# OBJECTIVE EQUITY, LLC X-17A-5 (2025-01-16) — Broker-dealer annual report - Company: OBJECTIVE EQUITY, LLC - Form: X-17A-5 - Filed: 2025-01-16 - Period: 2024-09-30 - Accession: 0001293168-25-000001 - CIK: 1293168 - File #: 8-66541 - Type: Broker-dealer - Material weakness: No - Auditor: Rubio CPA, PC - Auditor location: Atlanta, GA - Contact: Brian Megenity - Phone: 7702636003 - Email: bmegenity@bdcaonline.com - Website: bdcaonline.com - Signed by: David Riedel (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1293168/000129316825000001/oeaudit.pdf --- {0}------------------------------------------------ #### **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** | 0MB APPROVAL | | |---------------------------|--| | 0MB Number: 3235-0123 | | | Expires: Nov. 30, 2026 | | | Estimated average burden | | | hours per response:
12 | | # **ANNUAL REPORTS FORM X-17A-S PART** Ill | SEC Fl LE NUMBER | | |------------------|--| | 8-66541 | | | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | FACING PAGE | | | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|-----------------------------------------|----------------------------------------------| | FILING FOR THE PERIOD BEGINNING 10/01 /23 | | AND ENDING 09/30/24 | | | | MM/DD/VY | | MM/DD/VY | | | A. REGISTRANT IDENTIFICATION | | | | NAME oF FIRM: Objective Equity, LLC d/b/a ARC Group Securities LLC | | | | | TYPE OF REGISTRANT (check all applicable boxes):
D Security-based swap dealer
~ Broker-dealer
□ Check here if respondent is also an OTC derivatives dealer | | D Major security-based swap participant | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | 380 Bretana Way | | | | | | (No. and Street) | | | | Green brae | CA | | 94904 | | (City) | (State) | | (Zip.Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | Brian Megenity | 770-263-6003 | | bmegenity@bdcaonline.com | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
RUBIO CPA, PC | | | | | | (Name - if individual, state last, first, and middle name) | | | | 3500 Lenox Road NE, Suite 1500 Atlanta | | GA | 30326 | | (Address)
05/05/2009 | (City) | (State)
3514 | (Zip Code) | | l"
of RegistcaUoa with PCAOB)lif applicable I | FOR OFFICIAL USE ONLY | | (PCAOB Registcatioa N,mbec, if applicable) I | \* 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-S(e)(l)(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 0MB control number.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | I, David Riedel | | | swear (or affirm) that, to the best of my knowledge and belief, the | |------------------------------------------------------------------|----|--|-----------------------------------------------------------------------------------| | financial report pertaining to the firm of Objective Equity, LLC | | | as of | | September 30 | 2~ | | 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. See Attached Certificate\_]) N Signatu::f/~ Title: Notary Public #### **This filing\*\* contains (check all applicable boxes):** - ~ (a) Statement of financial condition. - □ (b) Notes to consolidated statement offinancial condition. - ii!!I (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). - iii!! (d) Statement of cash flows. - ~ (e) Statement of changes in stockholders' or partners' or sole proprietor' s equity. - D (f) Statement of changes in liabilities subordinated to claims of creditors. - ii!!! (g) Notes to consolidated financial statements. - ii!!I (h) Computation of net capital under 17 CFR 240.1Sc3-1 or 17 CFR 240.18a-l, as applic,able. - □ (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 (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. - D (I) 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. - D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.1Sc3-3{p)(2) or 17 CFR 240.18a-4, as applicable. - ii!!! (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.1Sc3-1, 17 CFR 240.18a-l, or 17 CFR 240.18a-2, as applicable, and the reserve requirement s 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. - **l!!!!I** (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. - D (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - iii!! (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - D (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 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. - **!iii!!!** (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable. - D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.1Sc3-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 240.17a-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 240.18a-7{d}(2}, as applicable. {2}------------------------------------------------ | ACKNOWLEDGMENT | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | A notary public or other officer completing this
certificate verifies only the identity of the individual
who signed the document to which this certificate is
attached, and not the truthfulness, accuracy, or
validity of that document. | | State of California
_________ _,
County of _}_l\_~-"-~_'V' | | | | R \~€. \
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personally appeared
who proved to me on the basis of satisfactory evidence to be the personW'whose name~➔ is/afe
subscribed to the within instrument and acknowledged to me that he/sl:te/tJ.re'y executed the same in
his/he'f7th.Eefr authorized capacity(i66J, and that by his/bef/lt!eir signature~ on the instrument the
person~, or the entity upon behalf of which the perso~ acted, executed the instrument. | | I certify under PENAL TY OF PERJURY under the laws of the State of California that the foregoing
paragraph is true and correct. | | WITNESS my hand and official seal. | | (Seal) | {3}------------------------------------------------ OBJECTIVE EQUITY, LLC GED\$5&\*URXS6HFXULWLHV//& Financial Statements For the Year Ended 6HSWHPEHU 30, 20 With 5HSRUWRI,QGHSHQGHQW5HJLVWHUHG3XEOLF\$FFRXQWLQJ)LUP {4}------------------------------------------------ Suite 1500 Atlanta, GA 30326 770-690-8995 ## **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of Objective Equity, LLC dba ARC Group Securities LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Objective Equity, LLC (the "Company") as of September 30, 2024, the related statements of operations, changes in member's equity, and cash flows for the year then ended and the related notes ( collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly , in all material respects, the financial position ofthe Company as of September 30, 2024, and the results of its operations and 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 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 . 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 audit, we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion. Our audit included performing procedures to assess the risks of material misstatement to 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. #### Supplemental Information The information contained in Schedules I, II and III has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determining whether the information in Schedules I, II and III 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 accompanying schedules. In forming our opinion on the accompanying schedules, we evaluated whether the supplemental information, including its form and content, is presented {5}------------------------------------------------ in conformity with 17 C.F.R. §240. l 7a-5. In our opinion, the aforementioned supplemental 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 2019. January 16, 2025 Atlanta, Georgia ![](_page_5_Picture_3.jpeg) {6}------------------------------------------------ # **Objective Equity, LLC (dba ARC Group Securities LLC) Statement of Financial Condition September 30, 2024** #### **Assets** | Cash
Accounts receivable | \$
58,948
316,540 | |---------------------------------------|-------------------------| | Prepaid expenses | 164 | | Total assets | \$
375,652 | | | | | Liabilities and member's equity | | | Liabilities | | | Accounts Payable and Accrued Expenses | \$
12,999 | | Total Liabilities | 12,999 | | Member's equity | 362,653 | | Total liabilities and member's equity | \$
375,652 | {7}------------------------------------------------ # **Objective Equity, LLC (dba ARC Group Securities LLC) Statement of Operations For the Year Ended September 30, 2024** | Revenues | | |-------------------|---------------| | Referral fees | \$
416,540 | | Total Revenues | 416,540 | | Expenses | | | | | | Compensation | 76,419 | | Professional fees | 94,165 | | Other | 12,982 | | Total Expenses | 183,566 | | | | | Net Income | \$
232,974 | | | | {8}------------------------------------------------ # **Objective Equity, LLC (dba ARC Group Securities LLC) For the Year Ended September 30, 2024 Statement of Changes in Member's Equity** | October 1, 2023, Balance | \$
12,679 | |-----------------------------|---------------| | Contributions | 117,000 | | Net income | 232,974 | | September 30, 2024, Balance | \$
362,653 | {9}------------------------------------------------ # **Objective Equity, LLC (dba ARC Group Securities LLC) Statement of Cash Flows For the Year Ended September 30, 2024** | Cash flows from operating activities: | | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------| | Net income | \$
232,974 | | Adjustments to reconcile net income to net cash used
by operating activities: | | | Decrease in due from related parties
Increase in accounts receivable
Decrease in prepaid expenses
Increase in accounts payable and accrued expenses
Decrease in due to related party | 3,225
(316,540)
111
7,999
(2,636) | | Net cash used by operating activities | (74,867) | | Cash flows from financing activities: | | | Contributions | 117,000 | | Net cash provided by financing activities | 117,000 | | Net increase in cash
Cash at beginning of year | 42,133
16,815 | | Cash at end of year | \$
58,948 | {10}------------------------------------------------ ### **Objective Equity, LLC (dba ARC Group Securities LLC) NOTES TO FINANCIAL STATEMENTS September 30, 2024** #### NOTE A- DESCRIPTION OF BUSINESS AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Description of Business: Objective Equity, LLC (dba ARC Group Securities LLC) (the "Company") is a broker-dealer that was organized in April 2004 as a New York limited liability company. The Company is approved to operate as a broker-dealer, with a perpetual period of duration, registered with the Securities and Exchange Commission ("SEC"). The Company is also a member of the Financial Industry Regulatory Authority ("FINRA"). The Company provides research and corporate advisory services. The Company's customers are primarily corporations and financial institutions located throughout the United States. As a limited liability company, the member's liability is limited to its investments. Cash: The Company maintains its bank accounts in a high credit quality financial institution. The balances at times may exceed federally insured limits. Accounts Receivable: 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 receivable 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 trends. Based on management's review, no allowance for credit losses is considered to be necessary. Income Taxes: The Company is a single-member limited liability company and is not recognized as a reporting entity under the Internal Revenue Code for taxation purposes. Accordingly, the Company does not file a separate income tax return. The effects of the Company's operations are passed through to the member for taxation purposes. Accordingly, no provision for income tax has been provided for in the accompanying financial statements. Under the provisions of FASB Accounting Standards Codification 740-10 (ASC 740-10), Accounting for Uncertainty in Income Taxes, 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's status, including its status as a pass-through entity, and the decision not to file a return. The Company has evaluated each of its tax positions and has determined that it has no uncertain tax positions for which a provision or liability for income taxes is necessary. Revenue Recognition: Revenue from contracts with customers includes placement and advisory services as well as referral fees. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transactions prices where multiple performance obligations are identified; when to recognize revenue based on appropriate measure of the Company's progress under the contract; whether revenue should {11}------------------------------------------------ ## **Objective Equity, LLC (dba ARC Group Securities LLC) NOTES TO FINANCIAL STATEMENTS September 30, 2024** #### NOTE A- DESCRIPTION OF BUSINESS AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) ### Revenue Recognition (continued): be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events. The Company provides placement and advisory services related to capital raising activities and mergers and acquisition transactions. Revenue for advisory arrangements is generally recognized at the point in time that performance under the agreement is completed (the closing of the transaction). In some circumstances, significant judgment is needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract. Retainers and other fees received from customers prior to recognizing the revenue would be reflected as unearned income. The Company recognizes success fee revenues upon the completion of a success fee based transaction as this satisfies the only performance obligation identified by the Company. The Company earns referral fees pursuant to a referral agreement in place with another brokerdealer. Revenue from this agreement is based upon a percentage of revenues generated by customers introduced by the Company to the contra-party to the agreement. As the revenue to be received by the contra-party is not known until the execution of each transaction, the referral fee revenue of the Company is unable to be recognized until that time. Basis of Presentation: The Company maintains its accounting records on an accrual basis and follows Generally Accepted Accounting Principles (GAAP), as established by the Financial Accounting Standards Board (the FASB), to ensure consistent reporting of financial condition, results of operation, and cash flows. Use of 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. Date of Management's Review: Subsequent events were evaluated through the date the financial statements were issued. ## NOTE B - NET CAPITAL The Company, as a registered broker dealer, is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule l5c3-l), which requires the maintenance of minimum net capital, equal to the greater of \$5,000 or 6 2/3% of aggregate indebtedness and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed {12}------------------------------------------------ ### **Objective Equity, LLC (dba ARC Group Securities LLC) NOTES TO FINANCIAL STATEMENTS September 30, 2024** #### NOTE B – NET CAPITAL (CONTINUED) 15 to 1. At September 30, 2024, the Company's net capital was \$45,949, which was \$40,949 in excess of its required net capital of \$5,000 and its ratio of aggregate indebtedness to net capital was 0.28 to 1.00. #### NOTE C – CONTINGENCIES The Company is subject to litigation in the normal course of business. The Company has no litigation in progress at September 30, 2024. ## NOTE D – RELATED PARTY TRANSACTIONS The Company operates from office space provided by its President at no cost. The Company has a services agreement with its President. Pursuant to the terms of the agreement, the President is compensated for supervisory and management services performed that are consistent with those typically performed by a General Securities Principal (Series 24) as such term is defined in FINRA Rule 1220(a)(2), an Investment Banking Principal as such term is defined in FINRA Rule 1220(a)(5), such compliance services performed by the Chief Compliance Officer of the Company, such management services performed by the Chief Executive Officer of the Company, and such other duties commensurate with such positions as specified or designated by the Company from time to time. The Company expensed approximately \$76,419 pursuant to this agreement during the year ended September 30, 2024, which has been included in compensation expense within the accompanying statement of operations. Financial position and results of operations could differ from the amounts in the accompanying financial statements if these related party transactions did not exist. #### NOTE E – CONCENTRATIONS All referral fees earned during the year ended September 30, 2024, were from one customer. All of the Company's accounts receivable at September 30, 2024, are due from one customer. {13}------------------------------------------------ #### **Schedule I** #### **Objective Equity, LLC (dba ARC Group Securities LLC) Pursuant to Rule 15c3-1 of the September 30, 2024 Computation of Net Capital Securities Exchange Act of 1934** | Total member's equity qualified for net capital | \$
362,653 | |------------------------------------------------------------------------------------------|---------------| | Non-allowable assets: | | | Accounts receivable | 316,540 | | Prepaid expenses | 164 | | Total non-allowable assets | 316,704 | | Net capital before haircuts | 45,949 | | Less haircuts on securities positions | - | | Net capital | \$
45,949 | | Aggregate indebtedness | \$
12,999 | | Computation of basic net capital requirement | | | Minimum net capital required (greater of \$5,000 or
6 2/3% of aggregate indebtedness) | \$
5,000 | | Excess Net Capital | \$
40,949 | | Ratio of aggregate indebtedness to net capital | 0.28 to 1.00 | #### **Reconciliation of Computation of Net Capital** There is no significant difference between net capital above and net capital as reported on Part IIA of Form X-17a-5 as of September 30, 2024, as amended. {14}------------------------------------------------ ## **OBJECTIVE EQUITY, LLC (dba ARC Group Securities LLC)** ### SCHEDULE II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER SEA RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF SEPTEMBER 30, 2024 With respect to the Computation for Determination of Reserve Requirements under SEA Rule 15c3-3, the Company does not claim an exemption from SEA Rule 15c3-3 in reliance upon footnote 74 of SEC Release No. 34-70073 dated July 30, 2013, and as discussed in Question 8 of the related FAQ released by SEC staff on April 4, 2014. The Company does not hold customer funds or securities. #### SCHEDULE III ## INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER SEA RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF SEPTEMBER 30, 2024 With respect to the Information Relating to Possession or Control Requirements under SEA Rule 15c3-3, the Company does not claim an exemption from SEA Rule 15c3-3 in reliance upon footnote 74 of SEC Release No. 34- 70073 dated July 30, 2013, and as discussed in Question 8 of the related FAQ released by SEC staff on April 4, 2014. The Company does not hold customer funds or securities. {15}------------------------------------------------ **RUBIO CPA, PC** CERTIFIED PUBLIC ACCOUNTANTS 3500 Lenox Road NE Suite 1500 Atlanta, GA 30326 770-690-8995 # **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of Objective Equity, LLC dba ARC Group Securities LLC We have reviewed management's statements included in the accompanying Broker Dealer's Annual Exemption Report in which (1) Objective Equity, LLC did not claim an exemption from Rule l 5c3-3 in reliance upon Footnote 74 of the 2013 Release, (2) Objective Equity, LLC stated that it conducted business activities involving referring customers to another broker-dealer throughout the year ended September 30, 2024, without exception, and (3) Objective Equity, LLC stated that Objective Equity, LLC met the identified conditions for such reliance throughout the most recent fiscal year without exception. Objective Equity, 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 Objective Equity, 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 Footnote 74 of the 201 3 Release. January 16, 2025 Atlanta, GA ![](_page_15_Picture_8.jpeg) {16}------------------------------------------------ 380 Bretano Way Greenbrae, CA 94904 Tel: 212-334-6365 Fax: 212-253-4263 # . . Objective Equity, LLC . . . . . . . - # OBJECTIVE EQUITY, LLC'S EXEMPTION REPORT We, as members of management of Objective Equity, LLC (the "Company"), are responsible for complying with Rule 17a-5, "Reports to be made by certain brokers and dealers". We have performed an evaluation of the Company's compliance with the requirements of Rule 17a-5 and the exemption provisions in Rule 15c3-3(k) (the "exemption provisions") and of the 2013 Release adopting amendments to Rule 17a-5, including Footnote 74 of the 2013 Release. We have determined that the Company does not meet any of the exemption conditions of paragraph (k) of Rule 15c3-3 (i.e., paragraph (k)(1), (k)(2)(i) or (k)(2)(ii)) but also (1) does not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Exchange Act Rule 15c2-4 ("Rule 15c2-4"); (2) does not carry accounts of or for customers; and (3) does not carry PAB accounts (as defined in Rule 15c3-3) and therefore is covered by Footnote 74 of the 2013 Release. . . . . . . . . . . . . . . . . . . . . . . . . . . . . {17}------------------------------------------------ Accordingly, based on our evaluation we make the following statements to the best knowledge and belief of the Company: - 1. We reviewed the provisions of Rule §15c3-3 and related guidance stated in the SEC Staff's FAQ and confirmed that the Company relied on Footnote 74 of the 2013 Release. - 2. The Company conducted business activities involving referring customers to another broker-dealer throughout the year ended September 30, 2024, without exception. - 3. The Company met the identified conditions for such reliance throughout the period October 1, 2023, to September 30, 2024, without exception. ![](_page_17_Picture_5.jpeg) \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ David Riedel, President December 16, 2024 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.