# TORA TRADING SERVICES, LLC X-17A-5 (2022-02-28) — Broker-dealer annual report - Company: TORA TRADING SERVICES, LLC - Form: X-17A-5 - Filed: 2022-02-28 - Period: 2021-12-31 - Accession: 0001325845-22-000001 - CIK: 1325845 - File #: 8-66925 - Type: Broker-dealer - Material weakness: No - Auditor: Armanino LLP - Auditor location: San Jose, CA - Contact: Paul Catuna - Phone: 415-546-2293 - Email: paul.catuna@tora.com - Website: tora.com - Signed by: Paul J Catuna (Chief Financial Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1325845/000132584522000001/TTSLSEC22822.pdf --- {0}------------------------------------------------ # Tora Trading Services, LLC (SEC ID. No. 8-66925) Financial Statements and Supplemental Schedules for the Year Ended December 31, 2021 and Report of Independent Registered Public Accounting Firm Public Document (Pursuant to Rule 17a-5(e)(3) under the Security and Exchange Act of 1934) {1}------------------------------------------------ UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: Expires: Estimated average burden hours per response: > SEC FILE NUMBER 8-66925 # ANNUAL REPORTS FORM X-17A-5 PART III 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 \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ AND ENDING \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ MM/DD/YY MM/DD/YY 01/01/22 12/31/22 A. REGISTRANT IDENTIFICATION #### NAME OF FIRM: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Tora Trading Services, LLC TYPE OF REGISTRANT (check all applicable boxes): Broker-dealer Security-based swap dealer Major security-based swap participant Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) #### \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ 1440 Chapin Avenue, Suite 205 | | (No. and Street) | | | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|--------------------------------------------|----------------------| | Burlingam
_____________________________________________________________________________________ | California | | 94010 | | (City) | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | Paul Catuna
_____________________________________________________________________________________ | (415)546-2293 | | paul.catuna@tora.com | | (Name) | (Area Code – Telephone Number) | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
Armanino LLP
_____________________________________________________________________________________ | (Name – if individual, state last, first, and middle name) | | | | 50 w San Fernando St., Suite 500
_____________________________________________________________________________________ | San Jose | California | 95113 | | (Address) | (City) | (State) | (Zip Code) | | 10/20/2003
_____________________________________________________________________________________ | | 32 | | | (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 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-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}------------------------------------------------ {3}------------------------------------------------ | Jumber of Pages | Document Date | | |-----------------|---------------|--| - - - - - - - {4}------------------------------------------------ ### TABLE OF CONTENTS #### This report \*\* contains (check all applicable boxes): | [x] | | Report of Independent Registered Public Accounting Firm. | |-----|-----|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | [x] | (a) | Facing page. | | [x] | (b) | Statement of Financial Condition. | | [x] | (c) | Statement of Income. | | [x] | (d) | Statement of Cash Flows. | | [x] | (e) | Statement of Changes in Member's Equity. | | | (f) | Statement of Changes in Subordinated Liabilities or Claims of General
Creditors (not applicable). | | [x] | (g) | Computation of Net Capital. | | [x] | (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 (not applicable). | | | (j) | A Reconciliation, including appropriate explanations, of the Computation
of Net Capital Under Rule 15c3-1 (not required) and the Computation for
Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-
3 (not applicable). | | | (k) | A Reconciliation between the audited and unaudited Statements of
Financial Condition with respect to methods of consolidation (not
applicable). | | [x] | (l) | An Oath or Affirmation. | | [x] | (m) | A copy of the SIPC Supplemental Report (filed separately). | | [x] | (n) | A Report Describing the Broker-Dealer's Compliance with the Exemption
Provisions of Section k of SEC Rule 15c3-3 (the "Exemption Report") and
Report of Independent Registered Public Accounting Firm Thereon (filed
separately). | \*\* For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3). {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) ![](_page_5_Picture_14.jpeg) {6}------------------------------------------------ ### STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2021 #### Assets | TORA TRADING SERVICES, LLC | | |--------------------------------------------------------------------|-----------------| | STATEMENT OF FINANCIAL CONDITION
DECEMBER 31, 2021 | | | Assets | | | Cash and cash equivalents | \$
2,190,502 | | Due from member | 1,558,688 | | Due from broker | 4,654 | | Prepaid expenses and other assets | 34,116 | | Property and equipment - net of \$253,949 accumulated depreciation | 59,628 | | Lease - right of use - net of \$5,450 accumulated depreciation | 160,245 | | Total assets | \$
4,007,833 | | Liabilities and Member's Equity | | | Accounts payable and accrued expenses | \$
237,904 | | Accrued compensation | 264,979 | | Lease liability | 173,834 | | Total liabilities | 676,717 | | Member's equity | 3,331,116 | | Total liabilities and member's equity | \$ 4,007,833 | {7}------------------------------------------------ ### STATEMENT OF INCOME YEAR ENDED DECEMBER 31, 2021 | TORA TRADING SERVICES, LLC | | |-------------------------------|-----------------| | STATEMENT OF INCOME | | | YEAR ENDED DECEMBER 31, 2021 | | | Revenues: | | | Service | \$
5,407,969 | | Commissions | 2,938,396 | | Total revenues | 8,346,365 | | Expenses: | | | Compensation | 6,740,379 | | Cost of commissions | 307,636 | | Rent | 239,473 | | Research fees | 221,467 | | Telecommunications | 90,947 | | Recruiting | 74,050 | | Travel and entertainment | 71,833 | | Outside services | 53,544 | | Depreciation and amortization | 40,333 | | Regulatory fees | 26,878 | | Legal and professional fees | 27,181 | | Other | 111,031 | | Total expenses | 8,004,752 | | Net income | \$
341,613 | {8}------------------------------------------------ ### STATEMENT OF CHANGES IN MEMBERS EQUITY YEAR ENDED DECEMBER 31, 2021 | TORA TRADING SERVICES, LLC | | |-------------------------------------------------------------------------|--------------| | STATEMENT OF CHANGES IN MEMBER'S EQUITY
YEAR ENDED DECEMBER 31, 2021 | | | Member's equity - January 1, 2021 | \$ 2,949,417 | | Stock-based compensation | 40,086 | | Net income | 341,613 | | | \$ 3,331,116 | | Member's equity - December 31, 2021 | | {9}------------------------------------------------ ### STATEMENT OF CASH FLOWS YEAR ENDED DECEMBER 31, 2021 | TORA TRADING SERVICES, LLC | | |-----------------------------------------------------------------------------------|--------------------| | | | | STATEMENT OF CASH FLOWS
YEAR ENDED DECEMBER 31, 2021 | | | Cash flow from operating activities: | | | Net income | \$
341,613 | | Adjustments to reconcile net income to net cash provided by operating activities: | | | Depreciation and amortization | 40,333 | | Stock-based compensation | 40,086 | | Changes in assets and liabilities: | | | Due from member | (20,099) | | Due from broker | (634) | | Prepaid expenses and other assets | 28,841 | | Accounts payable and accrued expenses | (127,960) | | Accrued compensation
Leases - right of use | (99,567)
74,401 | | Lease liability | (88, 646) | | Net cash provided by operating activities | 188,368 | | Cash flows from investing activities: | | | Purchase of property and equipment | (22,308) | | Net cash used in investing activities | (22,308) | | Cash flows from financing activities: | | | Repayment of note payable | (428,400) | | Net cash used in financing activities | (428,400) | | Net decrease in cash and cash equivalents | (262,340) | | Cash and cash equivalents - beginning of year | 2,452,842 | | Cash and cash equivalents - end of year | \$
2,190,502 | {10}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS AS OF AND FOR THE YEAR ENDED DECEMBER 31, 2021 #### 1. Organization Tora Trading Services, LLC (the Company) is organized as a Delaware limited liability company and operates in the United States. The Company is a securities broker dealer registered with the Securities and Exchange Commission and is a member of the Financial Industry Regulatory Authority (FINRA) and National Futures Association (NFA). The Company operates as an introducing broker dealer and does not hold funds or securities for customers, and does not owe any money or securities to customers. The Company is wholly owned by Tora Trading Services Limited, a Cayman Islands company (the Member). The Member is a wholly owned subsidiary of Tora Holdings, Inc. (the Parent Company or Tora Holdings), a Delaware corporation. Tora Holdings is a provider of execution and trade order management systems for hedge funds, asset managers, and proprietary trading desks. The Member delegates certain services to the Company, including outsourced trading. The Company refers trades to Tora Trading Services Limited, Hong Kong, a wholly owned subsidiary of the Member, and other nonaffiliated broker dealers. #### 2. Summary of Significant Accounting Policies Basis of Presentation The accompanying financial statements of the Company have been presented in conformity with accounting principles generally accepted in the United States of America (U.S. GAAP). The Companys results of operations and financial position could differ significantly from the financial position and results that would have been achieved if the Company was not owned by the Member and Tora Holdings. Use of Estimates The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect certain reported amounts and disclosures. Accordingly, actual results could differ from those estimates. Service Revenue The Company earns revenue by providing its Member services. The Company earns cost plus 5% for expenses incurred in the ordinary course of business and cost for certain other expenses such as employee bonuses and stock based compensation. Revenue is recognized at the time the expenses are incurred. Commission Revenue The Company also derives revenue from commissions which are earned when the Company executes trades as a broker for end users. Commissions are recorded on a trade date basis, which is when the Companys performance obligations in generating the commissions have been substantially completed. It is the Companys judgment that the geographical location and contracts of the end users do not affect the nature, timing, or certainty of revenue or cash flow, and therefore do not warrant disaggregation. Cash and Cash Equivalents The Company considers all demand deposits held in banks and certain highly liquid investments with maturities of 90 days or less at acquisition, other than those held for sale in the ordinary course of business, to be cash equivalents. The Company holds cash in financial institutions in excess of FDIC insured limits. The Company periodically reviews the financial condition of the institutions and assesses the credit risk. {11}------------------------------------------------ Due from Member The Company collects service revenue from the Member. The Company considers Due from Member to be fully collectible, and accordingly, no allowance for doubtful accounts has been provided. If amounts become uncollectible, they will be charged to operations when that determination is made. Due from Broker The Company collects commission revenue from its prime broker once the trades it executes are settled. The Company considers Due from Broker to be fully collectible, and accordingly, no allowance for doubtful accounts has been provided. If amounts become uncollectible, they will be charged to operations when that determination is made. Property and Equipment Property and equipment are valued at cost. Depreciation is being provided by the use of the straight-line method over the estimated useful lives of the assets. Income Taxes As a single member limited liability company, the Company is not directly liable for income taxes. Accordingly, federal and state income taxes have not been reflected in the accompanying financial statements. Fair Value of Financial Instruments The carrying amounts of cash and cash equivalents, the amount due from broker, accounts payable and accrued liabilities approximate fair values because of the short-term maturities and/or liquid nature of these assets and liabilities. Unless otherwise indicated, the fair values of all reported assets and liabilities which represent financial instruments (none of which are held for trading purposes) approximate the carrying values of such amounts. #### 3. Net Capital Requirements The Company is subject to the Securities and Exchange Commissions uniform net capital rule (Rule 15c3-1) which requires the Company to maintain a minimum net capital equal to or greater than \$250,000 and a ratio of aggregate indebtedness to net capital not exceeding 15 to 1, both as defined. At December 31, 2021, the Companys net capital was \$1,678,684, which exceeded the minimum requirement by \$1,428,684. The Companys ratio of aggregate indebtedness to net capital at December 31, 2021 was 0.31 to 1. {12}------------------------------------------------ #### 4. Leases | The Company leases office space under non-cancelable operating leases with various expiration dates
through 2022. Some of the leases include options to extend the leases for up to 2 years, but the Company
is not reasonably certain that it will exercise the option. Supplemental balance sheet information related
to leases is as follows: | | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------| | Operating Leases | | | Operating lease - right of use asset | \$
160,245 | | Operating lease liability - current
Operating lease liability | 173,834
- | | Total operating lease liability | \$ 173,834 | | Finance Leases | | | Finance lease - right of use asset (net) | - | | The components of lease expense are as follows: | | | Operating lease cost | \$
187,265 | | Supplemental cash flow information related to leases is as follows: | | | Operating cash payments for operating leases | \$
193,077 | | At December 31, 2021, the Company had a weighted average remaining lease term of 0.9 years for its
operating leases, and a weighted average discount rate of 2.5% for its operating leases. | | | Maturities of the Company's lease liabilities are as follows: | | | Year ending | Operating
Leases | | 2022 | \$
175,991 | | | | | At December 31, 2021, the Company had a weighted average remaining lease term of 0.9 years for its
operating leases, and a weighted average discount rate of 2.5% for its operating leases. | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | | | Operating
Leases | | \$
175,991
- | | 175,991
(2,157) | | | | \$
173,834 | | | {13}------------------------------------------------ #### 5. Note Payable In 2021, the Company repaid a \$428,400 promissory note issued by a bank pursuant to the Payment Protection Program (PPP) established under the Coronavirus Aid Relief, and Economic Security Act. The loan was issued in 2020 and included interest at a rate of 1% per annum. Under the terms of the PPP loan certain amounts could be forgiven if used for qualifying costs. While management believes the use of the funds met the terms of forgiveness, it repaid the principal and \$4,307 of interest. #### 6. Stock-Based Compensation ### Stock Options | Stock-Based Compensation | | | | | | | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|--------------------------------------------|-----------------------------------------------------------------------|--|--|--| | Stock Options | | | | | | | | Under the Tora Holdings 2010 Equity Incentive Plan ("2010 Plan") and the Tora Holdings 2020 Equity
Incentive Plan ("2020 Plan"), the Parent Company grants stock options to employees of the Company.
The Company records the related expense amounts in compensation expense. Generally, stock options
granted under the plan vest at a rate of 2.08% per month. All options expire 10 years from the date of
grant. | | | | | | | | The following table summarizes stock option activity for employees of the Company: | | | | | | | | | Options
Outstanding | Weighted
Exercise
Price | Weighted
Average
Remaining
Contractual
Term
(in years) | | | | | Outstanding at January 1, 2021
Granted
Exercised
Cancelled
Outstanding at December 31, 2021 | 675,950
145,500
-
-
821,450 | \$
4.17
4.53
-
-
\$
4.23 | 6.96 | | | | | Options exercisable at December 31, 2021 | 672,000 | \$
4.18 | 6.44 | | | | | | | | | | | | At December 31, 2021, all outstanding options have either vested or are expected to vest. The weighted average grant-date fair value was \$1.65. At December 31, 2021, there was \$217,521 of unrecognized compensation cost related to stock options, which will be recognized over the remaining weightedaverage vesting period of 3.4 years. In 2021, the Company recognized \$40,086 of compensation costs related to stock options. The cost of stock options is determined using the Black-Scholes option pricing model on the date of grant. The table below summarizes the weighted-average assumptions used during 2021: {14}------------------------------------------------ | Risk-free interest rate
Expected lives (in years) | 69.0%
6.0 | |------------------------------------------------------|--------------| | Dividend yield | - | | Expected volatility | 32.0% | | Fair value | \$
1.45 | | | | | Employee Benefit Plan | | #### 7. Employee Benefit Plan The Companys 401(k) profit sharing plan covers all employees who are over the age of 21 and will be employed for at least 1,000 hours of service per year of eligibility. The plan provides for matching employee contributions of 100% of the elective deferral which does not exceed 5% of compensation up to \$3,500. All employer contributions vest immediately. For the year ended December 31, 2021, the Company made matching contributions to the plan of \$86,672. #### 8. Subsequent Events The Company evaluated subsequent events through February 15, 2022, the date the financial statements were available to be issued. \* \* \* \* \* \* {15}------------------------------------------------ # SUPPLEMENTAL INFORMATION {16}------------------------------------------------ ### DECEMBER 31, 2021 COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION | TORA TRADING SERVICES, LLC | | | |----------------------------------------------------------------------------------------------------------------|-----------------|--| | COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF
THE SECURITIES AND EXCHANGE COMMISSION
DECEMBER 31, 2021 | | | | Net Capital -- | | | | Total member's equity | \$
3,331,116 | | | Less: Nonallowable assets: | | | | Due from member | 1,558,688 | | | Prepaid expenses and other assets | 34,116 | | | Property and equipment (net) | 59,628 | | | Total nonallowable assets | 1,652,432 | | | Net Capital Before Haircut | 1,678,684 | | | Less: Haircut on securities | - | | | Net capital | 1,678,684 | | | Net minimum capital requirement of 6 2/3% of aggregate indebtedness of | | | | \$516,472 or \$250,000 whichever is greater | 250,000 | | | Excess Net Capital | \$
1,428,684 | | | Aggregate indebtedness | 516,472 | | | Aggregate indebtedness to net capital | 0.31 | | | | | | | | | | | | | | There were no material differences between the above computation and the computation included in the Companys unaudited December 31, 2021 FOCUS Report. {17}------------------------------------------------ #### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS PURSUANT TO RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31, 2021 The Company is exempt from the provisions of Rule 15c3-3 pursuant to paragraph k(2)(ii) of such Rule under the Securities Exchange Act of 1934 as it is an introducing broker or dealer, clears all transactions with and for customers on a fully disclosed basis with a clearing broker or dealer, and does not otherwise hold funds or securities for, or owe money or securities to, customers. Operating under such exemption, the Company has not prepared a Determination of Reserve Requirements for Brokers or Dealers. {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) Tora Trading Services, LLC 1440 Chapin Avenue, Suite 205 Burlingame, CA 94010 Tel +1 (650) 513-6700 Fax +1 (650) 284-2117 Tora Trading Services, LLCs Exemption From SEC Rule 15c3-3 We as members of management of Tora Trading Services, LLC, (the Company) are responsible for complying with 17 C.F.R. §240.17a-5, Reports to be made by certain brokers and dealers and complying with 17 C.F.R. §240.15c3-3(k): (2)(ii) (the "exemption provisions"). This Exemption Report was prepared as required by 17 C.F.R. § 240.17a-5(d)(4). To the best of our knowledge and belief we state the following: (1) We identified the following provisions of 17 C.F.R. § 15c3-3(k) under which the Company claimed an exemption from 17 C.F.R. § 240.15c3-3(k): (2)(ii) and (2) we met the identified exemption provisions from January 1, 2021 to December 31, 2021 without exception. Paul J. Catuna Chief Financial Officer February 15, 2022 {19}------------------------------------------------ ![](_page_19_Picture_0.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON THE REPORT ON EXEMPTION FROM SEC RULE 15c3-3 OF TORA TRADING SERVICES LLC FOR THE YEAR ENDED DECEMBER 31, 2021 To the Board of Directors and Member of Tora Trading Services, LLC Burlingame, California We have reviewed management's statements, included in the accompanying Tora Trading Services, LLC Report on Exemption From SEC Rule 15c3-3 for the year ended December 31, 2021, in which (1) Tora Trading Services, LLC (the "Company") identified the following provision of 17 C.F.R. §15c3-3(k) under which the Company claimed an exemption from 17 C.F.R. §240.15c3-3 paragraph (k)(2)(ii) (the "exemption provisions") and (2) the Company stated that it met the identified exemption provisions throughout the most recent fiscal year without exception. The Company'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 the Company's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934. ArmaninoLLP San Jose, California February 15, 2022 ![](_page_19_Picture_9.jpeg) {20}------------------------------------------------ ![](_page_20_Picture_0.jpeg) ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES ON SCHEDULE OF ASSESSMENT AND PAYMENTS (Form SIPC-7) To the Board of Directors and Member of Tora Trading Services, LLC Burlingame, California We have performed the procedures included in Rule 17a-5(e)(4) of the Securities and Exchange Act of 1934 and in the Securities Investor Protection Corporation ("SIPC") Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation ("Form SIPC-7") for the year ended December 31, 2021. Management of Tora Trading Services, LLC (the "Company") is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7. Management of the Company has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting you and SIPC in evaluating the Companys compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2021. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows. - 1. Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement recording entries, noting no differences; - 2. Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17A-5 Part III for the year ended December 31, 2021 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31, 2021, noting no differences; - 3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences; - 4. Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments, noting no differences; and - 5. Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed, noting no differences. We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the American Institute of Certified Public Accountants and in accordance with the standards of the Public Company Accounting Oversight Board (United States). and in accordance with attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to and did not conduct an examination or a review engagement, the objective of which would be the expression of an opinion or conclusion, respectively, on the Company's Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2021. ![](_page_20_Picture_11.jpeg) {21}------------------------------------------------ Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. We are required to be independent of the Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement. This report is intended solely for the information and use of Tora Trading Services, LLC and SIPC and is not intended to be and should not be used by anyone other than these specified parties. ArmaninoLLP San Jose, California February 15, 2022 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.