# AVENTURA SECURITIES, LLC X-17A-5 (2021-03-26) — Broker-dealer annual report

- Company: AVENTURA SECURITIES, LLC
- Form: X-17A-5
- Filed: 2021-03-26
- Period: 2020-12-31
- Accession: 0001379039-21-000002
- CIK: 1379039
- File #: 8-67458
- Material weakness: No
- Auditor: RUBIO CPA, PC
- Auditor location: ATLANTA, GA
- Contact: Robert Devito
- Phone: 561-235-3528
- Email: form@sin.org
- Website: sin.org
- Signed by: DAN CAUCEGLIA (CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1379039/000137903921000002/aventuraauditreport.pdf

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### UNITEDSTATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

OMB APPROVAL OMB Number: 3235-0123 Expires: October 31, 2023 Estimated average burden hours per response .. . . . . . . 12.00

8-67458

SEC FILE NUMBER

# ANNUAL AUDITED REPORT FORM X-17A-5 PART III

FACING PAGE

Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder

| AND ENDING 12/31/2020<br>MM/DD/YY<br>OFFICIAL USE ONLY<br>FIRM I.D. NO.<br>33394<br>(Zip Code)<br>NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>(305) 466-0467<br>(Area Code - Telephone Number) |
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\*Claims for exemption 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.

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#### OATH OR AFFIRMATION

#### I DANIEL CAUCEGLIA

( the best of the swear (or affirm) that, to the best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of AVENTURA SECURITIES, LLC as a commendas of DECEMBER 31

# a see and connect of the and correct. I further swear (or affirm) that neither the company nor any partner, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows:

![](_page_1_Figure_4.jpeg)

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RUBIO CPA, PC

CERTIFIED PUBLIC ACCOUNTANTS

2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770690-8995 Fax: 770 838-7123

### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Aventura Securities. LLC

Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Aventura Securities, LLC (the "Company") as of December 31, 2020, 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 of the Company as of December 31, 2020, 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 misstatements, 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 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

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in conformity with 17 C.F.R. §240.17a-5. In our opinion, the aforemental 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 2005.

March 24, 2021 Atlanta, Georgia

Rubis CPA, PL

Rubio CPA, PC

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### **AVENTURA SECURITIES, LLC FINANCIAL STATEMENTS AND SCHEDULES**

**For the Year Ended December 31, 2020 With Report of Registered Public Accounting Firm**

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### **STATEMENT OF FINANCIAL CONDITION AVENTURA SECURITIES, LLC December 31, 2020**

#### ASSETS

| Cash<br>Accounts receivable<br>Securities owned<br>Due from clearing broker<br>Deposit with clearing broker<br>Property and equipment, at cost, less accumulated<br>depreciation of \$86<br>Prepaid expenses and other assets | \$<br>14,370<br>15,242<br>240,901<br>273,507<br>250,000<br>1,626<br>14,049 |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|
| Total assets                                                                                                                                                                                                                  | \$<br>809,695                                                              |
| LIABILITIES AND MEMBER'S EQUITY                                                                                                                                                                                               |                                                                            |
| Liabilities<br>Accounts payable and accrued expenses<br>Commissions payable<br>Accrued compensation<br>Due to clearing broker<br>Due to related parties                                                                       | \$<br>16,234<br>224,969<br>46,675<br>513<br>19,169                         |
| Total liabilities                                                                                                                                                                                                             | 307,560                                                                    |
| Member's equity                                                                                                                                                                                                               | 502,135                                                                    |
| Total liabilities and member's equity                                                                                                                                                                                         | \$<br>809,695                                                              |

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### **AVENTURA SECURITIES, LLC STATEMENT OF OPERATIONS For the Year Ended December 31, 2020**

| REVENUES                               |                 |
|----------------------------------------|-----------------|
| Commissions                            | \$<br>1,305,588 |
| Mutual fund fees                       | 89,771          |
| Principal transactions                 | 2,478           |
| Fees from related party                | 90,000          |
| Margin interest income                 | 23,629          |
| Interest and dividends                 | 1,892           |
| Total revenue                          | 1,513,358       |
| EXPENSES                               |                 |
| Commissions, compensation and benefits | 1,038,838       |
| Clearance fees                         | 259,619         |
| Technology and communications          | 56,393          |
| Occupancy and equipment                | 23,300          |
| Other                                  | 47,377          |
| Total expenses                         | 1,425,527       |
| NET INCOME                             | \$<br>87,831    |

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## **STATEMENT OF CHANGES IN MEMBER'S EQUITY AVENTURA SECURITIES, LLC For the Year Ended December 31, 2020**

| Balance, December 31, 2019 | \$<br>347,804 |
|----------------------------|---------------|
| Member Contribution        | 175,000       |
| Member Distributions       | (108,500)     |
| Net Income                 | 87,831        |
| Balance, December 31, 2020 | \$<br>502,135 |

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#### **AVENTURA SECURITIES, LLC STATEMENT OF CASH FLOWS For the Year Ended December 31, 2020**

| CASH FLOWS FROM OPERATING ACTIVITIES:<br>Net income                                                                                                                                                                                                                                                                                                                              | \$<br>87,831                                                               |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|
| Items which do not impact cash<br>Depreciation                                                                                                                                                                                                                                                                                                                                   | 86                                                                         |
| Adjustments to reconcile net income to net cash used by operating activities:<br>Increase in accounts receivable<br>Increase in deposit with clearing broker<br>Increase in due from clearing broker<br>Decrease in due from related party<br>Increase in prepaid expenses and other assets<br>Decrease in securities owned<br>Increase in accounts payable and accrued expenses | (11,896)<br>(175,000)<br>(264,584)<br>22,500<br>(2,025)<br>1,516<br>15,442 |
| Increase in commissions payable<br>Decrease in due to clearing broker<br>Increase in accrued compensation<br>Increase in due to related parties<br>Net cash used by operating activities                                                                                                                                                                                         | 224,969<br>(11,471)<br>46,675<br>5,384<br>(60,573)                         |
| CASH FLOWS FROM INVESTING ACTIVITIES:<br>Purchase of equipment<br>Net cash used by investing activities                                                                                                                                                                                                                                                                          | (1,712)<br>(1,712)                                                         |
| CASH FLOWS FROM FINANCING ACTIVITIES:<br>Member Contribution<br>Member Distributions<br>Net cash provided by financing activities                                                                                                                                                                                                                                                | 175,000<br>(108,500)<br>66,500                                             |
| NET INCREASE IN CASH                                                                                                                                                                                                                                                                                                                                                             | 4,215                                                                      |
| CASH:<br>Beginning of year                                                                                                                                                                                                                                                                                                                                                       | 10,155                                                                     |
| End of year                                                                                                                                                                                                                                                                                                                                                                      | \$<br>14,370                                                               |
| Supplemental disclosure of cash flow information<br>Cash paid during the year for interest                                                                                                                                                                                                                                                                                       | \$<br>1,408                                                                |

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### NOTE A - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

**Organization and Description of Business**: Aventura Securities, LLC (the "Company"), a Delaware Limited Liability Company organized in August 2006, is a securities broker-dealer registered with the Securities and Exchange Commission ("SEC") and the Financial Industry Regulatory Authority ("FINRA").

The Company is wholly-owned by Aventura Holdings, LLC. As a limited liability company, the member's liability is limited to their investment.

The Company operates as a "general securities" broker-dealer executing trades for institutional and retail customers. The Company does not carry customer accounts or perform custodial functions relating to customer securities. Customers of the Company are introduced to a carrying broker-dealer (clearance broker) on a fully disclosed basis. The Company's customers are located throughout the United States.

**Income Taxes**: The Company is taxed as a sole proprietorship. Therefore, the income or losses of the Company flow through to its member and no income taxes are recorded in the accompanying financial statements.

The Company has adopted the provisions of FASB Accounting Standards Codification 740-10, 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's status, including its status as a pass-through entity, and the decision not to file a tax return. The Company has evaluated each of its tax positions and has determined that no provision or liability for income taxes 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.

**Cash**: The Company maintains its cash deposits in a high credit quality financial institution. Balances at times may exceed federally insured limits.

**Securities Owned:** Securities owned consisted of mutual funds and exchange traded funds at December 31, 2020. The securities owned are valued at fair value. The resulting difference between cost and fair value, is included in income. Proprietary securities transactions are recorded on the trade date as if they had settled.

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### NOTE A - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)

**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 treads.

In June 2016, the FASB issued ASU No. 2016-13, "Financial Instruments-Credit Losses (Topic 326): Measurment of Credit Losses on Financial Instruments," which introduced an expected credit loss model for the impairment of financial assets measured at amortized cost. The model replaces the probable, incurred loss model for those assets and broadens the information an entity must consider in developing its expected credit loss estimate for assets measured at amortized costs. The Company adopted ASU No. 2016-13 on January 1, 2020 using the modified retrospective approach with no material impact to its financial position, results of operations or cash flows.

### **Revenue from Contracts with Customers:**

Revenue from contracts with customers includes commission income and fees from customers. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgement is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; whether revenue should be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events.

The Company buys and sells securities on behalf of its customers. Each time a customer enters into a buy or sell transaction, the Company charges a commission. Commissions and related clearing expenses are recorded on the trade date (the date that the Comany fills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). The Company believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified, the pricing is agreed upon and the risks and rewards of ownership of the securities have been transferred to/from the customer.

Mutual Funds or pooled investment vehicles (collectively, "funds") have entered into agreements with the Company to distribute/sell its shares to investors. Marketing or distribution fees are paid over time (12b-1 fees) on the basis of a contractual rate applied to the monthly or quarterly market value of the fund. Revenue is recognized as these fees are earned in accordance with the underlying agreements.

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

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#### NOTE B - NET CAPITAL REQUIREMENTS

The Company 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, 2020, the Company had net capital of \$454,229, which was \$433,725 more than its required net capital of \$20,504 and the ratio of aggregate indebtedness to net capital was .68 to 1.0.

#### NOTE C - OFF BALANCE SHEET RISK

In the normal course of business, the Company's customers execute securities transactions through the Company. These activities may expose the Company to off balance sheet risk in the event the customer or other broker is unable to fulfill its contracted obligations and the Company has to purchase or sell the finanial instrument underlying the contract at a loss.

#### NOTE D - CLEARANCE AGREEMENT

The Company has an agreement with a clearing broker to execute and clear, on a fully disclosed basis, customer accounts of the Company. In accordance with this agreement, the Company is required to maintain a deposit in cash or securities. Amounts receivable from its clearing broker at December 31, 2020 consist of commissions receivable and funds held in various accounts. The receivable is considered fully collectible at December 31, 2020 and no allowance is required.

Amounts payable to the clearing broker of December 31, 2020 consist of margin debt collateralized by securities owned and funds on deposit.

#### NOTE E - RELATED PARTY TRANSACTIONS

The Company has an expense sharing agreement with its member. Under the agreement, the Company pays its member monthly fees for use of office facilities, including office furniture and equipment, and other administrative services. The amount expensed in the financial statements for 2020 under the agreement is approximately \$42,678. Approximately \$7,601 of the due to related parties at December 31, 2020 arose from this agreement.

During 2020, the Company received \$90,000 of administrative fees from a related Registered Investment Advisor entity pursuant to an informal agreement. These fees primarily relate to sevices such as the execution of mutual fund, options, and fixed income trades on behalf of the related entity. Approximately \$11,568 of the due to related parties at December 31, 2020 arose from an overpayment under this agreement.

#### NOTE F - RETIREMENT PLAN

The Member has adopted a profit sharing plan that is subject to the expense sharing agreement with the Company as described in Note E. The amount expensed in the accompanying financial statements for 2020 pursuant to this plan is approximately \$13,020.

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### NOTE G - FAIR VALUE MEASUREMENTS

FASB ASC 820 defines fair value, establishes a framework for measuring fair value, and establishes a fair value hierarchy which prioritizes the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transaction to sell the asset or transfer the liability occurs in the principal market for the asset or liability or, in the absence of a principal market, the most advantageous market. Valuation techniques that are consistent with the market, income orꞏ cost approach, as specified by FASB ASC 820 are used to measure fair value.

The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels:

- Level 1 inputs are quoted prices (unadjusted) in active markets for identical assets or liabilities the Company has the ability to access.
- Level 2 inputs are inputs (other than quoted prices included within level 1) that are observable for the asset or liability, either directly or indirectly.
- Level 3 are unobservable inputs for the asset or liability and rely on management's own assumptions about the assumptions that market participants would use in pricing the asset or liability.

The following table presents the Company's fair value heirarchy for those assets and liabilities measured at fair value on a recurring basis as of December 31, 2020.

|                          | Fair Value<br>Measurements<br>December 31, 2020 | Level 1<br>Valuation | Level 2<br>Valuation | Level 3<br>Valuation |
|--------------------------|-------------------------------------------------|----------------------|----------------------|----------------------|
| Securities owned, mutual |                                                 |                      |                      |                      |
| funds, equity            | \$<br>19,683                                    | \$<br>19,683         | -                    | -                    |
| Securities owned, mutual |                                                 |                      |                      |                      |
| funds, fixed income      | 211,383                                         | 211,383              | -                    | -                    |
| Securities owned,        |                                                 |                      |                      |                      |
| exchange traded funds    | 9,835                                           | 9,835                | -                    | -                    |
| Total                    | \$<br>240,901                                   | \$<br>240,901        | -                    | -                    |

### NOTE H - 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 the Company believes that it is in an appropriate position to sustain the potential shortterm 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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### **AVENTURA SECURITIES, LLC**

### **Supplementary Information Securities Exchange Act of 1934 Pursuant to rule 17(a)-5 of the**

### **December 31, 2020**

The accompanying schedule I is prepared in accordance with the requirements and general format of FOCUS Form X-17 A-5.

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### **AVENTURA SECURITIES, LLC**

### **AND EXCHANGE COMMISSION ACT OF 1934 SCHEDULE I COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES**

#### **December 31, 2020**

| Net Capital                                                                           |    |            |
|---------------------------------------------------------------------------------------|----|------------|
| Total member's equity qualified for net capital                                       | \$ | 502,135    |
|                                                                                       |    |            |
| Accounts receivable                                                                   |    | (15,242)   |
| Property and equipment                                                                |    | (1,626)    |
| Prepaid expenses and other assets                                                     |    | (14,049)   |
|                                                                                       |    |            |
| Net capital before haircuts                                                           |    | 471,218    |
|                                                                                       |    |            |
| Less haircuts                                                                         |    | 16,989     |
|                                                                                       |    |            |
| Net capital                                                                           | \$ | 454,229    |
|                                                                                       |    |            |
|                                                                                       |    |            |
| Minimum net capital required (greater of \$5,000 or 6 2/3% of aggregate indebtedness) | \$ | 20,504     |
|                                                                                       |    |            |
| Excess net capital                                                                    | \$ | 433,725    |
|                                                                                       |    |            |
| Aggregate Indebtedness:                                                               |    |            |
| Liabilities                                                                           | \$ | 307,560    |
|                                                                                       |    |            |
| Ratio of aggregate indebtedness to net capital                                        |    | .68 to 1.0 |
|                                                                                       |    |            |

RECONCILIATION WITH COMPANY'S COMPUTATION OF NET CAPITAL INCLUDED IN PART IIA OF FORM X-17A-5 AS OF DECEMBER 31, 2020.

There was no significant difference between net capital in Part IIA of Form X-17A-5 and net capital above.

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### **AVENTURA SECURITIES, LLC**

### **SCHEDULE II COMPUTATION FOR DETERMINATION OF THE RESERVE REQUIREMENTS UNDER THE SECURITIES AND EXCHANGE COMMISSION RULE 15c3-3 December 31, 2020**

The Company is not required to file the above schedules as it is exempt from Securities and Exchange Commission Rule 15c3-3 under paragraph (k)(2)(ii) of the rule and does not hold customers' monies or securities.

### **INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER THE SECURITIES AND EXCHANGE COMMISSION RULE 15c3-3 December 31, 2020 SCHEDULE III**

The Company is not required to file the above schedules as it is exempt from Securities and Exchange Commission Rule 15c3-3 under paragraph (k)(2)(ii) of the rule and does not hold customers' monies or securities.

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CERTIFIED PUBLIC ACCOUNTANTS

RUBIO CPA, PC

2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770690-8995 Fax: 770 838-7123

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Aventura Securities, LLC

We have reviewed management's statements included in the accompanying Broker Dealers Annual Exemption Report in which (1) Aventura Securities, LLC identified the following provisions of 17 C.F.R. § 15c3-3(k) under which Aventura Securities, LLC claimed an exemption from 17 C.F.R. § 240.15c3-3: (k)(2)(ii) (the "exemption provisions"); and, (2) Aventura Securities, LLC stated that Aventura Securities, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. Aventura Securities, 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 Aventura Securities, LLC's compliance with the exemptions. 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)(i), of Rule 15c3-3 under the Securities Exchange Act of 1934.

March 24, 2021 Atlanta, GA

Rubio CPA. PC

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![](_page_17_Picture_0.jpeg)

### BROKER DEALERS ANNUAL EXEMPTION REPORT

Aventura Securities, LLC claims an exemption from the provisions of Rule 15c3-3 under the Securities and Exchange Act of 1934, pursuant to paragraph (k)(2)(ii) of the Rule.

Aventura Securities, LLC met the aforementioned exemption provisions throughout the most recent year ended December 31, 2020 without exception.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Daniel Cauceglia March 8, 2021

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CERTIFIED PUBLIC ACCOUNTANTS

RUBIO CPA, PC

2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770690-8995 Fax: 770 838-7123

### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES

To the Member of Aventura Securities, LLC

We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection (SIPC) Series 600 Rules, which are enumerated below and were agreed to by Aventura Securities, LLC and the SIPC, solely to assist you and SIPC in evaluating Aventura Securities, LLC's compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2020. Aventura Securities, LLC's management is responsible for its Form SIPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with standards established by the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. 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 records entries, noting no differences;
- 2) Compared the Total Revenue amount reported on the Annual Audited Report Form X-17A-5 Part III for the year ended December 31, 2020 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31, 2020, 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.

We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on Aventura Securities, LLC's compliance with the applicable instructions of the Form SIPC-7 for the year ended December 31, 2020. 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.

This report is intended solely for the information and use of Aventura Securities, LLC and the SIPC and is not intended to be and should not be used by anyone other than these specified parties.

March 24, 2021 Atlanta, GA

bio CPA PC

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|              | SIPC-                    |                                                                                                                                                                                                                        | SECURITIES INVESTOR PROTECTION CORPORATION<br>P.O. Box 92185 Washington, D.C. 20090-2185<br>202-371-8300 |                             |                                                                                                                                                                                       | SIPIF                       |                     |
|--------------|--------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------|-----------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------|---------------------|
|              | (35-REV 6/17)            |                                                                                                                                                                                                                        | General Assessment Reconcilliation                                                                       |                             |                                                                                                                                                                                       | (35-REV 6/17)               |                     |
|              |                          |                                                                                                                                                                                                                        | For the fiscal year ended 2020                                                                           |                             |                                                                                                                                                                                       |                             |                     |
|              |                          |                                                                                                                                                                                                                        | (Read carefully the instructions in your Working Copy before completing this Form)                       |                             |                                                                                                                                                                                       |                             |                     |
|              |                          |                                                                                                                                                                                                                        | TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS                                                 |                             |                                                                                                                                                                                       |                             |                     |
|              |                          | 1. Name of Member, address, Designated Examining Authority, 1934 Act registration no. and month in which fiscal year ends for<br>purposes of the audit requirement of SEC Rule 17a-5:                                  |                                                                                                          |                             |                                                                                                                                                                                       |                             |                     |
|              | 067458                   | FINRA DEC<br>AVENTURA SECURITIES LLC<br>100 SE 3rd Ave, Suite 2216<br>Fort Lauderdale, FL 33394                                                                                                                        |                                                                                                          | indicate on the form filed. | Note: If any of the information shown on the<br>mailing label requires correction, please e-mail<br>any corrections to form@sipc.org and so<br>Name and telephone number of person to |                             | 0<br>1<br>2<br>ర్లో |
|              |                          |                                                                                                                                                                                                                        |                                                                                                          |                             | contact respecting this form.                                                                                                                                                         |                             | 0                   |
|              |                          |                                                                                                                                                                                                                        |                                                                                                          | ROBERT DE VITO              |                                                                                                                                                                                       |                             | 的                   |
|              |                          | 2. A. General Assessment (item 2e from page 2)<br>B. Less payment made with SIPC-6 filed (exclude Interest)                                                                                                            |                                                                                                          |                             | \$ 1,804.87<br>299.19                                                                                                                                                                 |                             |                     |
|              | 08/2020                  |                                                                                                                                                                                                                        |                                                                                                          |                             |                                                                                                                                                                                       |                             |                     |
|              |                          | Date Paid<br>C. Less prior overpayment applied                                                                                                                                                                         |                                                                                                          |                             | 0                                                                                                                                                                                     |                             |                     |
|              |                          |                                                                                                                                                                                                                        |                                                                                                          |                             | 1,505.68                                                                                                                                                                              |                             |                     |
|              |                          | D. Assessment balance due or (overpayment)                                                                                                                                                                             |                                                                                                          |                             | 0                                                                                                                                                                                     |                             |                     |
|              |                          | E. Interest computed on late payment (see instruction E) for _________________________________________________________________________________________________________________                                         |                                                                                                          |                             |                                                                                                                                                                                       |                             |                     |
|              |                          | F. Total assessment balance and interest due (or overpayment carried torward)                                                                                                                                          |                                                                                                          |                             | € 1,505.68                                                                                                                                                                            |                             |                     |
|              |                          | G. PAYMENT: V the box<br>Check mailed to P.O. Box<br>Funds Wired<br>Total (must be same as F above)                                                                                                                    | \$ 1,505.68                                                                                              |                             |                                                                                                                                                                                       |                             |                     |
|              |                          | H. Overpayment carried forward                                                                                                                                                                                         | \$(                                                                                                      |                             |                                                                                                                                                                                       |                             |                     |
|              |                          | 3. Subsidiaries (S) and predecessors (P) included in this form (give name and 1934 Act registration number);                                                                                                           |                                                                                                          |                             |                                                                                                                                                                                       |                             |                     |
|              | and complete.            | The SIPC member submitting this form and the<br>person by whom it is executed represent thereby<br>that all information contained herein is true, correct                                                              |                                                                                                          | AVENTURA SE<br>artnersb     | ation)                                                                                                                                                                                |                             |                     |
|              | Dated the /              |                                                                                                                                                                                                                        |                                                                                                          | (Authorized Signaty<br>(120 |                                                                                                                                                                                       |                             |                     |
|              |                          | This form and the assessment payment is due 60 days after the end of the fiscal year. Retain the Working Copy of this form<br>for a period of not less than 6 years, the latest 2 years in an easily accessible place. |                                                                                                          | (Title)                     |                                                                                                                                                                                       |                             |                     |
| d<br>REVIEWE | Dates:<br>Calculations _ | Postmarked<br>Received                                                                                                                                                                                                 | Reviewed<br>Documentation __                                                                             |                             |                                                                                                                                                                                       | Forward Copy -------------- |                     |
| 5            | Exceptions:              |                                                                                                                                                                                                                        |                                                                                                          |                             |                                                                                                                                                                                       |                             |                     |

Disposition of exceptions:

{20}------------------------------------------------

#### DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT Amounts for the fiscal period

|                                                                                                                                                                                                                                                                                                                                                                                                | beginning January 1, 2020<br>and ending December 31, 2020 |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------|
| Item No.<br>2a. Total revenue (FOCUS Line 12/Part IIA Line 9, Code 4030)                                                                                                                                                                                                                                                                                                                       | Eliminate cents<br>\$ 1,513,358                           |
| 2b. Additions:<br>(1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and<br>predecessors not included above.                                                                                                                                                                                                                                        |                                                           |
| (2) Net loss from principal transactions in securities in trading accounts.                                                                                                                                                                                                                                                                                                                    |                                                           |
| (3) Net loss from principal transactions in commodities in trading accounts.                                                                                                                                                                                                                                                                                                                   |                                                           |
| (4) Interest and dividend expense deducted in determining item 2a.                                                                                                                                                                                                                                                                                                                             |                                                           |
| (5) Net loss from management of or participation in the underwriting or distribution of securities.                                                                                                                                                                                                                                                                                            |                                                           |
| (6) Expenses other than advertising, printing, registration fees and legal fees deducted in determining net<br>profit from management of or participation in underwriting or distribution of securities.                                                                                                                                                                                       |                                                           |
| (7) Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                           |                                                           |
| Total additions                                                                                                                                                                                                                                                                                                                                                                                |                                                           |
| 2c. Deductions:<br>(1) Revenues from the distribution of shares of a registered open end investment company or unit.<br>investment trust, from the sale of variable annuities, from the business of insurance, from investment<br>advisory services rendered to registered investment companies or insurance company separate<br>accounts, and from transactions in security futures products. | 96,438                                                    |
| (2) Revenues from commodity transactions.                                                                                                                                                                                                                                                                                                                                                      |                                                           |
| (3) Commissions, floor brokerage and clearance paid to other SIPC members in connection with<br>securities transactions.                                                                                                                                                                                                                                                                       | 204,224                                                   |
| (4) Reimbursements for postage in connection with proxy solicitation.                                                                                                                                                                                                                                                                                                                          |                                                           |
| (5) Net gain from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                           |                                                           |
| (6) 100% of commissions and markups earned from transactions in (i) certificates of deposit and<br>(ii) Treasury bills, bankers acceptances or commercial paper that mature nine months or less<br>from issuance date.                                                                                                                                                                         |                                                           |
| (7) Direct expenses of printing advertising and legal fees incurred in connection with other revenue<br>related to the securities business (revenue defined by Section 16(9)(L) of the Act).                                                                                                                                                                                                   |                                                           |
| (8) Other revenue not related either directly or indirectly to the securities business.<br>(See Instruction C):                                                                                                                                                                                                                                                                                |                                                           |
| (Deductions in excess of \$100,000 require documentation)                                                                                                                                                                                                                                                                                                                                      |                                                           |
| (9) (i) Total interest and dividend expense (FOCUS Line 22/PART IIA Line 13,<br>Code 4075 plus line 2b(4) above) but not in excess<br>\$ 1,408<br>of total interest and dividend income.                                                                                                                                                                                                       |                                                           |
| (ii) 40% of margin interest earned on customers securities<br>9,452<br>accounts (40% of FOCUS line 5, Code 3960).                                                                                                                                                                                                                                                                              |                                                           |
| Enter the greater of line (i) or (ii)                                                                                                                                                                                                                                                                                                                                                          | 9,452                                                     |
| Total deductions                                                                                                                                                                                                                                                                                                                                                                               | 310,114                                                   |
| 2d. SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                                                | 1,203,244                                                 |
| 2e. General Assessment @ .0015 Rate effective 1/1/2017                                                                                                                                                                                                                                                                                                                                         | 1,804.87                                                  |
|                                                                                                                                                                                                                                                                                                                                                                                                | (to page 1, line 2.A.)                                    |

{21}------------------------------------------------

This form is to be filed by all members of the Securities Investor Whose fiscal years end in 2011 and annually thereatter. The form together with the payment is due no later the end of the fiscal year or after members hip termination. Amounts reported herein must be readily reconcilable with the member's records and the Securities and Exhange Commission Rule 17-5 report filed. Questions pertaining to this form should be directed to SIPC via e-mail at form@sin.org of by telephoning 202-371-8300.

A. For the purposes of this form, the term "SIPC Net Operating Revenues" shall mean gross revenues from the securities business as defined in or pursuant to the applicable sections of the Securities Investor Protection Act of 1970 ("Act") and Article 6 of SIPC's bylaws (see page 4), less item 2c(9) on page 2.

B. Gross revenues of subsidiaries, except foreign subsidiaries, are required to be included in SIPC Net Operating Revenues on a consolidated basis except for a subsidiary filing separately as explained hereinafter.

If a subsidiary was required to file a Rule 17a-5 annual audited statement of income separately and is also a SIPC member, then such subsidiary must itself file SIPC-7, pay the assessment, and should not be consolidated in your SIPC-7.

SIPC Net Operating Revenues of a predecessor member which are not included in item 2a, were not reported separately and the SIPC assessments were not paid thereon by such predecessor, shall be included in item 2b(1).

- C. Your General Assessment should be computed as follows:
- (1) Line 2a For the applicable period enter total revenue based upon amounts reported in your Rule 17a-5 Annual Audited Statement of Income prepared in conformity with generally accepted accounting principles applicable to securities brokers and dealers. or if exempted from that rule, use X-17A-5 (FOCUS Report) Line 12, Code 4030.
- (2) Adjustments The purpose of the adjustments on page 2 is to determine SIPC Net Operating Revenues.
	- (a) Additions Lines 2b(1) through 2b(7) assure that assessable income and gain items of SIPC Net Operating Revenues are totaled, unreduced by any losses (e.g., if a net loss was incurred for the period from all transactions in trading account securities, that net loss does not reduce other assessable revenues). Thus, line 2b(4) would include all short dividend and interest payments including those incurred in reverse conversion accounts, rebates on stock loan positions and repo interest which have been netted in determining line 2(a).
	- (b) Deductions Line 2c(1) through line 2c(9) are either provided for in the statue, as in deduction 2c(1), or are allowed to arrive at an assessment base consisting of net operating revenues from the securities business. For example, line 2c(9) allows for a deduction of either the total of interest and dividend expense (not to exceed interest and dividend income), as reported on FOCUS line 22/PART IIA line 13 (Code 4075), plus line 2b(4) or 40% of interest earned on customers' securities accounts (40% of FOCUS Line 5 Code 3960). Be certain to complete both line (i) and (ii), entering the greater of the two in the far right column. Dividends paid to shareholders are not considered "Expense" and thus are not to be included in the deduction. Likewise, interest and dividends paid to partners pursuant to the partnership agreements would also not be deducted.

If the amount reported on line 2c (8) aggregates to \$100,000 or greater, supporting documentation must accompany the form that identifies these deductions. Examples of support information include; contractual agreements, prospectuses,

and limited partnership documentation.

- (i) Determine your SIPC Net Operating Revenues. item 2d, by adding to item 2a, the total of item 2b, and deducting the total of item 2c.
- (ii) Multiply SIPC Net Operating Revenues by the applicable rate. Enter the resulting amount in item 2e and on line 2A of page 1.
- (iii) Enter on line 2B the assessment due as reflected on the SIPC-6 previously filed.
- (iv) Subtract line 2B and 2C from line 2A and enter the difference on line 2D. This is the balance due for the period.
- (v) Enter interest computed on late payment (if applicable) on line 2E.
- (vi) Enter the total due on line 2F and the payment of the amount due on line 2G.
- (vii) Enter overpayment carried forward (if any) on line 2H.

D. Any SIPC member which is also a bank (as defined in the Securities Exchange Act of 1934) may exclude from SIPC Net Operating Revenues dividends and interest received on securities in its investment accounts to the extent that it can demonstrate to SIPC's satisfaction that such securities are held, and such dividends and interest are received, solely in connection with its operations as a bank and not in connection with its operations as a broker, dealer or member of a national securities exchange. Any member who excludes from SIPC Net Operating Revenues any dividends or interest pursuant to the preceding sentence shall file with this form a supplementary statement setting forth the amount so excluded and proof of its entitlement to such exclusion.

E. Interest on Assessments. If all or any part of assessment payable under Section 4 of the Act has not been postmarked within 15 days after the due date thereof, the member shall pay, in addition to the amount of the assessment, interest at the rate of 20% per annum on the unpaid portion of the assessment for each day it has been overdue.

F. Securities and Exchange Commission Rule 17a-5(e) (4) requires those who are not exempted from the audit requirement of the rule and whose gross revenues are in excess of \$500,000 to file a supplemental independent public accountants report covering this SIPC-7 no later than 60 days after their fiscal year ends.

Mail this completed form to SIPC together with a check for the amount due, made payable to SIPC, using the enclosed return PO BOX envelope or wire the payment to: Bank Name: Citibank, New York Swift: CITIUS33 ABA#: 021000089 Account Number: 30801482 Address: 111 Wall Street, New York, New York 10043 USA On the wire identify the name of the firm and its SEC Registration 8-# and label it as "for assessment." Please fax a copy of the assessment form to (202)-371-6728 or e-mail a copy to form@sipc.org on the same day as the wire.

{22}------------------------------------------------

### From Section 16(9) of the Act:

The term "gross revenues from the securities business" means the sum of (but without duplication)-

(A) commissions earned in connections in securities effected for customers as agent (net of commissions paid to other brokers and dealers in connections) and markups with respect to ourchases or span (nec recurities on spacifies on specurities as principal;

(B) charges for executing or clearing transactions in securities for other brokers and dealers;

(C) the net realized gain, if any, from principal transactions in securities in trading accounts;

(D) the net profit, if any, from the management of or participation in the underwriting or distribution of securities;

(E) interest earned on customers' securities accounts:

(F) fees for investment advisory services (except when rendered to one or more registered investment companies or insurance company separate accounts) or account supervision with respect to securities:

(G) fees for the solicitation of proxies with respect to, or tenders or exchanges of, securities;

(H) income from service charges or other surcharges with respect to securities;

(1) except as otherwise provided by rule of the Commission, dividends and interest received on securities in investment accounts of the broker or dealer;

(J) fees in connection with put, call, and other options transactions in securities;

(K) commissions earned for transactions in (i) certificates of deposit, and (ii) Treasury bills, bankers acceptances, or commercial paper which have a maturity at the of issuance of not exceeding nine months, exclusive of days of grace, or any renewal thereof, the maturity of which is likewise limited, except that SIPC shall by bylaw include in the aggregate of gross revenues only an appropriate percentage of such commissions based on SIPC's loss experience with respect to such instruments over at least the preceding five years; and

(L) fees and other income from such other categories of the securities business as SIPC shall provide by bylaw.

Such term includes revenues earned by a broker in connection with a transaction in the portfolio margining account of a customer carried as securities accounts pursuant to a portfolio margining program approved by the Commission. Such term does not include revenues received by a broker in connection with the distribution of shares of a registered open end investment company or unit investment trust or revenues derived by a broker or variable annuities, the business of insurance, or transactions in security futures products.

### From Section 16(14) of the Act:

The term "Security" means any note, stock, bond, debenture, evidence of indebtedness, any collateral trust certificate, preorganization certificate or subscription, transferable share, vertificate, certificate of deposit for a security, or any security future as that term is defined in section 78c(a){55}(A) of this title, any investment contract or certificate of interest or participation in any profit-sharing agreement or in any oil, gas or mineral royalty or lease (f such investment contract or interest is the subject of a registration statement with the Commission of the Securities Act of 1933 [15 U.S.C. 77a et seq.]), any put, call, straddle, option, or privilege on any securities (including any interest therein or based on the value thereo), or any put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency, any certification in, temporary or interim certificate for, receipt for, guarantee of, or warrant or right to subscribe to or purchase or sell any of the instrument commonly known as a security. Except as specifically provided above, the term "security" does not include any currency, or any commodity or related ontract or futures contract, or any warrant or right to subscribe to or purchase or sell any of the foregoing.

# From SIPC Bylaw Article 6 (Assessments):

#### Section 1 (f):

The term "gross revenues from the securities business" in the definition of gross revenues from the securities business set forth in the applicable sections of the Act.

#### Section 3:

For purpose of this article:

(a) The term "securities in trading accurities held for sale in the ordinary course of business and not identified as having been held for investment.

(b) The term "securities in investment accurities that are clearly identified as having been acquired for investment in accordance with provisions of the Internal Revenue Code applicable to dealers in securities.

(c) The term "fees and other income from such other categories business" shall mean all revenue related either directly or indirectly to the securities business except revenue included in Section 16(9)(A)-(L) axepted in Section 4(c)(3)(C)[Item 2c(1), page 2].

Wore: If the emount of assessment entered on 1/2 of 1% of "gross revenues from the sourcios business" as defined above, you nay submit hat calculation along with the SIPC-7 form to SIPC and pay the smaller amount, subject to review by your Examining Authority and by SIPC.

SIPC Examining Authorities:

| ASE  | American Stock Exchange, LLC                 |   |
|------|----------------------------------------------|---|
| CBOE | Chicago Board Options Exchange, Incorporated |   |
| CHX  | Chicago Stock Exchange, Incorporated         | 1 |

FINRA Financial Industry Regulatory Authority NYSE NASDAQ OMX PHLX SIPC Securities Investor Protection Corporation


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