# THEMIS TRADING LLC X-17A-5 (2025-02-27) — Broker-dealer annual report - Company: THEMIS TRADING LLC - Form: X-17A-5 - Filed: 2025-02-27 - Period: 2024-12-31 - Accession: 0001169786-25-000001 - CIK: 1169786 - File #: 8-65260 - Type: Broker-dealer - Material weakness: No - Auditor: Ohab and Company, P.A - Auditor location: Maitland, FL - Contact: Gennaro J Fulvio - Phone: 212-490-3113 - Email: pzajac@themistrading.com - Website: themistrading.com - Signed by: Paul S Zalak (Managing Member) Original filing: https://www.sec.gov/Archives/edgar/data/1169786/000116978625000001/themispub24.pdf --- {0}------------------------------------------------ # THEMIS TRADING LLC STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2024 # FILED PURSUANT TO RULE 17A-5(e)(3) OF THE SECURITIES ACT OF 1934 AS A PUBLIC DOCUMENT **PUBLIC** {1}------------------------------------------------ ### UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 # ANNUAL REPORTS FORM X-17A-5 ## PART III SEC FILE NUMBER 8-65260 #### FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | FILING FOR THE PERIOD BEGINNING 01/01/2024
AND ENDING 12/31/2024 | |---------------------------------------------------------------------| |---------------------------------------------------------------------| MM/DD/YY MM/DD/YY A. REGISTRANT IDENTIFICATION # NAME OF FIRM: THEMIS TRADING LLC TYPE OF REGISTRANT (check all applicable boxes): E Broker-dealer [ ] Check here if respondent is also an OTC derivatives dealer ### ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) # 10 TOWN SQUARE, SUITE #100 | | (No. and Street) | | | |----------------------------------------------------------------------------------------------------|------------------------------------------------------------|--------------------------------------------|--------------------------| | CHATHAM | NJ | | 07928 | | (City) | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | PAUL ZAJAC | 973-665-9600 | | PZAJAC@THEMISTRADING.COM | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filling*
OHAB & COMPANY, P.A. | | | | | | (Name - if individual, state last, first, and middle name) | | | | 100 EST SYBELIA AVENUE, SUITE #130 MAITLAND | | i | 32751 | | (Address) | (City) | (State) | (Zip Code) | | 07/28/2004 | | 1839 | | | (Date of Registration with PCAOB)(if applicable) | | (PCAOB Registration Number, if applicable) | | | | FOR OFFICIAL USE ONLY | | | \* Claims for exemption from the requirement that the annual reports of an independent public accountant must be supported by a statement of facts and circumstances relled on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(ii), 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 OMB control number. {2}------------------------------------------------ #### OATH OR AFFIRMATION | PAUL S ZAJAC | | | | swear (or affirm) that, to the best of my knowledge and belief, the | |------------------------|-------------------------------------------------------------------------------------------------------------------------------------|--------|-------------------------------|-----------------------------------------------------------------------------------------| | | financial report pertaining to the firm of THEMIS TRADING LLC | | | as of | | 12/31 | | | | 2 024 is true and correct. I further swear (or affirm) that neither the company nor any | | | 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. | BRIGITTE RICHTER-HAJDUK
Notary Public - State of New Jersey
My Commission Expires Jun 7, 2026
740 NHONK | Title: | Signature:
MANAGING MEMBER | | | Notary Public | | | | | #### This filing\*\* contains (check all applicable boxes): - (a) Statement of financial condition. - (b) Notes to consolidated 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). - O (d) Statement of cash flows. - □ (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - [ (f) Statement of changes in liabilities subordinated to claims of creditors. - □ (g) Notes to consolidated financial statements. - | (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - [ (i) Computation of tangible net worth under 17 CFR 240.18a-2. - [] Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - | Exhibit A to 17 CFR 240.18a-4, as applicable. - [ (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3. - [ (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - □ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - □ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - [ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - | (q) Oath or affirmation in accordance with 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - [ {r} Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - [ (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - (t) Independent public accountant's report based on an examination of the statement of financial condition. - [ (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - □ (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} |ndependent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - | (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.17-12, as applicable. - \_ (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). [ (z) Other: \*\* To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(2), or 17 CFR 240.18a-7(d)(2), as applicable. {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) 100 E. Sybelia Ave. Suite 130 Maitland, FL 32751 Certified Public Accountants Email: pam(@ohabco.com Telephone 407-740-7311 Fax 407-740-6441 ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Members of Themis Trading LLC ### Opinion on the Financial Statement We have audited the accompanying statement of financial condition of Themis Trading LLC as of December 31, 2024 and the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of Themis Trading LLC as of December 31, 2024 in conformity with accounting principles generally accepted in the United States of America. ### Basis for Opinion This financial statement is the responsibility of Themis Trading LLC's management. Our responsibility is to express an opinion on Themis Trading LLC'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 Themis Trading 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 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. Oher and Compag, OF We have served as Themis Trading LLC's auditor since 2023. Maitland, Florida February 24, 2025 {4}------------------------------------------------ # THEMIS TRADING LLC STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2024 # ASSETS | Cash
Deposit with clearing broker
Commissions receivable
Fixed assets at cost, net of | \$
123,063
500,000
545,076 | |------------------------------------------------------------------------------------------------|-------------------------------------| | accumulated depreciation of \$ 168,478
Other assets | 4,145
20,779 | | TOTAL ASSETS | \$
1,193,063 | | | | | LIABILITIES AND MEMBERS' CAPITAL | | | LIABILITIES | | | Accrued expenses and other liabilities | \$
359,364
359,364 | | COMMITMENTS AND CONTINGENCIES | | | MEMBERS' CAPITAL | 833,699 | | TOTAL LIABILITIES AND MEMBERS' CAPITAL | \$
1,193,063 | | | | {5}------------------------------------------------ ## 1. ORGANIZATION AND NATURE OF BUSINESS Themis Trading LLC (the "Company") was organized under the laws of the State of Delaware on February 19, 2002. The Company is a registered broker-dealer with the Securities and Exchange Commission ("SEC"), Financial Industry Regulatory Authority, Inc. ("FINRA"), Investors' Exchange LLC, and 17 states. The Company is engaged in a single line of business as a securities broker-dealer, comprising of agency transactions*.* In this capacity the Company executes agencybased brokerage and soft dollar transactions for institutional customers. The Company operates on a fully disclosed basis through its clearing broker, RBC Capital Markets, LLC ("RBC"). In the normal course of its business, the Company enters into financial transactions where the risk of potential loss due to changes in market value ("market risk") or failures of counterparty performance ("credit risk") exceed the amounts recorded for the transaction. The Company's policy is to continuously monitor its exposure to market risk through the use of a variety of credit exposure reporting and control procedures. In addition, the Company has a policy of reviewing the credit risk of each institutional counterparty with which it conducts business. The Company introduces its customer transactions on a fully disclosed basis to RBC for correspondent clearing services in accordance with the terms of a clearing agreement. In connection with the agreement RBC has agreed to perform clearing and depository operations, and the Company has agreed to indemnify RBC for losses that it may sustain related to the Company's customers. At December 31, 2024, the deposit with clearing broker reflected on the statement of financial condition was substantially in cash held by RBC. ## 2. SIGNIFICANT ACCOUNTING POLICIES The Company maintains its books and records on an accrual basis in accordance with accounting principles generally accepted in the United States of America which require management to make estimates and assumptions in determining the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements. Actual results could differ from these estimates. {6}------------------------------------------------ # 2. SIGNIFICANT ACCOUNTING POLICIES (continued) Depreciation is charged to operations over the estimated useful lives of the assets on a straight-line basis. Brokerage transactions are classified as operating activities on the statement of cash flows since this is the Company's principal business activity. The Company recognizes revenue in accordance with Accounting Standards Update No. 2014-09 and records commission, other revenue, and interest as well as clearing expenses on a trade date basis as transactions occur. The trade date is the date that pricing, performance obligations, and ownership terms are agreed upon. For purposes of reporting cash and cash equivalents, the Company considers all cash accounts, which are not subject to withdrawal restrictions or penalties, and all highly liquid debt instruments purchased with a maturity of three months or less to be cash equivalents. The Company maintains cash accounts with several financial institutions with balances that may at times exceed the Federal Deposit Insurance Corporation ("FDIC") insurance limits and Securities Investor Protection Corporation ("SIPC") insurance limits, respectively. At year end, amounts were under the FDIC and SIPC insurance limits. # 3. INCOME TAXES The Company has elected to be recognized as an S-corporation by the Internal Revenue Service for tax purposes only. For state income tax purposes, the Company recognizes corporation business tax ("CBT") at the maximum level of \$1,500, which is included in other expenses on the Statement of Operations. The Company's income or loss is reportable by its shareholders on their individual tax returns. The FASB provides guidance for how uncertain tax positions should be recognized, measured, disclosed and presented in the financial statements. This requires the evaluation of tax positions taken or expected to be taken in the course of preparing the Company's tax returns to determine whether the tax positions are "more Iikely than not" of being sustained "when challenged" or "when examined" by the applicable tax authority. Tax positions not deemed to meet the more likely than not threshold would be recorded as a tax benefit or expense and liability in the current year. As of December 31, 2024 management has determined that there are no material uncertain income tax positions. {7}------------------------------------------------ ## 4. SOFT DOLLAR EXPENSE The Company's clients are permitted to allocate a portion of their gross commissions to pay for third party research that is consistent with the guidelines set forth in SEA Section 28(e). Soft dollar expense of \$1,190,191 included in the financial statements represents these commission payments or accruals for future commission payments. On December 31, 2024, \$8,576 is included in other liabilities related to these accrued commission payments. # 5. CREDIT LOSSES The Company follows ASC Topic 326, Financial Instruments – Credit Losses ("ASC 326"). ASC 326 impacts the impairment model for certain financial assets by requiring a current expected credit loss methodology to estimate expected credit losses during the entire life of any existing financial asset. Under the accounting update, Themis has the ability to determine that there are no or limited expected credit losses associated with its business, such as the risk related to institutional counterparty credit quality during the transaction settlement period. The Company had commissions receivable of \$545,076, primarily from settled transactions, as of December 31, 2024. ## 6. PROFIT SHARING PLAN The Company had a profit-sharing plan covering all qualified employees during a portion of the year. The profit-sharing plan expense of \$2,343 for the year ended December 31, 2024, included in the Statement of Operations, represented contributions required by profit-sharing plan regulations. The profit-sharing plan was terminated during the year. # 7. COMMITMENTS AND CONTINGENT LIABILITIES The Company is leasing its office space on a month-to-month basis. The Company had no contingent liabilities and has not been named as a defendant in any lawsuit at December 31, 2024, or during the year then ended. {8}------------------------------------------------ ## 8. SEA RULE 15C3-3 The Company is exempt from the provisions of the SEC customer protection rules, SEA Rule 15c3-3 under Paragraph (k)(2)(ii) in that the Company carries no accounts, does not hold funds or securities for or owe money or securities to clients and executes all financial transactions on behalf of clients on a fully disclosed basis through its clearing firm. # 9. NET CAPITAL REQUIREMENTS The Company is subject to the SEC's net capital rule (SEA 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 15 to 1. On December 31, 2024, the Company had net capital of \$808,775, which exceeded the minimum requirement of \$100,000 by \$708,775. The Company's ratio of aggregate indebtedness to net capital at that same date was 0.44 to 1. # 10. FINANCIAL INSTRUMENTS WITH OFF-BALANCE SHEET RISK As a securities broker-dealer, the Company is engaged in various securities trading and brokerage activities servicing a diverse group of institutional clients. These activities may expose the Company to off balance sheet credit risk in the event a client is unable to fulfill its contracted obligation. # 11. SUBSEQUENT EVENTS Management has evaluated events subsequent to December 31, 2024, and through February 24, 2025, the date that these financial statements were available to be issued and has concluded that no further information is required to be recognized or disclosed. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.