# PROFESSIONAL TRADING SERVICES BROKERAGE, LLC X-17A-5 (2020-03-02) — Broker-dealer annual report
- Company: PROFESSIONAL TRADING SERVICES BROKERAGE, LLC
- Form: X-17A-5
- Filed: 2020-03-02
- Period: 2019-12-31
- Accession: 0001166547-20-000001
- CIK: 1166547
- File #: 8-65173
- Material weakness: No
- Auditor: Romeo & Chiaverelli, LLC CPA's
- Auditor location: Bala Cynwyd, PA
- Contact: Richard Schank
- Phone: 8568029400
- Signed by: Richard W Schank (President)
Original filing: https://www.sec.gov/Archives/edgar/data/1166547/000116654720000001/Auditoptimized.pdf
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UNITEDSTATES SECURITIES ANDEXCHANGE COMMISSION Washington, D.C. 20549
OMB APPROVAL OMB Number: 3235-0123 Expires: August 31, 2020 Estimated average burden hours per response……. 12.00
8-
SEC FILE NUMBER
# ANNUAL AUDITED REPORT FORM X-17A-5 PART III
FACING PAGE
Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder
| report for the period beginning 01/01/19 | AND ENDING 12/31/19 | | | |
|----------------------------------------------------------------------------------------------------------|--------------------------------------------------------|---------------|--------------------------------|--|
| | MM/DD/Y Y | | MM/DD/YY | |
| | A. REGISTRANT IDENTIFICATION | | | |
| NAME OF BROKER-DEALER: Professional Trading Services Brokerage, LLC alk/a PTS Brokerage, LLC | | | OFFICIAL USE ONLY | |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | FIRM I.D. NO. | | |
| 125 Gaither Drive, Suite C | | | | |
| | (No. and Street) | | | |
| Mount Laurel | NJ | | 08054 | |
| (City) | (State) | | (Zip Code) | |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Richard W Schank 856-802-9400 | | | | |
| | | | (Area Code - Telephone Number) | |
| | B. ACCOUNTANT IDENTIFICATION | | | |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | |
| Romeo & Chiaverelli, LLC CPA's | | | | |
| | (Name - If individual, state last, first, middle name) | | | |
| One Bala Avenue, Suite 234 | Bala Cynwyd | PA | 19004 | |
| (Address) | (City) | (State) | (Zip Code) | |
| CHECK ONE: | | | | |
| Certified Public Accountant | | | | |
| Public Accountant | | | | |
| Accountant not resident in United States or any of its possessions. | | | | |
| | FOR OFFICIAL USE ONLY | | | |
| | | | | |
| | | | | |
\*( laims for exemption from the requirement that the annual report be evered by the opinion of an independent public accountant nust be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240. 17a-5(e)(2)
> Potential 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 OMB control number.
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## OATH OR AFFIRMATION
| Richard W Schank | and and a more a swear (or affirm) that, to the best of |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|
| Professional Trading Services Brokerage, LLC a/k/a PTS Brokerage, LLC | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of |
| of December 31 | , 20 19 |
| classified solely as that of a customer, except as follows: | neither the company nor any partner, principal officer or director has any proprietary interest in any account |
| None | |
| | |
| | |
| | |
| | Signature |
| | President |
| | Title |
| | RYAN J. SCHWARTZ |
| Notary Public | NOTARY PUBLIC OF NEW JERSEY
Comm. # 50058868 |
| This report ** contains (check all applicable boxes): | My Commission Expires 4/17/2022 |
| (a) Facing Page. | |
| (b) Statement of Financial Condition. | |
| | (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement |
| of Comprehensive Income (as defined in §210.1-02 of Regulation S-X).
(d) Statement of Ranges XIX RIMANK Cash Flows | |
| < (c) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. | |
| N/A_ (1) Statement of Changes in Liabilities Subordinated to Claims of Creditors. | |
| (g) Computation of Net Capital. | |
| N/A Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.
N/A (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3. | |
| | (i) A Reconciliation, including appropriate explanation of Net Capital Under Rule 15c3-1 and the |
| Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | |
| consolidation. | N/A] (k) A Reconciliation between the audited Statements of Financial Condition with respect to methods of |
| (1) An Oath or Affirmation.
(m) A copy of the SIPC Supplemental Report. | |
| | N/A (n) A report describing any material inadequacies found to have existed since the date of the previous audit. |
\*\* For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e){3).
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#### **FINANCIAL STATEMENTS SUPPLEMENTARY INFORMATION INDEPENDENT AUDITORS' REPORT AND OTHER MATTERS**
# **PTS BROKERAGE, LLC**
**DECEMBER 31, 2019**
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#### **PTS BROKERAGE, LLC**
### **DECEMBER 31, 2019**
#### **TABLE OF CONTENTS**
| Report of Independent Registered Public Accounting Firm | 1-2 |
|--------------------------------------------------------------------------------------------------------------------------|-------|
| Financial Statements | |
| Statement of Financial Condition | 3 |
| Statement of Income | 4 |
| Statement of Changes in Member's Equity | 5 |
| Statement of Cash Flows | 6 |
| Notes to Financial Statement | 7-10 |
| Supplementary Information | |
| Schedule I
Computation of Net Capital Pursuant to Rule 15c3-1 of
the Securities and Exchange Commission | 11 |
| Schedule II
Exemptive Provisions Under SEC Rule 15c3-3 | 12 |
| Report of Independent Registered Public Accounting Firm
Exemption Report Review | 13 |
| Exemption Report | 14 |
| Independent Accountant's Report on Agreed-Upon Procedures
Report on Schedule of Assessment and Payments (Form SIPC-7) | 15-16 |
| Schedule of Assessment and Payments
(General Assessment
Reconciliation Form SIPC-7) | 17 |
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# ROMEO & CHIAVERELLI LLC CERTIFIED PUBLIC ACCOUNTANTS ONE BALA AVENUESUITE 234 BALA CYNWYD, PA 19004
# REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
To the Member of: PTS Brokerage, LLC
#### Opinion on the Financial Statements
We have audited the accompanying statement of financial condition of PTS Brokerage, LLC(the "Company"), as of December 31, 2019, and the related statements of operations, changes in members' equity and cash flows for the year then ended, and the related notes and supplementary information (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2019, and the results of its operations and its cash flows for the year ended December 31, 2019, in conformity with accounting principles generally accepted in the United States of America.
#### Basis for Opinion
These financial statements are the responsibility of the Company's management. Our responsibility is 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 the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the РСАОВ.
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 Supplementary Information
The supplementary information of Net Capital under Rule 15c3-1 of the Securities and Exchange Commission and the Computation of Reserve Requirements and Information Relating to Possession or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission OR contained in schedules I and II,has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplementary information is the responsibility of the Company's management. Our audit procedures included determining whether the supplementary information reconciles to the financial statements or the underlying and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplementary information. In forming our opinion on the supplementary information, we evaluated whether the supplementary including its form and content, is
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presented in conformity with 17 C.F.R. § 240.17a-5. In our opinion, the supplementary information is fairly stated, in all material respects, in relation to the financial statements as a whole.
We have served as the Company's auditor since 2009.
Carla C
February 25, 2020 Bala Cynwyd, PA 19004
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## **PTS BROKERAGE, LLC STATEMENT OF FINANCIAL CONDITION**
## **DECEMBER 31, 2019**
| ASSETS | | |
|-------------------------------------|-----------|--|
| Cash | \$ 93,405 | |
| Receivables | 92,944 | |
| Other Assets | 11,074 | |
| TOTAL ASSETS | \$197,423 | |
| LIABILITIES & MEMBER EQUITY | | |
| LIABILITIES | | |
| Accounts Payable & Accrued Expenses | \$ 83,269 | |
| TOTAL LIABILITIES | \$ 83,269 | |
| | | |
| MEMBER EQUITY | \$114,154 |
|-----------------------------------|-----------|
| TOTAL LIABILITIES & MEMBER EQUITY | \$197,423 |
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#### **PTS BROKERAGE, LLC STATEMENT OF INCOME**
## **For the Year Ended DECEMBER 31, 2019**
| REVENUE | | |
|--------------------------|-----------|--|
| Commissions | \$904,651 | |
| Investment Advisory Fees | 378,504 | |
| Mutual Fund Fees | 88,624 | |
| TOTAL REVENUE | 1,371,779 | |
| OPERATING EXPENSES | | |
| Employee Compensation | 965,868 | |
| Occupancy | 15,775 | |
| Regulatory Fees | 12,783 | |
| Other Expenses | 31,293 | |
| TOTAL OPERATING EXPENSE | 1,025,719 | |
| NET INCOME | \$346,060 | |
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## **PTS BROKERAGE, LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY**
#### **DECEMBER 31, 2019**
| Member Equity, beginning of year | \$143,199 |
|----------------------------------|-----------|
| Net Income | 346,060 |
| Less: Capital Distributions | (375,105) |
| Member Equity, end of year | \$114,154 |
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## **PTS BROKERAGE, LLC STATEMENT OF CASH FLOWS**
## **For the Year Ended DECEMBER 31, 2019**
| CASH FLOWS FROM OPERATING ACTIVITES | | |
|-------------------------------------------|-----------|--|
| Net Income | \$346,060 | |
| Adjustments to reconcile Net Income | | |
| to net cash provided by operations: | | |
| Depreciation | 107 | |
| Receivables | (955) | |
| Accounts Payable & Accrued Expenses | 14,909 | |
| Net cash provided by Operating Activities | 360,121 | |
| FINANCING ACTIVITES | | |
| Capital Distributions | (375,105) | |
| Net cash used for Financing Activities | (375,105) | |
| Net cash decrease for period | (14,984) | |
| Cash at beginning of period | 108,389 | |
| Cash at end of period | \$ 93,405 | |
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# **DECEMBER 31, 2019**
# **NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**
The following is a summary of the significant accounting policies applied by management in the preparation of the financial statements.
# *Organization*
PTS Brokerage, LLC (Company) was organized under the Laws of the State of New Jersey in 2001 and has been registered as a broker-dealer with the SEC and has been a member of the Financial Industry Regulatory Authority (FINRA) since August 2002. The Company sells mutual funds, life insurance products including variable annuities, provides investment advisory services and provides financial planning services to public customers. The Company is registered in thirteen (13) states to conduct securities transactions. Federal, state, and local income tax returns for years prior to 2016 are no longer subject to examination by tax authorities.
# *Estimates*
The preparation of financial statements in conformity with accounting principles generally accepted in the United of States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates.
## *Property and equipment*
Property and equipment are carried at cost.
# *Revenue recognition*
Revenue is recognized from the sale of mutual funds as earned. Broker-dealers acting as mutual fund distributors may earn 12b-1 fees paid by the fund to the broker-dealer to cover distribution expenses which encompass marketing and selling of mutual fund shares. Revenue from the placement of life insurance products is recognized upon notification of policy acceptance and renewal. Revenue from investment advisory services is recognized as earned. Revenue from financial planning services is recognized as billed.
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## **DECEMBER 31, 2019**
## **NOTE A – SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**
#### *Income taxes*
The Company, a limited liability company, has elected to be taxed for federal and state purposes as a proprietorship. As a result, the Company is not a taxpaying entity for federal or state income tax purposes and, accordingly, no income tax expense or tax benefit has been recorded in these financial statements. Income or losses from the Company are reflected on the Member's income tax returns.
# **NOTE B – NET CAPITAL REQUIREMENT**
The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-1), 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 a ratio of 15 to 1. At December 31, 2019 the ratio was 1.81 to 1. The Company complied with the exemptive provisions of Rule 15c3-3 under subparagraph (k)(1). All customer transactions are limited to the sale and redemption of redeemable securities of registered investment companies, the sale of life insurance products including variable annuities, and providing investment advisory services. At December 31, 2019, the Company had net capital, as defined, of \$46,020, which was \$40,469 in excess of its required minimum net capital of \$5,551.
## **NOTE C – EXPENSE AGREEMENT**
The Company enters into an annual expense agreement with Professional Training Services, a company under common control. Under the agreement, the Company shares space with Professional Training Services and utilizes their telephone services in return for the payment of a percentage of Professional Training Services' monthly lease expense and their monthly telephone costs. For the year 2019, the Company paid 50% of the rent expense and 50% of the monthly telephone costs. The total rent expense for 2019 was \$15,775 and the total telephone expense was \$3,676. The Company also paid \$60,000 (12 monthly payments of \$5,000) to Professional Training Services for the use of its employees' administrative services.
## **NOTE D – SUBSEQUENT EVENTS**
Events of the company subsequent to December 31, 2019 have been evaluated through February 25, 2020 which is the date the financial statements were available to be issued, for the purpose of identifying events requiring recording or disclosure in the financial statements for the year ended December 31, 2019. No subsequent events were identified that required disclosure.
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#### **DECEMBER 31, 2019**
#### **NOTE E – RECENT ACCOUNTING PRONONUNCEMENTS**
#### **Accounting Pronouncements - ASC 606 Revenue Recognition**
In May 2014, the Financial Accounting Standards Board ("FASB") issued Accounting Standards Codification 606, Revenue from Contracts with Customers ("ASC 606"). The accounting standard, along with its related amendments, replaces the current rules-based GAAP governing revenue recognition with a principles-based approach. The Company adopted the new standard on January 1, 2019 using the modified retrospective approach, which requires the Firm to apply the new revenue standard to (i) all new revenue contracts entered into after January 1, 2019 and (ii) all existing revenue contracts as of January 1, 2019 through a cumulative adjustment to equity. In accordance with this approach, revenues for periods prior to January 1, 2019 will not be revised.
The core principle in the new guidance is that a company should recognize revenue in a manner that depicts the transfer of goods or services to customers in amounts that reflect the consideration the company expects to receive for those goods or services. In order to apply this core principle, the Company will apply the following five steps in determining the amount of revenues to recognize: (i) identify the contract; (ii) identify the performance obligations in the contract; (iii) determine the transaction price; (iv) allocate the transaction price to the performance obligations in the contract; and (v) recognize revenue when (or as) the performance obligation is satisfied. Each of these steps involves management's judgment and an analysis of the material terms and conditions of the contract. Although total revenues may not be materially impacted by the new guidance, management notes changes to the disclosures based on the additional requirements prescribed by ASC 606. These new disclosures include information regarding the judgments used in evaluating when and how revenue is recognized and disclosures related to contract assets and liabilities.
#### **New Accounting Pronouncements - ASC 842 Leases**
In February 2016, the Financial Accounting Standards Board ("FASB") published Accounting Standards Update No. 2016-02, Leases ("ASC 842"). The new accounting standard is applied to operating leases with a term greater than 12 months and requires lessee's to recognize (i) their obligations to make lease payments as a liability (the "lease liability"), initially measured at the present value of the lease payments, and (ii) their ability to use the leased property as a corresponding asset (a "right-of-use asset"). The updated standard is effective for fiscal years beginning after December 15, 2018 and the Company adopted the new standard on January 1, 2019 using the modified retrospective approach, which requires the Firm to (i) apply the new standard to leases in place as of the adoption date, (ii) record a cumulative-effect adjustment to retained earnings as of the first day of the adoption year, and (iii) follow the new rules for all leases entered or modified going forward. In accordance with this approach, assets and liabilities for periods prior to January 1, 2019 will not be revised.
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#### **DECEMBER 31, 2019**
#### **New Accounting Pronouncements - ASC 842 Leases (Continued)**
The core principle in the new guidance is that a company should provide information necessary to understand its leasing activities including a comprehensive understanding of the costs of property essential to a company's operations and how those costs are funded including the recognition of assets and liabilities associated with leases.
Although the economic or legal characteristics of these leases are not altered, the impact on the presentation of assets and liabilities on financial statements may be material. Also, as a broker-dealer registered with the Securities and Exchange Commission ("SEC") and Financial Industry Regulatory Authority ("FINRA"), the Company is subject to SEC Rule 15C3-1, the Net Capital rule, under which the lease asset would be recorded as a non-allowable asset and the associated liability would be recorded as aggregate indebtedness, both of which could have a materially negative effect on Net Capital computed under SEC Rule 15c3-1. On May 31, 2016, the Securities Industry and Financial Markets Association ("SIFMA") requested relief from the SEC from the net capital impact of the lease capitalization required under ASC 842. On November 8, 2016, the SEC issued a "no action" letter permitting broker-dealers to add back to Net Capital the operating lease asset to the extent of the associated operating lease liability. If the value of the operating lease liability exceeds the value of the associated operating lease asset, the amount by which the liability's value exceeds the associated lease asset must be deducted for net capital purposes.
The new guidance provided by ASC 842 may not materially impact the Company's presentation of assets and liabilities, and the relief provided by the SEC "no action" letter will substantially negate the effect of its application on the Company's Net Capital; however management notes changes to the disclosures based on the additional requirements prescribed by ASC 842. These new disclosures include information regarding the judgments used in determining the present value of lease payments and the corresponding value of the right-ofuse asset.
The new guidance does not apply to the Company as the lease of our office space is pursuant to an expense sharing agreement for a period of 12 months.
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SUPPLEMENTARY INFORMATION
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# PTS BROKERAGE, LLC SCHEDULE I COMPUTATION OF NET CAPITAL PURSUANT TO RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION
# DECEMBER 31, 2019
| Total member equity from
Statement of financial condition | \$114,154 |
|------------------------------------------------------------------------------------------|----------------------------|
| Non-Allowable Assets:
Receivables
Fixed assets
Total Non-Allowable Assets | 57,524
10,610
68,134 |
| Net Capital | \$ 46,020 |
| COMPUTATION OF BASIC NET CAPITAL REQUIREMENT | |
| Minimum net capital required per 15c3-1 (a)(2) | \$
5,551 |
| Minimum Dollar Net Capital Requirement
Minimum Net Capital Requirement | \$ 5,000
\$ 5,551 |
| Excess Net Capital | \$ 40,469 |
| Excess Net Capital at 120% | \$ 37,693 |
| Aggregate Indebtedness from Statement of Financial
Condition, net of A-1c liabilities | \$ 83,269 |
| Percentage of AI to NC | 180.94 % |
| Debt-Equity Ratio in accordance with 15c3-1(d) | 0 |
Note: There are no material differences between the preceding computation and the Company's corresponding unaudited part IIA of Form X-17A-5 as of December 31, 2019
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#### SCHEDULE II
## PTS BROKERAGE, LLC EXEMPTIVE PROVISIONS UNDER 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION
#### DECEMBER 31, 2019
The Company is exempt from Rule 15c3-3 of the Securities and Exchange Commission under paragraph (k)(1) of that Rule.
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OTHER MATTERS
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# ROMEO & CHIAVERELLI LLC ONE BALA AVE SUITE 234 BALA CYNWYD, PA 19004
# Report of Independent Registered Public Accounting Firm Exemption Report Review
To the Member of: PTS Brokerage, LLC
We have reviewed management's statements, included in the accompanying Exemption Report, on which identified the following provisions of 17 C.F.R. ~ 15c3-3(k) under which PTS Brokerage, LLC claimed an exemption from 17 C.F.R. ~240.15c3-3:(1). SEC Rule 15c3-3(k)(1) and PTS Brokerage, LLC stated that PTS Brokerage, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. PTS Brokerage LLC'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 PTS Brokerage, LLC'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)(1) of Rule 15c3-3 under the Securities Exchange Act of 19347
LLC
Romeo & Chiaverelli, LLĆ Bala Cynwyd, PA
February 25, 2020
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PTS Brokerag'e, LLC
.Iì'ofcssional Tiading Scn'iccs Brckenge, LLC
Ilast (]atc llusincss (-cntcr 125 Gaither Dlive, Suitc C Mount Laurcl, NJ 08054 \wvw. p t s b ro kera ge. c om
()fficc: (85ó) 802-9400 Fax: (85ó) 802-9444
Richard W. Schank, CIrP@, ClhtrC, CI-U, CFS, RIIU,lUiBC, trr\
President, CFO
E-¡nail: pts@ptsbrokerâge.com
EXEMPTION REPORT
- l. PTS Brokerage,LLc claimed an exemption from SEC Rule l5c3-3 under the provisions in 2. PTS Brokerage, LLC met the identified exemption provisions in SEC Rule l5c3-3(k)(l) throughout Richard W. , 125 Gaither Drive, Suite C Mount Laurel, NJ 08054 (8s6) 802-9400
- We confirm, to the best of our knowledge and belief, that: paragraph of (kX I ) throughout the calendar year January I , 2019 to December 3 I ,2019 . the calendar year January 1,2019 to December 3l ,2019 without exception. LLC
PTS
Sccr¡ritics r¡ffe rctl bv PTS Bruk<'ntgc, ZZC. Mcnrbcr FINIIA/SIPC Iìcgistcretl I nvcslnìcnl Advisor
2125120
Date
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# ROMEO & CHIAVERELLI LLC ONE BALA PLAZA SUITE 234 BALA CYNWYD, PA 19004
# Independent Accountant's Agreed-Upon Procedures Report On Schedule Of Assessment And Payments (Form SIPC-7)
To The Member of: PTS Brokerage, LLC
We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below and were agreed to by PTS Brokerage, LLC and the SIPC, solely to assist you and SIPC in evaluating PTS Brokerage, LLC's compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2019. PTS Brokerage, LLC's management is responsible for its Form SIPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with standards established by the Public Company Accounting Oversight Board (United States) and in conformance with 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 records entries, noting no differences;
- 2. Compared the Total Revenue amounts reported on the Annual Audited FormX-17A-5 for the year ended December 31, 2019, with the Total Revenue amount reported in Form SPIC-7 for the year ended December 31, 2019, noting no differences:
- 3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences;
- 4. Recalculated 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: and
- 5. Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed, 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 or conclusion, respectively, on PTS
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Brokerage, LLC's compliance with the applicable instructions of 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 PTS Brokerage, LLC and the SIPC and is not intended to be and should not be used by anyone other than these specified parties.
Romeo & Chiaverelli, LLC Bala Cynwyd, PA
February 25, 2020
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## PTS BROKERAGE, LLC SCHEDULE OF ASSESMENT AND PAYMENTS TO THE SECURITIES INVESTOR PROTECTION CORPORATION
#### DECEMBER 31, 2019
| Period Covered | Date Paid | Amount |
|---------------------------------------------------------------------------|-----------|---------|
| General Assessment Reconciliation for the year
ended December 31, 2019 | | \$595 |
| Payment Schedule | | |
| SIPC-6 | 7/30/2019 | 294 |
| SIPC-7 | 2/06/2020 | 301 |
| Amount Due | | \$
0 |
Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.