# WOODROCK SECURITIES, L.P. X-17A-5 (2019-03-01) — Broker-dealer annual report - Company: WOODROCK SECURITIES, L.P. - Form: X-17A-5 - Filed: 2019-03-01 - Period: 2018-12-31 - Accession: 0001310705-19-000001 - CIK: 1310705 - File #: 8-66753 - Material weakness: No - Auditor: Harper & Pearson Company, P.C. - Auditor location: Houston, TX - Contact: Kristy Johnson - Phone: 2813670380 - Signed by: John Dennis, III (Designated Principal) Original filing: https://www.sec.gov/Archives/edgar/data/1310705/000131070519000001/woodrocksecurities.pdf --- {0}------------------------------------------------ WOODROCK SECURITIES, L.P. FINANCIAL STATEMENTS DECEMBER 31, 2018 {1}------------------------------------------------ UNITEDSTATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235 0123 Expires: August 31, 2020 Estimated average burden hours per response .. . . . . 12.00 # ANNUAL AUDITED REPORT FORM X-17A-5 PART III | SEC FILE NUMBER | | | |-----------------|--|--| | 8-66753 | | | ## FACING PAGE ## Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thercunder | REPORT FOR THE PERIOD BEGINNING 01/01/2018 | AND ENDING 12/31/2018 | | | |------------------------------------------------------------------------------------------------|---------------------------------------------------------|----------------|--------------------------------| | | MM/DD/YY | | MM/DD/Y Y | | | A. REGISTRANT IDENTITICATION | | | | NAME OF BROKER-DEALER: WoodPock Securities, L.P. | | | OFFICIAL USE ONLY | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | FIRM I.D. NO. | | | 4265 San Felipe, Suite 600 | | | | | | (No and Street) | | | | Houston | Texas | 77027 | | | (City) | (State) | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
John P. Dennis, III | | (713) 654-0912 | | | | | | (Area Code - Telephone Number) | | | B. ACCOUNTANT IDENTICATION | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | Harper & Pearson Company, P.C. | | | | | | (Name - if individual, state last, first, middle name } | | | | One Riverway, Suite 1900 | Houston | Texas | 77056 | | (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 | | | \*Claims for exemplion from the requirement that the annual report be covered by the opinion of an independent public accountant must 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. SEC 1410 (06-02) {2}------------------------------------------------ ## OATH OR AFFIRMATION | John P. Dennis, III | swear swear swear (or affirm) that, to the best of | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | WoodRock Securities, L.P. | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of | | of December 31 | , 2018 are true and correct. I further swear (or affirm) that | | 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 | | SANDRA GAIL SMITH
Notary Public, State of Texas
Comm. Expires 01-25-2022
Notary ID 6990127
11.2 B LL CLE PRODUCT PRODUCT PLATE | Signature
Designated Principal | | Notary Public | Title | | This report ** contains (check all applicable boxes):
V (a) Facing Page.
(b) Statement of Financial Condition.
(c) Statement of Income (Loss).
(d) Statement of Changes in Financial Condition.
(c) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
(g) Computation of Net Capital.
(h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.
(i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.
consolidation.
(I) An Oath or Affirmation.
(m) A copy of the SIPC Supplemental Report. | () () 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.
(k) A Reconciliation between the and unaudited Statements of Financial Condition with respect to methods of
(n) A report describing any material inadequacics found to have cxisted since the date of the previous andit. | \*\* For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3). ﺪ ﺍﻟﻤﻮﺿﻮﻉ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺎﺣﺔ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺎﺣﺔ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺎﺣﺔ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤ {3}------------------------------------------------ ## CONTENTS Page | Report of Independent Registered Public Accounting Firm | |---------------------------------------------------------| | Statement of Financial Condition | | Statement of Income | | Statement of Changes in Partners' Capital | | Statement of Changes in Subordinated Borrowings | | Statement of Cash Flows | | Notes to Financial Statements | | Schedule I | | Schedule II | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) ### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Board of Directors and Partners of WoodRock Securities, L.P. ### **Opinion on the Financial Statements** We have audited the acwmpanying statement of financial condition of WoodRock Securities, L.P. as of December 31, 2018, the related statements of income, changes in partneus' capital, changes in subordinated borrowings, 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 of Wood Rock Securities, L.P. as of December 31, 2018, 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 WoodRock Securities, L.P.'s management. Our responsibility is to express an opinion on WoodRock Securities, L.P.'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 WoodRock Securities, L.P. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. ### **Auditor's Opinion on Supplemental Information** The Computation of Net Capital Under Rule 1Sc3-1 of the Securities Exchange Commission and the Computation for Determination of Reserve Requirements and Information Relating to Possession or Control of Securities Under Rule 15c3-3 of the Securities Exchange Commission have been subjected to audit procedures performed in conjunction with the audit of WoodRock Securities, L.P.'s financial statements. The supplemental information is the responsibility of WoodRock Securities, L.P.'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 information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as WoodRock Securities, L.P.'s auditor since 2006. Houston, Texas February 26, 2019 One Riven.yay ·Suite 1900 ·Houston, Texas 77056-1973 · 713 .622.2310 · 713.622.5613 fax harperpearson.com {5}------------------------------------------------ ## **WOODROCK SECURITIES, L.P. STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2018** ## **ASSETS** | Cash and cash equivalents | \$ 7,698,380 | |---------------------------------|--------------| | Prepaid expenses -
affiliate | 974,238 | | Prepaid expenses | 40,001 | | TOTAL ASSETS | \$ 8,712,619 | ## **LIABILITIES AND PARTNERS' CAPnAL** | Accounts payable | \$
1,910 | |----------------------------------------|--------------| | Accrued Expenses | 6,196 | | Line of Credit -
Subordinate | 7,500,000 | | TOTAL UABILITIES | 7,508,106 | | Partners' capital | 1,204,513 | | TOTAL UABili11ES AND PARTNERS' CAPITAL | \$ 8,712,619 | {6}------------------------------------------------ | Commissions and other revenues | \$ 4,051,003 | |------------------------------------------------------------------|--------------------------| | Management fee and administrative expense
Commissions expense | (1,552,734)
(626,073) | | Net Income | \$ 1,872,196 | {7}------------------------------------------------ ## WOODROCK SECURITIES, l.P. STATEMENT OF CHANGES IN PARTNERS' CAPITAL FOR THE YEAR ENDED DECEMBER 31, 2018 | | Limited Partners | | General
Partner | | | | | | |----------------------------|-------------------------------------|---------|--------------------|-------------|--------------------------------|---------|-------|--------------| | | Texas
Capital
Bancshares, Inc | | Wood Rock,
LLC | | Wood Rock
HoldingsGP
LLC | | Total | | | Balance, December 31, 2017 | \$ | 515,430 | \$ | (105,622) | \$ | (7,739) | \$ | 402,069 | | Contributions | | 123,448 | | 1,800 | | | | 125,248 | | Distributions | | | | (1,195,000) | | | | (1,195,000) | | Net Income | | 18,722 | | 1,834,752 | | 18,722 | | 1.872.196 | | Balance, December 31, 2018 | \$ | 657,600 | \$ | 535,930 | \$ | 10,983 | | \$ 1,204,513 | {8}------------------------------------------------ ## **WOODROCK SECURITIES, L.P. STATEMENT OF CHANGES IN SUBORDINATED BORROWINGS FOR THE YEAR ENDED DECEMBER** 31, **2018** Suborinated borrowings at December 31, 2017 \$ 7,500,000 Increase: Revolving Line of Credit Subordinated borrowings at December 31, 2018 \$ 7,500,000 {9}------------------------------------------------ | CASH FLOWS FROM OPERATING ACTIVffiES | | |------------------------------------------------|-----------------| | Cash received from customers | \$ 4,307,795 | | Cash paid for management fees and expenses | (2,359,449) | | Commissions paid to affiliate | (939,918) | | Net cash provided by operating activities | 1,008,428 | | CASH FLOWS FROM FINANCING ACfiVffiES | | | Contributions | 125,248 | | Partner's Distributions | {1,195,000) | | Net cash used by financing activities | {1,069,752) | | CASH FLOWS FROM INVESTING ACTIVffiES | | | Purchase of investments | (22,500,906) | | Sale of investments | 22,602,008 | | Net cash provided by investing activities | 101,102 | | NET INCREASE IN CASH AND CASH i:QUIVALENTS | 39,778 | | CASH AND CASH EQUIVALENTS AT BEGINNING OF YEAR | 7,658,602 | | CASH AND CASH EQUIVALENTS AT END OF YEAR | | | RECONCIUATION OF NET INCOME TO NET CASH | | | PROVIDED BY OPERATING ACTIVmES | | | Net income | \$
1,872,196 | | Adjustments: | | | Gain on investment sales | (101,102)
\$ | | Change in operating assets and liabilities: | | | Increase in prepaid expense - affiliate | (750,213) | | Decrease in accounts receivable | 357,894 | | Increase in prepaid expenses | {33,t>84) | | Decrease in commission payable | (313,845) | | Decrease in accounts payable | (23,449) | | Increase in accrued expenses | 631 | | Net cash provided by operating activities | 11008,428
~ | {10}------------------------------------------------ #### NOTE A BASIS OF PRESENTATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POUCIES Description of Business - WoodRock Securities, L.P. (a Texas limited partnership) ("the Partnership") maintains its accounts on the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America (GAAP). Accounting principles followed by the Partnership and the methods of applying those principles which materially affect the determination of financial position, results of operations and cash flows are summarized below: The Partnership is located in Houston, Texas, and is a private investment banking firm. Accordingly, the Partnership has claimed an exemption from the Securities and Exchange Commission's (SEC) Rule 15c3-3 under section (K)(2)(ii). The Partnership is registered as a Broker-Dealer with the SEC, and a member of the Financial Industry Regulatory Authority (FINRA). Statement Presentation - The unclassified statement of financial condition is presented in accordance with industry standards. Estimates- The preparation of financial statements 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 revenues and expenses during the reporting period. Actual results could differ from tthose estimates. Cash and Cash Equivalents- The Partnership considers all highly liquid debt instruments with an oriQiinal maturity of three months or less to be cash equivalents. Income Taxes- The Partnership's income, losses, and tax credits will be included in the income tax returns of the Partners. Accordingly, the Partnership does not record a provision for Federal income taxes. The Partnership records Texas margin taxes if owed. Texas margin taxes recorded for the year ended December 31, 2018 were \$6,196. The Partnership believes that all significant tax positions utilized by the Partnership will more likely than not be sustained upon examination. As of December 31, 2018, the tax years that remain subject to examination by the major tax jurisdictions under the statute of limitations are from the year 2015 forward (with limited exceptions). Tax penalties and interest, if any, would be accrued as incurred and would be classified as tax expense in the statement of income. Revenue Recognition - Investment banking fees from securities related transactions are recognized when transactions close or at settlement date and receivables are recorded at this time. Retainer fees are recorded and recognized as revenue in accordance with the terms contained in the Partnership's written engagement agreements. In 2018 the Partnership's main source of revenue was from investment banking fees. During the year ended December 31, 2018 commission revenue related to investment banking transactions was \$3,418,750. This amount is included commissions and other revenues on the statement of income. In 2014, Financial Accounting Standards Board issued ASC 606, Revenue from Contracts with Customers, which superseded nearly all existing revenue recognition guidance under GAAP. The core principle of this standard is that revenue should be recognized for the amount of {11}------------------------------------------------ #### NOTE A BASIS OF PRESENTATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - Revenue Recognition (CONTINUED} consideration expected to be received for promised goods or services transferred to customers. This standard was effective for the Company for the annual reporting period beginning January 1, 2018. The Company has evaluated the new guidance and the adoption did not have an impact on the Company's financial statements and a cumulative effect adjustment under the modified retrospective method of adoption was not necessary. Management deems no allowance necessary for commissions receivable as the deal terms are agreed upon and no significant credit risk is deemed to be present. There were no commissions receivable at December 31, 2018. Related to underwriting services provided whereby the Partnership receives a referral from its limited partner Texas Capital Bancshares, Inc. (TCB), 80% of each commission earned by the Partnership will be paid to TCB. During the year ended December 31, 2018 commission expense of \$626,073 was recorded in the statement of operations related to this referral agreement. Subsequent Events- The Partnership has evaluated subsequent events through February 26, 2019, the date the financial statements were available to be issued. No subsequent events occurred which require adjustment or disclosure to the financial statements at December 31, 2018. #### NOTE B PARTNERSHIP AGREEMENT The Partnership was formed October 28, 2003. The general partner of the Partnership is WoodRock Holdings GP LLC, and the initial limited partner was WoodRock, LLC. Effective November 6, 2015 Texas Capital Bancshares, Inc became a limited partner and obtained a 1% ownership interest from the initial limited partner. The general partner maintained its ownership interest of 1% and the limited partners have a 99% owners.hip interest. All Partnership profits, losses and distributions are to be allocated to the partners in proportion to their respective percentage interests and in accordance with the Members Agreement between the parties. TCB began participating in allocations beginning in 2016. #### NOTEC MANAGEMENT AGREEMENT The Partnership entered into a management agreement with Wood Rock, LLC, a company related through common ownership, whereby WoodRock, LLC will provide administrative and operational services, facilities, furniture and pay all overhead expenses of the Partnership. WoodRock, LLC received an incremental allocation service fee of \$84,000 per month for the period January 1, 2018 through December 31, 2018. Service fees and expense allocations for 2018 totaled \$1,008,000. #### NOTED NET CAPITAL REQUIREMENTS Pursuant to the net capital provisions of Rule 15c3-1 of the Securities Exchange Act of 1934, the Partnership is required to maintain a minimum net capital, as defined under such provisions. Net capital and the related net capital ratio may fluctuate on a daily basis. {12}------------------------------------------------ #### NOTED NET CAPITAL REQUIREMENTS (CONTINUED) At December 31, 2018, the Partnership had net capital of \$7,690,274 and a net capital requirement of \$100,000. The Partnership's ratio of aggregate indebtedness to net capital was .11 to 1 at December 31, 2018. The Securities Exchange Commission permits a ratio of aggregate indebtedness to net capital for the Partnership at this time of no greater than 15 to 1. #### NOTE E CONCENTRATIONS AND CREDIT RISK The Partnership's bank balances are insured by the Federal Deposit Insurance Corporation (FDIC) up to \$250,000. It is the Partnership's practice to utilize high net worth financial institutions to minimize its credit risk. Generally, no collateral or other security is required to support trade receivables or advances to limited partner. At December 31, 2018, management determined that no allowance for doubtful accounts was necessary. For the year ended December 31, 2018, revenue from two customers represented 77% the Partnership's commission and other income. #### NOTE F SUBORDINATED BORROWINGS The borrowings under subordination agreements at December 31, 2018, are listed in the following: ### Revolving Line of Credit 7,500,000 The subordinated borrowings are from a limited partner, Texas Capital Bancshares, Inc., and are available in computing net capital under the SEC's uniform net capital rule. To the extent that such borrowings are required for the Company's continued compliance with minimum net capital requirements, they may not be repaid. The line of credit is for a total of \$15,0000,000 and matures October 26, 2020. The line bears interest at 2.0% and is payable on maturity of the line of credit advance, but can be prepaid at borrower's discretion. During 2018 the Partnership paid \$150,700 in interest on the line of credit. The principal and interest under this Agreement are fully and irrevocably subordinate in right of payment and subject to the prior payment or provision for payment in full of all claims of all other present and future creditors of the Company that are not similarly subordinated. {13}------------------------------------------------ | NET CAPITAL
Total partners' capital qualified for net capital | \$
1,204,513 | |------------------------------------------------------------------|-----------------| | Additions to net worth | | | Subordinated loan | 7,500,000 | | Total capital and allowable subordinated liabilities | 8,704,513 | | Deductions and/or charges | | | Nonallowable assets: | | | Accounts receivable | | | Prepaid expenses | 40,001 | | Prepaid expenses - affiliate | 974,238 | | NET CAPITAL BEFORE HAIRCUTS ON SECURITIES POSffiON | 7,690,274 | | Haircuts on securities | | | Net capital | \$
7,690,274 | | COMPUTATION OF BASIC NET CAPITAL REQUIREMENTS | | | Minimum net capital required (6 2/3% of total aggregate | | | indebtedness) | \$
540 | | | | | Minimum dollar net capital requirement | \$
100,000 | | Net capital requirement (greater of above two minimum | | | requirement amounts) | \$
100,000 | | Excess net capital | \$
7,590,274 | | Ratio: Aggregate indebtedness to net capital | 0.11 to 1 | | | | No material differences existed between the audited computation of net capital pursuant to Rule 15c3-1 as of December 31, 2018 and the corresponding amended unaudited filing of part IIA of the FOCUS Report/form X-17A-5 filed by WoodRock Securities, L.P. {14}------------------------------------------------ ## **WOODROCK SECURITIES, L.P. SCHEDULE** II **COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS AND INFORMATION RELATING TO POSSESSION OR CONTROL OF SECURITIES UNDER RULE 15C3-3 OF THE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31, 2018** ## Exemption Provisions The Partnership has claimed an exemption from Rule 15c3-3 under Section (k)(2)(ii), in which a "Special Account for the Exclusive Benefit of Customers" is maintained . • {15}------------------------------------------------ ![](_page_15_Picture_0.jpeg) ### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Board of Directors and Partners of WoodRock Securities, L.P. We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) WoodRock Securities, L.P. identified the following provisions of 17 C.F.R. §15c3-3(k) under which WoodRock Securities, L.P. claimed an exemption from 17 C.F.R. §240.15c3-3 (k)(2)(ii) (the exemption provisions) and (2) WoodRock Securities, L.P. stated that WoodRock Securities, L.P. met the identified exemption provisions throughout the most recent fiscal year without exception. Wood Rock Securities, L.P. '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 WoodRock Securities, L.P.'s compliance with the exemption provisions. A review is substantially less in s<:ope 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 modifiications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(2)(ii) of Rule 1Sc3-3 under the Securities Exchange Act of 1934. Houston, Texas February 26, 2019 {16}------------------------------------------------ ## **WoodRock Securities, L.P.'s Exemption Report** WoodRock Securities, L.P. (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-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: - 1. WoodRock Securities, L.P. claimed an exemption 17 C.F.R. *§* 240.1Sc3-3 under the following provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(i) for the fiscal year ended December 31, 2018. - 2. WoodRock Securities, L.,P. met the identified exemption provisions in 17 C.F.R. § 240.15c3-3{k)(2)(i) throughout the most recentflscal year of January 1, 2018 to December 31, 2018, without exception. Wood Rock Securities, L.P. I, John P. Dennis, IU, affirm that, to my best knowledge and belief, this Exemption Report Is true and correct. 11 ~~ -----\_:; .. &lfnated Principal T tl February 4, 2019 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.