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 240.17aͲ5(e)(1)(ii), if applicable. **Persons who are to respond to the collection of information contained in thisform are notrequired to respond unlessthe form displays a currently valid OMB control number.** {2}------------------------------------------------ ![](_page_2_Picture_4.jpeg) - - - - - - - - - - - - - - - - - - - - - - - - - - - {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) **RYAN & JURASKA LLP** # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of Comhar Capital Markets, LLC # **Opinion on the Financial Statement** We have audited the accompanying statement of financial condition of Comhar Capital Markets, LLC (the "Company") as of December 31, 2023, and the related notes (collectively referred to as the "financial statement"). In our opinion, the statement of financial condition presents fairly, in all material respects, the financial position of Comhar Capital Markets, LLC as of December 31, 2023 in conformity with accounting principles generally accepted in the United States of America. ### **Basis for Opinion** This financial statement is the responsibility of Comhar Capital Markets, LLC's management. Our responsibility is to express an opinion on the Company's financial statement 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 Comhar Capital Markets, LLC 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 statement is 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 statement, 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 statement. 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 statement. We believe that our audit provides a reasonable basis for our opinion. ### **Auditor's Report on Supplemental Information** The Supplementary Schedules (the "supplemental information") have been subjected to audit procedures performed in conjunction with the audit of Comhar Capital Markets, LLC's financial statement. The supplemental information is the responsibility of Comhar Capital Markets, LLC's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statement 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 Supplementary Schedules are fairly stated, in all material respects, in relation to the financial statement as a whole. We have served as Comhar Capital Markets, LLC's auditor since 2005. Chicago, Illinois February 27, 2024 {4}------------------------------------------------ # **Assets** | Cash
Receivables from broker-dealer
Accounts receivable
Securities owned, at fair value
Receivable from affiliate
Other assets | \$
839,201
6,628,474
36,135
4,251
6
13,108 | |-----------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------| | | \$
7,521,175 | | Liabilities and Member's Equity | | | Liabilities:
Accounts payable and accrued expenses
Payable to affiliate | \$
1,850,109
220,082
2,070,191 | | Member's equity | \$
5,450,984
7,521,175 | {5}------------------------------------------------ # **Notes to Statement of Financial Condition** # **December 31, 2023** # **1. Organization and Business** Comhar Capital Markets, LLC formerly Global Liquidity Execution Services, LLC (the "Company"), a Delaware limited liability company, was organized on May 16, 1996. On March 1, 2017, the sole member of the Company sold their entire membership interest to ACS Global Holdings, LLC. The Company is a broker-dealer registered with the Securities and Exchange Commission and is a member of FINRA. The Company engages primarily in market-making of exchange-traded equity securities. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ # **2. Summary of Significant Accounting Policies** # Revenue Recognition and Securities Valuation The Company records all securities transactions on a trade date basis. Dividends are recorded on the ex-dividend date and interest is recognized on the accrual basis. Investments in securities and securities sold short are recorded in the statement of financial condition at fair value in accordance with Accounting Standards Codification Topic 820 ("ASC 820") - Fair Value Measurement and Disclosures (see Note 8). ### Use of Estimates The preparation of financial statements in conformity with United States Generally Accepted Accounting Principles ("U.S. GAAP") requires management to make estimates and assumptions that affect the amounts reported in the financial statements and the accompanying notes. Management determines that the estimates utilized in preparing its financial statements are reasonable and prudent. Actual results could differ from these estimates. ### Income Taxes No provision has been made for federal income taxes as the taxable income or loss of the Company is included in the respective income tax returns of the member. In accordance with U.S. GAAP, the Company is required to determine whether its tax positions are more likely than not to be sustained upon examination by the applicable taxing authority, based on the technical merits of the position. Generally, the Company is no longer subject to income tax examinations by major taxing authorities for the years before 2020. Based on its analysis, there were no tax positions identified by management which did not meet the "more likely than not" standard as of and for the year ended December 31, 2023. ### **3. Clearing Agreement** The Company has entered into an agreement with Clear Street, LLC who provides clearing services for the Company for orders placed by the Company's traders. # **4. Credit Concentration** At December 31, 2023, a significant credit concentration of approximately \$6,633,000 is held at the clearing broker. Management does not consider the risk associated with the balances held at the clearing broker to be significant. At December 31, 2023, the Company had a balance in the bank in excess of FDIC limits by approximately \$589,000. Management believes the Company is not exposed to any significant credit risk on cash. {6}------------------------------------------------ **Notes to Statement of Financial Condition, Continued** # **December 31, 2023** # **5. Financial Instruments** Accounting Standards Codification Topic 815 ("ASC 815"), Derivatives and Hedging, requires qualitative disclosures about objectives and strategies for using derivatives, quantitative disclosures about fair value amounts of gains and losses on derivative instruments, and disclosures about credit risk related contingent features in derivative agreements. The disclosure requirements of ASC 815 distinguish between derivatives, which are accounted for as "hedges" and those that do not qualify for such accounting. The Company reflects derivatives at fair value and recognizes changes in fair value through the statement of operations, and as such do not qualify for ASC 815 hedge accounting treatment. The Company does not trade derivative financial instruments. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Securities sold short represent obligations of the Company to deliver the security or underlying instrument and, thereby, create a liability to repurchase the security or underlying instrument in the market at prevailing prices. Accordingly, these transactions result in risk as the Company's satisfaction of the obligations may exceed the amount recognized in the statement of financial condition. The Company is engaged in various trading activities in which counterparties solely include broker-dealers. In the event counterparties do not fulfill their obligations, the Company may be exposed to risk. The risk of default depends on the creditworthiness of the counterparty. It is the Company's policy to review, as necessary, the credit standing of each counterparty. # **6. Financial Instruments – Credit Losses** In June 2016, the FASB issued ASU 2016-13, Financial Instruments – Credit Losses (topic 326) ("ASU 2016-13"). This ASU amends several aspects of the measurement of credit losses on financial instruments, including replacing the existing incurred credit loss model and other models with Current Expected Credit Losses model ("CECL"). Under CECL, the allowance for losses reflects management's estimate of credit losses over the remaining expected life of the financial assets and expected credit losses for newly recognized financial assets, as well as changes to expected credit losses during the period, would be recognized in earnings. Expected credit losses will be measured based on historical experience, current conditions, and forecasts that affect the collectability of the reported amount, and will be generally recognized earlier than under current standards. The standard became effective for the Company for fiscal years beginning after December 15, 2019. The adoption of this standard on January 1, 2020 did not have a material impact on the Company's financial statements. {7}------------------------------------------------ # **Notes to Statement of Financial Condition, Continued** # **December 31, 2023** # **7. Guarantees** Accounting Standards Codification Topic 460 ("ASC 460"), Guarantees, requires the Company to disclose information about its obligations under certain guarantee arrangements. ASC 460 defines guarantees as contracts and indemnification agreements that contingently require a guarantor to make payments to the guaranteed party based on changes in an underlying (such as an interest or foreign exchange rate, security or commodity price, an index or the occurrence or nonoccurrence of a specified event) related to an asset, liability or equity security of a guaranteed party. This guidance also defines guarantees as contracts that contingently require the guarantor to make payments to the guaranteed party based on another entity's failure to perform under an agreement, as well as indirect guarantees of the indebtedness of others. The Company does not trade derivative financial instruments that would fall under the accounting definition of a guarantee. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ ### **8. Fair Value Measurement and Disclosures** ASC 820 defines fair value, establishes a framework for measuring fair value, and establishes a fair value hierarchy which prioritizes the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transaction to sell the asset or transfer the liability occurs in the principal market for the asset or liability or, in the absence of a principal market, the most advantageous market. Valuation techniques that are consistent with the market, income or cost approach, as specified by ASC 820, are used to measure fair value. The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels: - x Level 1 inputs are quoted prices (unadjusted) in active markets for identical assets or liabilities the Company has the ability to access. - x Level 2 Inputs are inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either directly or indirectly. - x Level 3 are unobservable inputs for the asset or liability and rely on management's own assumptions that market participants would use in pricing the asset or liability. The unobservable inputs should be developed based on the best information available in the circumstances and may include the Company's own data. {8}------------------------------------------------ **Notes to Statement of Financial Condition, Continued** # **December 31, 2023** # **8. Fair Value Measurement and Disclosures, continued** The availability of valuation techniques and observable inputs can vary from investment to investment and is affected by a wide variety of factors, including, the type of investment, whether the investment is new and not yet established in the marketplace, and other characteristics particular to the transaction. To the extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgement. Those estimated values do not necessarily represent the amounts that may be ultimately realized due to the occurrence of future circumstances that cannot be reasonably determined. Because of the inherent uncertainty of valuation, those estimated values may be materially higher or lower than the values that would have been used had a ready market for the investments existed. Accordingly, the degree of judgement exercised by the Company in determining fair value is greatest for investments categorized in Level 3. In certain cases, the inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement in its entirety falls is determined based on the lowest level input that is significant to the fair value measurement. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ The Company values its positions based on the following principles and methods of valuation: Equities securities listed on an exchange and which are freely transferable are valued at their last sales price on such exchange on the date of valuation. To the extent these securities are actively traded, and valuation adjustments are not applied, they are categorized in Level 1 of the fair value hierarchy. Preferred, other equities, warrants, and fixed income securities traded on inactive markets or valued by dealer quotations or an alternative pricing source or model supported by observable inputs are classified within Level 2. The following table presents the Company's assets measured at fair value at December 31, 2023: | Assets | Level 1 | Level 2 | Total | | |------------------|----------|----------|-------------|--| | Securities owned | | | | | | Stocks | \$ 2,556 | \$
- | \$
2,556 | | | Warrants | \$
- | \$ 1,695 | \$
1,695 | | | Total | \$ 2,556 | \$ 1,695 | \$
4,251 | | At December 31, 2023 the Company held no Level 3 investments. {9}------------------------------------------------ # **Notes to Statement of Financial Condition, Continued** # **December 31, 2023** # **9. Related Party Transactions** The Company utilizes an entity affiliated through common ownership for technology services. At December 31, 2023, the Company owed GLP \$220,082 which is presented as a payable to affiliate on the statement of financial condition. Additionally, the Company paid ACS Execution Services, LLC ("ACS"), an entity affiliated through common ownership, for execution and trading related fees, which is included in commissions, execution, clearing and regulatory fees in the statement of operations, and received payment for make/take liquidity credits, which is included in trading gains, net in the statement of income. At December 31, 2023, ACS owed the Company \$6 which is presented as receivable from affiliate on the statement of financial condition. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ # **10. Employee Benefit Plan** The Company has established a 401(k) plan for qualified employees. The company matches a portion of employee contributions and may elect to make further discretionary contributions to the plan, subject to certain limitations as set forth in the plan agreement. # **11. Net Capital Requirements** The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15(c)3-1). Under this rule, the Company is required to maintain "net capital" equal to the greater of \$1,000,000 or 6 and Ҁ% of "aggregate indebtedness", as defined. At December 31, 2023, the Company had net capital and net capital requirements of \$5,437,081 and \$1,000,000, respectively. ### **12. Subsequent Events** The Company's management has evaluated events and transactions through February 27, 2024, the date the financial statements were available to be issued, noting no material events requiring disclosure in the Company's financial statements. {10}------------------------------------------------ # **SUPPLEMENTAL SCHEDULES** {11}------------------------------------------------ #### **FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT PART III** | | COMHAR CAPITAL MARKETS, LLC
BROKER OR DEALER: | | | as of December 31, 2023 | | |-----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|------------------------------------------------------------------------------|-------------------------|------------------| | | COMPUTATION OF NET CAPITAL | | | | | | 1. | Total ownership (from Statement of Financial Condition- Item 1800) | | | \$
5,450,984 | [3480] | | 2. | Deduct: Ownership equity not allowable for net capital | | | | [3490] | | 3. | Total ownership equity qualified for net capital | | | \$
5,450,984 | [3500] | | 4. | Add:
A. Liabilities subordinated to claims of general creditors allowable in computation of net capital
B. Other (deductions) or allowable subordinated liabilities | | | | [3520]
[3525] | | 5. | Total capital and allowable subordinated liabilities | | | \$
5,450,984 | [3530] | | 6. | Deductions and/or charges:
A. Total non-allowable assets from Statement of Financial Condition
(Other assets)
B. Secured demand note deficiency
C. Commodity futures contract and spot commodities proprietary
capital charges
D. Other deductions and/or charges | \$
13,265 | [3540]
[3590]
[3600]
[3610] | \$
(13,265) | [3620] | | 7. | Other additions and/or allowable credits (List) | | | - | [3630] | | 8. | Net Capital before haircuts on securities positions | | | \$
5,437,719 | [3640] | | 9. | Haircuts on securities (computed, where applicable pursuant to 15c3-1(f)):
A. Contractual securities commitments
B. Subordinated securities borrowings
C. Trading and Investment securities
1. Exempted securities
2. Debt securities
3. Options
4. Other securities
D. Undue concentration
E. Other (List) | 638 | [3660]
[3670]
[3735]
[3733]
[3730]
[3734]
[3650]
[3736] | \$
(638) | [3740] | | 10. | Net Capital | | | \$
5,437,081 | [3750] | Non allowable assets consist of the following: | Non allowable accounts receivable | \$
157 | |-----------------------------------|--------------| | Other assets | 13,108 | | Total | \$
13,265 | **Note: There are no material differences between the audited computation of net capital and that per the Company's unaudited FOCUS report as filed.** {12}------------------------------------------------ | | BROKER OR DEALER:
COMHAR CAPITAL MARKETS, LLC | as of December 31, 2023 | | |---------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------|--------| | | COMPUTATION OF BASIC NET CAPITAL REQUIREMENT | | | | Part A | | | [3756] | | 11. | Minimum net capital required (6-2/3% of line 19) | \$
138,013 | | | 12. | Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital
requirement of subsidiaries computed in accordance with Note (A) | \$
1,000,000 | [3758] | | 13. | Net capital requirement (greater of line 11 or 12) | \$
1,000,000 | [3760] | | 14. | Excess net capital (line 10 less 13) | \$
4,437,081 | [3770] | | 15. | Excess net capital at 1000% (line 10 less 10% of line 19) | \$
4,237,081 | [3780] | | | COMPUTATION OF AGGREGATE INDEBTEDNESS | | | | 16. | Total A.I. liabilities from Statement of Financial Condition | \$
2,070,191 | [3790] | | 17. | Add: | | | | | [3800]
A. Drafts for immediate credit
B. Market value of securities borrowed for which no equivalent value | | | | | [3810]
is paid or credited | | | | | C. Other unrecorded amounts (List)
[3820] | | [3830] | | 18. | Deduct: Adjustment based on deposits in Special Reserve Bank Accounts (15c3-1(c)(1)(vii)) | | [3838] | | 19. | Total aggregate indebtedness | \$
2,070,191 | [3840] | | 20. | Percentage of aggregate indebtedness to net capital (line 19 ÷ by line 10) | 38.08 | [3850] | | 21. | Percentage of debt to debt-equity total computed in accordance with Rule 15c3-1(d) | | [3860] | | | COMPUTATION OF ALTERNATE NET CAPITAL REQUIREMENT | | | | Part B
22. | 2% of combined aggregate debit items as shown in Formula for Reserve Requirements pursuant
to Rule 15c-3-3 prepared as of the date of the net capital computation including both brokers
or dealers and consolidated subsidiaries debits | | [3870] | | 23. | Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital
requirement of subsidiaries computed in accordance with Note (A) | | [3880] | | 24. | Net capital requirement (greater of line 22 or 23) | | [3760] | | 25. | Excess net capital (line 10 less 24) | | [3910] | | 26. | Net capital in excess of:
5% of combined aggregate debit items or \$300,000 | | [3920] | | NOTES:
A. | The minimum net capital requirement should be computed by adding the minimum dollar net capital requirement of the reporting broker dealer and,
for each subsidiary to be consolidated, the greater of:
1.
Minimum dollar net capital requirement, or | | | 2. 6-2/3% of **aggregate** indebtedness or **2% of aggregate debits if alternative method is used.** B. Do not deduct the value of securities borrowed under subordination agreements of secured demand notes covered by subordination agreements not in satisfactory form and the market values of memberships in exchanges contributed for use of company (contra to item 1740) and partners securities which were included in non-allowable assets. C. For reports filed pursuant to paragraph (d) of Rule 17a-5, respondent should provide a list of material non-allowable assets. {13}------------------------------------------------ **Information Relating to the Possession or Control Requirements Under Rule 15c3-3** **December 31, 2023** The Company did not handle any customer cash or securities during the year ended December 31, 2023 and does not have any customer accounts. **\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_** # **COMHAR CAPITAL MARKETS, LLC** # **Information for Determination of Reserve Requirements Under Rule 15c3-3a** **December 31, 2023** The Company did not handle any customer cash or securities during the year ended December 31, 2023 and does not have any customer accounts. **\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_** Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.