# WALNUT CREEK CAPITAL ADVISORS, LLC X-17A-5 (2025-04-07) — Broker-dealer annual report

- Company: WALNUT CREEK CAPITAL ADVISORS, LLC
- Form: X-17A-5
- Filed: 2025-04-07
- Period: 2024-12-31
- Accession: 0001291460-25-000008
- CIK: 1291460
- File #: 8-66521
- Type: Broker-dealer
- Material weakness: No
- Auditor: Tuttle & Bond
- Auditor location: Fredricksburg, TX
- Contact: Andy Mason
- Phone: 678-322-3000
- Email: edsamson@finopconsultants.com
- Website: finopconsultants.com
- Signed by: John Williams (PEO/CCO)

Original filing: https://www.sec.gov/Archives/edgar/data/1291460/000129146025000008/caaudit24confidential.pdf

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| UNITED STATES                      |
|------------------------------------|
| SECURITIES AND EXCHANGE COMMISSION |
| Washington, D.C. 20549             |

### ANNUAL REPORTS FORM X-17A-5 PART III

| OMB APPROVAL                                                                                          |  |
|-------------------------------------------------------------------------------------------------------|--|
| OMB Number: 3235-0123<br>Expires: Nov. 30, 2026<br>Estimated average burden<br>hours per response: 12 |  |
| SEC FILE NUMBER                                                                                       |  |

FACING PAGE

Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934

| "ING FOR THE PERIOD BEGINNING 1/1/2024 |          | AND ENDING 12/31/2024 |          |  |  |
|----------------------------------------|----------|-----------------------|----------|--|--|
|                                        | MM/DD/YY |                       | MM/DD/YY |  |  |

A. REGISTRANT IDENTIFICATION

NAME OF FIRM: Walnut Creek Capital Advisors, LLC

TYPE OF REGISTRANT (check all applicable boxes):

□ Check here if respondent is also an OTC derivatives dealer

@ Broker-dealer | | Security-based swap dealer | | Major security-based swap participant

ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)

|             | (No. and Street) |            |
|-------------|------------------|------------|
| McDonough   |                  | 30252      |
| (City) ==== | (State)          | (Zip Code) |

732-233-3500 edsamson@finopconsultants.com Edward Samson (Area Code - Telephone Number) (Email Address) (Name)

B. ACCOUNTANT IDENTIFICATION

INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\*

### Tuttle & Bond, PPL

| (State)<br>(Zip Code)                      |
|--------------------------------------------|
|                                            |
| 6543                                       |
| (PCAOB Registration Number, if applicable) |
| FOR OFFICIAL USE ONLY                      |
|                                            |

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 valld OMB control number.

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### OATH OR AFFIRMATION

, swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Walnut Creek Capital Advisors, 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.

> Kelsie D. McAlister Notary Public, State of South Carolina My Commission Expires April 8, 2031

Signature: Title: VENICCO

Notary Public

### This filing \*\* contains (check all applicable boxes):

- (a) Statement of financial condition.
- O (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).
- (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.
- [ (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- □ (k) 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.
- [ (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.
- O (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 capital or tangible 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-5, 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.
- O (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 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 240.17a-12, as applicable.
- [ {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 240.17a-12(k).
- □ (z) Other:
- \*\* To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.180-7(d)(2), as applicable.

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Walnut Creek Capital Advisors, LLC

Financial Statements and Supplemental Schedules Required by the U.S. Securities and Exchange Commission

Including Independent Auditor's Report Thereon

December 31, 2024

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# CONFIDENTIAL

## Contents

| Independent Auditor's Opinion                                                                     |
|---------------------------------------------------------------------------------------------------|
| Financial Statements                                                                              |
| Statement of Financial Condition For the year ended December 31, 2024                             |
| Statement of Income                                                                               |
| Statement of Cash Flow                                                                            |
| Statement of Changes in Ownership Equity                                                          |
| Footnotes to Financial Statements                                                                 |
| Supplementary Information Section                                                                 |
| Supplementary Information                                                                         |
| Net Capital Computations                                                                          |
| Computation of Net Capital                                                                        |
| Computation of Net Capital Requirement                                                            |
| Computation of Aggregate Indebtedness                                                             |
| Computation of Reconciliation of Net Capital                                                      |
| Supplementary Statements                                                                          |
| Net Capital Statement, Determination of Customer Reserve and Possession & Control Requirements 14 |
| Statement Related to Uniform Net Capital Rule                                                     |
| Determination of Customer Reserve Requirements                                                    |
| Possession and Control Requirements                                                               |
| Supplementary Customer Protection Exemption Report                                                |

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### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Walnut Creek Capital Advisors, LLC

### Opinion on The Financial Statements

We have audited the accompanying statement of financial condition of Walnut Creek Capital Advisors, LLC (the "Company") as of December 31, 2024, and the related statements of operations, member's and cash flows for the related notes (collectively referred to as "financial statements"). In our opinion, the financial statements, the financial position of the Company as of December 31, 2024, and the results of its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America.

### Basis for Opinion

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's 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 PCAOB.

We conducted our audit of these financial statements in accordance with the standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement, whether due to error or fraud. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audits, we are required to obtain an understanding of internal reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal reporting. Accordingly, we express no such opinion.

Our audit included performing procedures to assess the risstatement 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 principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that the audit provides a reasonable basis for our opinion.

### Report on Supplementary Information

The accompanying information contained in the Supplementary Information section has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statement. The supplemental information is the Company's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental informing our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with Rule 17a-5 under the Securities Exchange Act of 1934 and, if applicable, under Regulation 1.10 under the Commodity Exchange Act. In our opinion, the information contained in the Supplementary Information section is fairly stated, in all material respects, in relation to the financial statements as a whole.

Tuttle & Bond, PLLC

Giddings, Texas March 19, 2025

We have served as the auditor for Walnut Creek Capital Advisors, LLC since 2025.

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### Walnut Creek Capital Advisors, LLC Financial Statements Statement of Financial Condition For the year ended December 31, 2024

|                               |     | Dec 31, 24 |
|-------------------------------|-----|------------|
| ASSETS                        |     |            |
| Current Assets                |     |            |
| Cash                          |     |            |
| Checking/Savings              | ക്ക | 8,302      |
| Fees receivable               |     | 9,038      |
| Deposits - FINRA Flex account |     | 147        |
| TOTAL ASSETS                  | ക്ക | 17,487     |
| LIABILITIES & EQUITY          |     |            |
| Liabilities (all current)     |     |            |
| Accruals                      |     | 32         |
| Equity                        |     |            |
| Distributions                 |     | (855,391)  |
| Additional Paid-in Capital    |     | 159,019    |
| Retained Earnings             |     | 716,988    |
| Net Income                    |     | (3,161)    |
| Total Equity                  | ക്ക | 17,455     |
|                               |     |            |
| TOTAL LIABILITIES & EQUITY    | ಕಾ  | 17,487     |

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### Walnut Creek Capital Advisors, LLC Statement of Income For the year ended December 31, 2024

|                               |      | Jan - Dec 24 |  |
|-------------------------------|------|--------------|--|
| Ordinary Income/Expense       |      |              |  |
| Revenue                       |      |              |  |
| Fees Securities               | ಕ್ಕಾ | 39,796       |  |
| Total Revenue                 | ಕ್ಕಾ | 39,796       |  |
| Expense                       |      |              |  |
| Compliance                    |      | 32,652       |  |
| Communications and Technology |      | 7,025        |  |
| Other expenses                |      | 3,280        |  |
| Total Expense                 | ಕ್ಕಿ | 42,957       |  |
| Net Ordinary Income           | ಲ್ಲಿ | (3,161)      |  |
| Net Income                    | ಕ್ಕಾ | (3,161)      |  |

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### Walnut Creek Capital Advisors, LLC Statement of Cash Flow For the year ended December 31, 2024

|                                                                                                | Dec 31, 24 |          |
|------------------------------------------------------------------------------------------------|------------|----------|
| Cash flows from operating activities:                                                          |            |          |
| Net Income                                                                                     | ea         | (3,161)  |
| Adjustments to Reconcile net income to net<br>cash provided by (used by) operating activities: |            |          |
| Depreciation                                                                                   |            |          |
| Amortization                                                                                   |            |          |
| Receivables from affilates                                                                     |            | (6,916)  |
| Prepaid expenses                                                                               |            | 88       |
| Accrued expenses                                                                               |            | 32       |
| Accounts payables                                                                              |            | 46,215   |
| Net Cash provided by operating activities                                                      | ಕಿ         | 36,258   |
| Cash flows from financing activities:                                                          |            |          |
| Distributions                                                                                  |            | (55,940) |
| Net Cash provided (used) by financing activities                                               | ല്ല        | (55,940) |
| Net increase in cash                                                                           | ಕಾ         | (19,682) |
| Cash at beginning of year                                                                      | ಕಾ         | 27,984   |
| Cash at end of year                                                                            | ક્તિ       | 8,302    |

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# CONFIDENTIAL

Statement of Changes in Ownership Equity For the year ended December 31, 2024 Walnut Creek Capital Advisors, LLC

|                            |               | Additional    |           |                |
|----------------------------|---------------|---------------|-----------|----------------|
|                            |               | Paid-in       | Retained  |                |
|                            | Distributions | Capital       | Earnings  | Total          |
| Balances at                |               |               |           |                |
| December 31, 2023          | \$(767,920)   | 127,489<br>ಕಾ | \$716,988 | 76,557<br>ક્તિ |
| Additional Paid-in Capital |               | 31,780        |           | 31,780<br>ક    |
| Distributions              | 87,721        |               |           | \$ (87,721)    |
| Net Income                 |               |               | (3,161    | \$ (3,161)     |
| Balances at                |               |               |           |                |
| December 31, 2024          | \$(855,641    | \$ 159,269    | \$713,827 | \$ 17,455      |

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Walnut Creek Capital Advisors, LLC Footnotes to Financial Statements For the year ended December 31, 2024

### Note 1 - Organization and Description of Business

Walnut Creek Capital Advisors, LLC (the Company), a Georgia Limited Liability Company, is a securities broker-dealer registered with the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA).

The Company is primarily engaged in investment banking and financial advisory services. The Company's customers are located throughout the United States, but primarily in the Southeast.

NOTE 2-Summary of Significant Accounting Policies

Accounts Receivable and Allowance for Credit Losses

Accounts receivable are non-interest-bearing uncollateralized obligations receivable in accordance with the terms agreed upon with each customer. The Company regularly reviews its accounts receivables for any uncollectible amounts. The review for uncollectible amounts is based on an analysis of the Company's collection experience, customer credit worthiness, and current economic treads.

### Cash

The Company maintains its bank account in a high credit quality financial institution. The balance at times may exceed federally insured limits.

### Property and Equipment

Property and equipment are recorded at cost. Depreciation is provided by use of the straight-line method over the estimated useful lives of the respective assets, which ranges from five to seven years.

### Income Taxes

Because the Company is a Limited Liability Company, it is taxed as a partnership. Therefore the income or losses of the Company flow through to its members and no income taxes are recorded in the accompanying financial statements.

The Company has adopted the provisions of FASB Accounting Standards Codification (ASC) 74010, Accounting for Uncertainty in Income Taxes. Under ASC 740-10, the Company is required to evaluate each of its tax positions to determine if they are more likely than not to be sustained if the taxing authority examines the respective position. A tax position includes an entity status, including its status as a pass-through entity, and the decision to file Form 1065, U.S. Return of Partnership Income. The

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Company has evaluated each of its tax positions and has determined that no provision or liability for income taxes from the Company is necessary.

### Estimates

Management uses estimates and assumptions in preparing financial statements in accordance with generally accepted accounting principles. Those estimates and assumptions affect the reported amounts of assets, liabilities, revenues and expenses. Actual results could vary from the estimates that were assumed in preparing the financial statements.

### Revenue Recognition

The Company adopted ASU 2014-09, Revenue from Contracts with Customers, (codified in ASC 606). The Company recognizes revenue when services are transferred to clients. Revenue is recognized based on the amount of consideration that management expects to receive in exchange for these services in accordance with the terms of the contract with the client. To determine the amount and timing of revenue recognition, the Company must (1) identify the contract with the client, (2) identify the performance obligations in the contract, (3) determine the transaction price, (4) allocate the transaction price to the performance obligations in the contract, and (5) recognize revenue when the Company satisfies a performance obligation to which the entity expects to be entitled in exchange for those goods or services. ASU 2014-09 prescribes a five-step process to accomplish this core principle, including:

### Investment Advisory Fee Revenue

The Company's advisory customers enter into an investment advisory agreement with the Company, which sets forth the Company's obligations and right to remuneration. The fee charged the customer is calculated and earned by the Company in accordance with the rate set forth in the advisory agreement for the period in which the Company manages the customer's assets. The Company has satisfied its obligation if it has provided its services through the date of invoice to the customer, at which time investment advisory fee revenue is recognized.

Reimbursement from Registered Representatives: Registered representatives reimburse the Company for certain expenses pursuant to an agreement with the Company. Such reimbursements are reflected as revenue in the accompanying income statement.

Date of Management's Review: Subsequent events were evaluated through the date the financial statements were issued.

Note 3 -Related Party Transactions

The Company operates from premises provided by its majority member at no cost to the Company.

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The balance sheet and income statement would differ from the amounts in the accompanying financial statements if these related party transactions did not exist.

The Company and its Member occasionally pay expenses on behalf of each other that are reimbursed at cost with no gain or loss. During the period of the report 2024, payments on behalf of one another were \$26,255 were treated as a capital contribution. The balance due from member on the accompanying statement of financial condition arose from such transactions.

The Company operates from office space provided by the owners of the Company's Member at no cost to the Company. Financial position and results of operations could have differed from the amounts in the accompanying financial statements if these related party transactions did not exist.

### Note 4 - Concentrations

During 2023, approximately 100% of investment banking revenues were earned from 1 customer(s). We had no net accounts receivable at December 31, 2024.

### Note 5 - Net Capital Requirements

The Company, as a registered broker dealer, 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 15 to 1. At December 31, 2024, the Company had net capital of \$3,269, which was in excess of its required net capital of \$5,000, and its ratio of aggregate indebtedness to net capital was 0.4%.

### Note 6 - Subsequent Events

The Company has evaluated all events and transactions that occurred after December 31, 2024 through March 19, 2025. On January 28, 2025, the company was sold to Assent Securities, LLC a Georgia limited liability company. The name and the type of business remain unchanged.

### Note 7 - Contingencies

The Company is subject to litigation in the normal course of business. The Company has no litigation in progress as of December 31, 2024, as defendant.

### Note 8 - Economic Risks

In March 2020, the World Health Organization (WHO) declared COVID-19 a global pandemic. This pandemic event has resulted in significant business disruption and uncertainty in both global and U.S. markets. While management believes the Company is in an appropriate position to sustain potential short-term effects of these world-wide events, the direct and long-term impact to the Company and its financial statements is undetermined at this time.

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### Note 9 - Commitments and Contingencies

The Company does not have any commitments, guarantees or contingencies that may result in a loss or future obligation, or that may be asserted against the firm at a future date.

### Notes 10 Segment reporting

The Company is engaged in a single line of business as a limited purpose broker dealer which provides distribution related serves to its customers. The Company has identified its president as the chief operating decision maker "CODM' who uses net income to evaluate the results of the business in the forecasting process to manage the Company. Additionally, the CODM uses excess net capital which is not a measure of profit loss to make operational decisions while maintaining capital as whether to reinvest profits or pay out income. The Company's operations constitute a single segment and therefore a single reportable segment because the CODM manages the business activities using the Company's information as a whole. The Company's policy is used to measure the profit and loss in the segment is the same as those described in the summary of significant accounting policies. Included in the Statement of Operations is the segment information. (ASU 280 Segment reporting)

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### Supplementary Information Section

Pursuant to SEA Rule 17a-5 of the Securities and Exchange Act of 1934

As of and for the year ended December 31, 2024

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Walnut Creek Capital Advisors, LLC Supplementary Information Net Capital Computations Pursuant to SEA Rule 17a-5 of the Securities and Exchange Act of 1934 As of and for the year ended December 31, 2024

Computation of Net Capital

| Total Stockholder's Equity<br>Allowable Subordinated Loans | ക     | 17.455 |
|------------------------------------------------------------|-------|--------|
| Non-Allowable Assets                                       |       | 9,185  |
| Haircuts on Securities Positions                           |       |        |
| Securities Haircuts                                        |       |        |
| Undue Concentration Charges                                |       |        |
| Net Allowable Capital                                      | લ્ત્વ | 8.270  |

### Computation of Net Capital Requirement

| Minimum Net Capital Required as a Percentage of Aggregate Indebtedness | ea | 2     |
|------------------------------------------------------------------------|----|-------|
| Minimum Dollar Net Capital Requirement of Reporting Broker/Dealer      | S  | 5.000 |
| Net Capital Requirement                                                |    | 5,000 |
| Excess Net Capital                                                     |    | 3.270 |
| Computation of Aggregate Indebtedness                                  |    |       |
|                                                                        | €  | C C   |

| ിവി പുറ്റിയുമ്പം നിർഗ്ഗത്തിന്റെ                     |       |
|-----------------------------------------------------|-------|
| Percentage of Aggregate Indebtedness to Net Capital | 1.39% |

Computation of Reconciliation of Net Capital

There were no material differences reported as Net Capital in the audited computation of Net Capital and the brokerdealer's corresponding unaudited Part IIA of the FOCUS report required under Rule 15c3-1.

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### Walnut Creek Capital Advisors, LLC Supplementary Statements Net Capital Statement, Determination of Customer Reserve and Possession & Control Requirements

### Pursuant to SEA Rule 17a-5 of the Securities and Exchange Act of 1934 As of and for the year ended December 31, 2024

### Statement Related to Uniform Net Capital Rule

The Company is a member of the FINRA and is subject to the SEC Uniform Net Capital Rule 15c3-1. This rule requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 1500% (15:1), or, during its first year of operations, 800% (8:1). Net capital and the related net capital ratio may fluctuate on a daily basis. At December 31, 2024, the Company had net capital of \$8,270 in excess of its required net capital of \$5,000. The Company's ratio of aggregate indebtedness to net capital was 0.39%. The Company has elected to use the basic computation method, as is permitted by the rule, which requires that the Company maintain minimum Net Capital pursuant to a fixed dollar amount or total aggregate indebtedness, as defined, whichever is greater, and does not, therefore, calculate its net capital requirement under the alternative reserve requirement method.

### Determination of Customer Reserve Requirements

The Company operates pursuant to an exemption from 15c3-3, or no exemption purusant to footnote 74 of SEC Release 34-70073, and does not take possession of customer funds or securities and is therefore not required to compute the determination of customer reserve requirements.

### Possession and Control Requirements

The Company operates pursuant to an exemption from 15c3-3, or no exemption purusant to footnote 74 of SEC Release 34-70073, and does not take possession or control of customer funds or securities. There were no exceptions in adhering to the Company's operating exemption and/or no exemption, as applicable.

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Walnut Creek Capital Advisors, LLC

### Supplementary Customer Protection Exemption Report

Pursuant to SEA Rule 17a-5(d)(1)(i)(B)(2) Of the Securities and Exchange Act of 1934

As of and for the year ended December 31, 2024

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### Supplementary Schedules Pursuant to SEA Rule 17a-5 Of the Securities and Exchange Act of 1934 For the Year-End December 31, 2024

### Report of Independent Registered Public Accounting Firm Exemption Review Report Pursuant to 15c3-3

Exemption: 15c3-3(k)(2)(i)

Dan Fort Walnut Creek Capital Advisors, LLC 616 Elliot Road McDonough, GA 30252

Dear Dan Fort:

We have reviewed managements, included in the accompanying representation in the Exemption Report, in which Walnut Creek Capital Advisors, LLC identified 15c3-3(k)(2)(i) as the provision under 17 C.F.R. § 15c3-3(k) under which it claims exemption from 17 C.F.R. \$240.15c3-3. Walnut Creek Capital Advisors, LLC stated that it has met the 15c3-3(k)(2)(i) exemption throughout the most recent fiscal year January 01, 2024, without exception, or, with exception, as represented in the Exemption Report provided to us. Walnut Creek Capital Advisors, LLC's management is responsible for compliance with the exemption 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 Walnut Creek Capital Advisors, 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 Rule 15c3-3 under the Securities Exchange Act of 1934.

Tuttle & Bond. PLLC

Giddings, Texas March 19, 2025

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### Walnut Creek Capital Advisors, LLC

### Exemption Report

Walnut Creek Capital Advisors, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.17a-S(d)(1) and (4). To the best of its knowledge and belief, the Company states the following:

- 1. The Company claimed an exemption from 17 C.F.R. § 240.15c3-3 under the following provisions of 17 C.F.R. § 240.15c3-3(k)(1)
- 2. The Company met the identified exemption provisions in 17 C.F.R. § 240.1Sc3-30<) throughout the most recent fiscal year without exception.

I, John Williams, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true . and correct.

the Will any By: \_( Principal Executive Officer / Chief Compliance Officer Walnut Creek Capital Advisors, LLC

February 28, 2025


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
