# CALLAWAY FINANCIAL SERVICES, INC. X-17A-5 (2022-03-07) — Broker-dealer annual report - Company: CALLAWAY FINANCIAL SERVICES, INC. - Form: X-17A-5 - Filed: 2022-03-07 - Period: 2021-12-31 - Accession: 0001111120-22-000001 - CIK: 1111120 - File #: 8-52474 - Type: Broker-dealer - Material weakness: No - Auditor: Jennifer Wray CPA PLLC - Auditor location: Sugar Land, TX - Contact: Maria Dembski - Phone: 954-707-0586 - Email: david@synerysecurities.com - Website: synerysecurities.com - Signed by: Maria Dembski (CFO) Original filing: https://www.sec.gov/Archives/edgar/data/1111120/000111112022000001/callaway2021.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** # **ANNUAL REPORTS FORM X-17A-S PART** Ill | OMS APPROVAL | | |---------------------------|--| | 0MB Number, 3235-0123 | | | Expires: Oct. 31, 2023 | | | Estimated average burden | | | hours per response:
12 | | | | | | SEC FILE NUMBER | |-----------------| | 8-52474 | **FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and lSa-7 under the Securities Exchange Act of 1934** FILING FOR THE PERIOD BEGINNING **01/01/2021** MM/DD/YY AND ENDING \_1\_2\_/3\_1\_/2\_0\_2\_1 \_\_ \_ MM/DO/YY **A. REGISTRANT IDENTIFICATION** NAME OF FIRM: \_\_\_ C\_a\_l\_la\_w\_a...;;..y\_F\_i\_na\_n\_c\_ia\_l\_S\_e\_r\_v\_ic\_e\_s,\_l\_n\_c\_. \_\_\_\_\_\_\_\_\_ \_ TYPE OF REGISTRANT (check all applicable boxes}: 181Broker-dealer D Security-based swap dealer D Major security-based swap participant 0 Check here if respondent ls also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: {Do not use a P.O. box no.) 2245 Texas Dr. Suite 300 ( No. and Street) Sugar Land TX (City) (State) PERSON TO CONTACT WITH REGARD TO THIS FILING 77479 (Zip Code) James David Jones (Name) 954-707-0586 (Area Code - Telephone Number) david@synerysecurities.com (Email Address) **B. ACCOUNTANT IDENTIFICATION** INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\* Jennifer Wray CPA PLLC (Name - if individual, state last, first, and middle name) 800 Bonaventure Way, Suite 168 Sugar Land TX (Address) (City) (State) 11/30/2016 6328 **FOR OFFICIAL USE ONLY** 77479 (Zip Code) • Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(l)(il), if applicable. **Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | I, | Maria Dembski
swear (or affirm) that, to the best of my knowledge and belief, the | | | | | |----------|-------------------------------------------------------------------------------------------------------------------------------------|--|--|--|--| | | fi?jndal rrsort 3rtaining to the firm of
CaHaway Financial Services, Inc.
, as of | | | | | | | 2~1s true and correct. I further swear (or affirm) that neither the company nor any
ecem er | | | | | | | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely | | | | | | | as that of a customer. | | | | | | | Y11P1,,,/c .
CHVENNE MEYERS
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| | | | | | | ·aria Dembski CFO | | | | | | | | | | | | | | | | | | | | | | | | | | | | This fifing** c
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:JNMMlnblicable boxes): | | | | | | l2ia | (a) Statement offinancial condition. | | | | | | D | (b) Notes to consolidated statement of financial condition. | | | | | | t!9 | (c) Statement of income (loss) or, ifthere is other comprehensive income in the period(s) presented, a statement of | | | | | | | comprehensive income (as defined in§ 210,1°02 of Regulation S-X). | | | | | | [81 | {d) Statement of cash flows. | | | | | | | (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. | | | | | | [81
D | (fl Statement of changes in liabilities subordinated to claims of creditors. | | | | | | | | | | | | | | ~ (g) Notes to consolidated finan.cial statements. | | | | | | | ~ (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. | | | | | | | D
(i) Computation of tangible net worth under 17 CFR 240.18a-2. | | | | | | | ~ (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.1Sc3-3. | | | | | | | D
fk) 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 240.18a-4, as applicable. | | | | | | | □ (l) Computation for Determination of PAB Requirements under Exhibit A to§ 240.1Sc3-3. | | | | | | | (m) Information relating to possession or control requirements for customers under 17 CFR 240.1Sc3-3.
[81 | | | | | | | □ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR | | | | | | | 240.15c3-3(p)(2) or 17 CFR 240,lBa-4, as applicable. | | | | | | | ~ (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.lBa-1, or 17 CFR 240.18a-Z, as applicable, and the reserve requirements under 17 | | | | | | | CFR 240. 15c3-3 or 17 CFR 240.18a-4, as appli.cable, 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. | | | | | | | ~ (q) Oath or affirmation in accordance with 17 CFR 240.l?a-5, 17 CFR 240.17a-12, or 17 CFR 240.lSa-7, as applicable. | | | | | | | D (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | | | | | | t!9 | (s) Exemption report in accordance with 17 CFR240.17a-5 or 17 CFR 240.lSa-7, as applicable. | | | | | | | D (t) Independent public accountant's report based on an examination of the statement of financial condition. | | | | | | {!9 | (u) Independent public account,mt's report based on an examination of the financial report or financial statements under 17 | | | | | | | CFR 240.17a-S, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. | | | | | | | D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 | | | | | | | CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | | | | | | | ~ (w) Independent public accountant's report based on a review of the ex.emption report under 17 CFR 240.17a-5 or 17 | | | | | | | CFR240.18a-7, as applicable. | | | | | | | D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-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.l 7a-12(k).
____________________________________ | | | | | | | □ (z) Other:
_ | | | | | *"\*To request confidential treotment of certain portions of this filing,* see 17 CFR 240.17a-5(e)(3} or 17 CFR 24D.18a-7(d)(2}, *as applicable.* {2}------------------------------------------------ #### CALLA WAY FINANCIAL SERVICES, INC. #### Financial Statements and Supplemental Schedules For the Year Ended December 31, 2021 {3}------------------------------------------------ #### **CONTENTS** | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 3 | |-----------------------------------------------------------------------------------------------------------------|-----------| | Financial Statements | | | Statement of financial condition | 4 | | Statement of Income | 5 | | Statement of changes in stockholder's equity | 6 | | Statement of cash flows | 7 | | Notes to financial statements | 8 -
11 | | Supplemental information pursuant to Rule 17a-5 | | | Schedule I: Computation of Net Capital | 12 | | Schedule II: Statement of Computation for Determination of Reserve
Requirements | 13 | | Schedule III: Statement oflnformation Relating to the Possession or Control
Requirements Under Rule 15c3-314 | 14 | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 15 | | EXEMPTION REPORT | 16 | 2 {4}------------------------------------------------ # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the member of Callaway Financial Services Inc #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Callaway Financial Services Inc as of December 31, 2021, the related statements of income, changes in member's equity, and cash flows for the year ended December 31, 2021, and the related notes and schedules. In our opinion, the financial statements present fairly, in all material respects, the financial position of Callaway Financial Services Inc as of December 31, 2021 and the results of its operations and its cash flows for the year ended December 31, 2021 in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** These financial statements are the responsibility of Callaway Financial Services Inc's management. Our responsibility is to express an opinion on Callaway Financial Services Inc 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 Callaway Financial Services 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 supplementary information contained in Schedules I, II & Ill have been subjected to audit procedures performed in conjunction with the audit of Callaway Financial Services Inc financial statements. The supplemental information is the responsibility of Callaway Financial Services Inc 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 Supplementary schedule is fairly stated, in all material respects, in relation to the financial statements as a whole. Jennifer Wray CPA PLLC We have served as Callaway Financial Services Inc's auditor since 2019. Sugar Land, Texas March 3, 2022 3 {5}------------------------------------------------ # **CALLAWAY FINANCIAL SERVICES, INC. Statement of Financial Condition December 31, 2021** # **ASSETS** | Cash
Accounts receivables
Prepaid expenses
Interactive Brokers | \$
2,117
1,198
6,789
37,120 | | |-------------------------------------------------------------------------|-----------------------------------------|--| | TOTAL ASSETS | \$
47,224 | | | LIABILITIES AND STOCKHOLDER'S EQUITY | | | | Liabilities | | | | Accounts payable | 1,069
\$ | | | Commission payable | 694
\$ | | | Other Liability | 8,391
\$ | | | TOTAL LIABILITIES | 10,154 | | | Stockholder's Equity | | | | Common stock, 100,000,000 shares
authorized with \$.01 par value, | | | | 20,000 shares issued and outstanding | 200 | | | Additional paid-in capital | 41,785 | | | Dividends paid | (56,000) | | | Retained Earnings | 24,413 | | | TOTAL STOCKHOLDER'S EQUITY | 37,070 | | | TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY | 47,224
\$ | | {6}------------------------------------------------ # **CALLA WAY FINANCIAL SERVICES, INC. Statement of Income Year Ended December 31, 2021** #### **Revenue** | Commission -
Trading | 3,315
\$ | |------------------------------------|--------------| | 12B-1 Fees | 44,338
\$ | | Commission -
Mutual Funds | 11,194
\$ | | Commission -
Variable Annuity | 37,656
\$ | | Total Interest | 235
\$ | | Other Fees from Trading Services | 95,270
\$ | | Other Income | 1,541
\$ | | TOTAL REVENUE | 193,549 | | Expenses | | | Compensation and related costs | 104,232 | | Clearing charges | 24,913 | | Communications | 1,200 | | Professional fees | 7,493 | | Regulatory fees | 16,106 | | Other expenses | 5,635 | | TOTAL EXPENSES | 159,578 | | Net Income before income taxes | 33,971 | | Income taxes | 7,300 | | Non Cash Items | | | NET Income | 26,671 | | See notes to financial statements. | | {7}------------------------------------------------ ## **CALLA WAY FINANCIAL SERVICES, INC. Statement of Changes in Stockholder's Equity Year Ended December 31, 2021** | | Common
Shares
Issued | Stock | Common | Additional
Paid-in
Capital | Accumulated | Total | | |-----------------------|----------------------------|-------|--------|----------------------------------|--------------|--------------|---| | Balances at | | | | | | | | | December 31, 2020 | 20,000 | \$ | 200 | \$ 21,785 | \$
24,413 | \$
46,398 | | | | | | | \$ (36,000) | | \$ (36,000) | | | Net Income | | | | | \$
26,671 | \$
26,671 | | | Net Income Adjustment | | | | | | | 1 | | Balances at | | | | | | | | | December 31, 2021 | 20,000 | | 200 | \$ (14,215) | \$
51,084 | \$
37,070 | | {8}------------------------------------------------ #### **CALLAWAY FINANCIAL SERVICES, INC. Statement of Cash Flows Year Ended December 31, 2021** #### **OPERATING ACTNITIES** | Net Income | | 26,671 | |-----------------------------------------------------------------------|----------------------|---------| | Adjustments to reconcile net income to net cash provided by operation | | | | | Accounts receivables | 3,132 | | | Prepaid expenses | -996 | | | Interactive Brokers | 3,554 | | | Commission payables | -2,857 | | | Other liabilities | 7,314 | | Net cash provided by Operating Activities | | 36,818 | | FINANCING ACTIVITIES | | | | | 30200-Dividends Paid | -36,000 | | Net cash provided by Financing Activities | | -36,000 | | Net cash increse for period | | 818 | | Cash at the beginning of period | | 1,299 | | Cash at end of period | | 2,117 | {9}------------------------------------------------ ## **CALLAWAY FINANCIAL SERVICES, INC. Notes to Financial Statements December 31, 2021** # **Note 1 - Nature of Business and Summary of Significant Accounting Policies** # **Nature of Business:** Callaway Financial Services, Inc. (the Company) was organized in January 2000 as a Texas corporation. The Company is a subsidiary of MDX Holdings Inc., an S corporation, (Parent) owning one hundred (100%) of the Company. The Company is registered with the Securities and Exchange Commission (SEC) as a broker-dealer in securities and is a member of the Financial Industry Regulatory Authority (FINRA) and Securities Investor Protection Corporation (SIPC). The Company operates under the exemptive provisions ofRule 15c3-3(k)(2)(ii) of the Securities Exchange Act of 1934, and accordingly, is exempt from the remaining provisions of that Rule. The Company does not hold customer funds or securities, but as an introducing broker-dealer, will clear all transactions on behalf of customers on a fully disclosed basis through a clearing broker-dealer. The clearing 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. The Company is a general securities broker-dealer whose customers consist primarily of individuals and retirement plans located in Texas. ## **Significant Accounting Policies:** ## Use of Estimates The preparation of financial statements in conformity with U.S. generally accepted accounting principles 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. #### Fair Value of Financial Instruments Substantially all the Company's financial asset and liability amounts reported in the statement of financial condition are short term in nature and approximate fair value. {10}------------------------------------------------ ## **CALLAWAY FINANCIAL SERVICES, INC. Notes to Financial Statements December 31, 2021** ## Revenue Recognition Securities commissions and the related expenses are recorded on a trade date basis as securities transactions occur. For Mutual Funds, 12b-1 Fees and Variable Annuity contracts, the Company recognizes the revenue based on commission statements received from issuers. For commission in Muni Bonds, OTC Corporate Bonds, OTC Stocks, Listed Option and Interest Income, the Company recognizes revenue based on statements received from Clearing Firm. ## **Note 2 - Net Capital Requirements** The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule 15c3-l), which requires the maintenance of minimum 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. On December 31, 2021, the Company had net capital of \$29,083 which was \$24,083 in excess of its required net capital of \$5,000. The Company's net capital ratio was .35 to 1. #### **Note 3 - Transactions with Clearing Broker-Dealer** The Company has an agreement with a clearing broker-dealer (Interactive Brokers) to provide clearing, execution, and other related securities services. Clearing charges are incurred at markup rate multiplied by the number of shares or stock options traded by the Company. The clearing agreement with Interactive Brokers includes a monthly minimum clearing and execution fee of \$2,000 per month. #### **Note 4 - Related Party Transactions/ Economic Dependency/ Concentrations** The Company and its Parent Company are under common control and the existence of that control creates operating results and financial position significantly different than if the companies were autonomous. The Company has a Services Agreement (Agreement) with its Parent MDX Holdings Inc. The Agreement is for a one-year term, automatically renewed on a year-to-year basis unless terminated by any of the parties on 30 days notice prior to expiration of an annual term. Under the Agreement, the Parent is to provide office facilities, personal property and support services, with rent for the office space. The Parent issues monthly invoice to the Company that represents the Company's allocable share {11}------------------------------------------------ ## **CALLA WAY FINANCIAL SERVICES, INC. Notes to Financial Statements December 31, 2021** of services provided by the Parent. Net services allocation - Parent, incurred and paid, totaled \$7,385 under this Agreement for the period ending December 31, 2021. The Company has a single Parent company, with two primary owners, both of which are registered securities representatives of the Company. MDX Holdings Inc. is a Parent Company, and one of its shareholders is a producing registered securities representative and officer of the Company. The other shareholder is the Chief Compliance Officer and FIN OP of the Company but is not a producing representative. ## **Note 5 - Income Taxes** The Company made a profit of \$33,971 for the year. The Company has NO net operating loss carryforward available to offset 2021 taxable income against. Therefore, company has a tax liability of approximately \$7,300. There is accrued tax liability recognized in the accompanying statement of financial condition. As of December 31, 2021, open Federal tax years subject to examination include the tax years ended December 31, 2018, through December 31, 2021. ## **Note 6 - Off-Balance-Sheet Risk and Concentration of Credit Risk** As discussed in Note 1, the Company's customers' securities transactions are introduced on a fully disclosed basis with its clearing broker-dealer. The clearing broker-dealer carries all the accounts of the customers of the Company and is responsible for execution, collection and payment of funds, and receipt and delivery of securities relative to customer transactions. Off-balance-sheet risk exists with respect to these transactions due to the possibility that customers may be unable to fulfill their contractual commitments wherein the clearing broker-dealer may charge any losses incurred to the Company. The Company seeks to minimize this risk through procedures designed to monitor the credit worthiness of its customers and that customer transactions are executed properly by the clearing broker-dealer. The Company has accounts receivables of \$1,198 which represents approximately 2.5% of the Company's total assets. #### **Note 7 - Commitments and Contingencies** There are currently no asserted claims or legal proceedings against the Company; however, the nature of the Company"s business subjects it to various claims, regulatory examinations, and other proceedings in the ordinary course of business. The ultimate outcome of any such future action against the Company could have an adverse impact on the financial condition, results of operations, or cash flows of the Company. {12}------------------------------------------------ ## **CALLAWAY FINANCIAL SERVICES, INC. Notes to Financial Statements December 31, 2021** ## **Note 8 - Subsequent Events** Management has evaluated the Company's events and transactions that occurred subsequent to December 31, 2021, through March 3, 2022, the date the :financial statements were available to be issued. {13}------------------------------------------------ # **CALLAWAY FINANCIAL SERVICES, INC. Schedule** I - **Supplemental Information Pursuant to Rule 17a-5 December 31, 2021** # **Computation of Net Capital** | Total stockholder's equity qualified for net capital | \$ | 37,070 | |------------------------------------------------------|----|----------| | Deductions / charges | | | | Non-allowable assets: | | | | Commissions receivable | | 883 | | Commission receivable from non-customer | | 315 | | Prepaid expenses | | 6,789 | | Total deductions/ charges | | 7,987 | | Net capital before haircuts on securities positions | | 29,083 | | Net Capital | \$ | 29,083 | | Aggregate indebtedness | | | | Accounts Payable | | 1,069 | | Commission payable | | 694 | | Other Current Liability | \$ | 8,391 | | Total aggregate indebtedness | \$ | 10,154 | | Computation of basic net capital requirement | | | | Minimum net capital required (greater of \$5,000 or | | | | 6 2/3 % of aggregate indebtedness) | \$ | 5,000 | | Net capital in excess of minimum requirement | \$ | 24,083 | | Ratio of aggregate indebtedness to net capital | | .35 to 1 | #### **Reconciliation of Computation of Net Capital** The above computation does not differ from the computation of net capital under Rule 15c3-1 as of December 31, 2021, as filed by Callaway Financial Services, Inc. on form X-17 A-5. Accordingly, no reconciliation is deemed necessary. {14}------------------------------------------------ ## **CALLA WAY FINANCIAL SERVICES, INC. Schedule** II - **Computation for Determination** of **Reserve Requirements Pursuant to Rule l 5c3-3 As of December 31, 2021** A computation of reserve requirement is not applicable to Callaway Financial Services, Inc as theCompany qualifies for exemption under Rule l 5c3-3(k)(2)(ii). {15}------------------------------------------------ #### **CALLAWAY FINANCIAL SERVICES, INC.** Schedule HI - hlformation Relating to the Possessimwr Control Requirements Under Rule l5e3-3 As **of** December 31, 2021 Information Relating to the Possession or Control Requirements is not applicable to Callaway Financial Services, Inc as the Company qualifies for exemption under Rule l 5c3- J(k)(2)(ii). {16}------------------------------------------------ # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Members of Callaway Financial Services Inc We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Callaway Financial Services Inc identified the following provisions of 17 C.F.R. §15c3-3(k) under which Callaway Financial Services Inc claimed an exemption from 17 C.F.R. §240.15c3-3(k)(2)(ii), and, for transactions direct with mutual fund companies, The Company claimed an exemption because it does not hold customer funds or securities (exemption provision), and (2) Callaway Financial Services Inc stated that Callaway Financial Services Inc met the identified exemption provisions throughout the most recent fiscal year without exception. Callaway Financial Services Inc'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 Callaway Financial Services Inc'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. Jennifer Wray CPA PLLC Sugar Land, Texas. March 3, 2022 {17}------------------------------------------------ # **Callaway Financial Services Inc.** **c~1llaway Financial Services~ Inc. F.xem11tio11 lfo110rt** **Callaway Financial Services, Inc.** (the ''Company") is a registered broker-dealer suhjcct to Rule l 7a-5 promulgated by the Securities and Exchange Commission ( 17 C.F.R. §240. I 7a-5, "lfeports lo be 1T1ade 1-,y ccrlf1in brokers ~llld dealers"). This Exemptiotf Repcfr(was 0prdpared as required by 17 C.F.R. § 240. I 7a-5(o)( I) and'(4f To the best of' its knowledge and belief; the Company statesthe foHowriig:' - , , - ( l) The Company claimed an exemption from 17 C.F.R. § 240. I 5c3-3 under the following provisions of 17 C.F.R. § 240. I 5c3-3 (k)(2)(ii), and, fo11iansac1ions di1ec1 with mutual fund companies,,The Company claimed an exemption be01 secu1i1ies. , - (2) The Company mel the identified exemption provision 111 17 C.F.R. § 240. I 5c3-3(k) throughout the most recent fiscal year without exception #### **c~1llaway Financial Services, Inc.** l. M:1ria Dembski, swear (or affirm) that, to my best k11owledge and belief, this Exemption Report is true and correct. Maria Dembski, CFO February 07, 2022 2245 Texas Dr., Suite 300 Sugar Land, TX 77479 Member FINRA/SIPC phone: (954) 707-0586 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.