# NORTHWEST FINANCIAL GROUP LLC X-17A-5 (2024-03-29) — Broker-dealer annual report

- Company: NORTHWEST FINANCIAL GROUP LLC
- Form: X-17A-5
- Filed: 2024-03-29
- Period: 2023-12-31
- Accession: 0001410645-24-000001
- CIK: 1410645
- File #: 8-67698
- Type: Broker-dealer
- Material weakness: No
- Auditor: Crowe LLP
- Auditor location: New York, NY
- Contact: Karen Benedict
- Phone: 703-828-0715
- Email: form@sipe.org
- Website: sipe.org
- Signed by: Karen Benedict (SVP/FinOp)

Original filing: https://www.sec.gov/Archives/edgar/data/1410645/000141064524000001/edgarfiling1.pdf

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## NORTHWEST FINANCIAL GROUP, LLC

## FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION PURSUANT TO RULE 17A-5 UNDER THE SECURITIES EXCHANGE ACT OF 1934

DECEMBER 31, 2023

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# Page

| INDEPENDENT AUDITOR'S REPORT.                               |  |
|-------------------------------------------------------------|--|
| FINANCIAL STATEMENTS                                        |  |
| Statement of Financial Condition                            |  |
| Statement of Loss                                           |  |
| Statement of Changes in Membership Capital                  |  |
| Statement of Cash Flows                                     |  |
| Notes to Financial Statements                               |  |
| SUPPLEMENTAL INFORMATION                                    |  |
| Communities of American Industrations and Not Cantol<br>1 1 |  |

| Computation of Aggregate Indebtedness and Net Capital |  |
|-------------------------------------------------------|--|
| Computation for Determination of Reserve Requirements |  |
| Information for Possession or Control Requirements    |  |

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Crows LLP Indispandiant Maniber Crosse Global

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#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Directors of Northwest Financial Group, LLC Hemdon, VA

#### Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Northwest Financial Group, LLC (the "Company") as of December 31, 2023, the related statements of loss, changes in membership capital, and cash flows for the year ended December 31, 2023, and the related notes (collectively referred to as the "Ensencial statements"). In our opinion, the financial statements present feirly, in all material respects, the financial position of the Company as of December 31, 2023, and the results of to operations and its cash flows for the year ended December 31, 2023, 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 financisi statements based on our such. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCACB") and are requeed 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 awlit in ecoordance with the stendards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial atalements are free of malenal missiatement, whether due to errar or fraud. Char audit included performing procedures to assess the naterial misstatement of the financial statements, whether due to error or fraud, and performing procadures that respond to those risks. Such prosedures included examining, on a feat bease. evidence regarding the amounts and disclosures in the financial statements. Our audit also included eveluating the accounting principles used and significant estimates made by mensgement, as well as evaluating the overall presentation of the fisherments. We believe that our audit provides a reasonable basis for our opinion.

#### Emphasis of Matter

As discussed in Note 1 to the financial statements, errors in the prior year were discovered by management. of the Company during the current vear. Adjustments have been made to member a equily as of January 1. 2023 to correct those errors. Our opinion is not modified with respect to this matter.

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#### Supplemental Information

The Schedule I, Schedule II and Schedule III (the "Supplemental Information") has been subjected to audit procedures partermed in conjunction with the audit of the Company's financial statements. The Supplemental information is the responsibility of the Company's menagement. Our audit procedures included determining whether the Supplemental Information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented information. In formation. In formation. In formation. In formaing our opinion on the Supplemental Information, we evaluated whether the Supplemental Information, including its form and content is presented in conformity with 17 C.F.R. § 240.176-5. In our opinion, the Supplemental Information is fairly stated, in all meterial respects, in relation to the financial statements as a whole,

Crowe LLP

We have served as the Company's auditor since 2023.

New York, New York March 25, 2024

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# NORTHWEST FINANCIAL GROUP LLC STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31, 2023

| ASS IN IN                       |            |
|---------------------------------|------------|
| ASSETS:                         |            |
| Cash and Cash Equivalents       | \$ 367,576 |
| Commissions and Fees Receivable | 23,430     |
| Prepaid and Other Assets        | 54,7475    |
| Total Assets                    | \$ 445,231 |
|                                 |            |

|  |  |  |  | LIABILITIES AND MEMBERSHIP CAPITAL |  |
|--|--|--|--|------------------------------------|--|
|--|--|--|--|------------------------------------|--|

| CURRENT LIABILITIES                      |    |         |
|------------------------------------------|----|---------|
| Accounts Payable                         | ﯿ  | 125,183 |
| Other Accrued Liabilities                |    | 26.466  |
| Total Liabilities                        |    | 151.649 |
| MEMBERSHIP CAPITAL:                      |    |         |
| Invested Capital                         |    | 293.582 |
| Total Liabilities and Membership Capital | ﻮﻱ | 445.231 |

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# NORTHWEST FINANCIAL GROUP LLC STATEMENT OF LOSS FOR THE YEAR ENDED DECEMBER 31, 2023

| Revenues:                         |         |           |
|-----------------------------------|---------|-----------|
| Commissions, Concessions and Fees | a Santa | 1,373,352 |
| Interest                          |         | 127       |
| Total Revenues                    |         | 1,373,479 |
| Operating Expenses:               |         |           |
| Commissions                       |         | 580.909   |
| Compensation and Benefits         |         | 345.876   |
| Office Operations                 |         | 222,992   |
| Professional Services             |         | 229,056   |
| Miscellaneous                     |         | 1,017     |
| Total Operating Expenses          |         | 1,379,850 |
| Net Loss                          |         | (6,371)   |

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## NORTHWEST FINANCIAL GROUP LLC STATEMENT OF CHANGES IN MEMBERSHIP CAPITAL FOR THE YEAR ENDED DECEMBER 31, 2023

|                                     |    | Membership<br>Capital |
|-------------------------------------|----|-----------------------|
| Balance at January 1, 2023          | 37 | 289.631               |
| Prior Period Adjustment             |    | 10.322                |
| Balance at January 1, 2023 restated |    | 299.953               |
| Net Loss                            |    | (6,371)               |
| Balance at December 31, 2023        | 5  | 293.582               |

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# NORTHWEST FINANCIAL GROUP LLC STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2023

| CASH FLOWS FROM OPERATING ACTIVITIES:          |   |            |
|------------------------------------------------|---|------------|
| Net Loss                                       | 5 | (6,371)    |
| Changes in Operating Assets and Liabilities:   |   |            |
| Commissions and Fees Receivable                |   | 3.035      |
| Prepaid and Other Assets                       |   | (38.907)   |
| Accounts Payable and Other Accrued Liabilities |   | 18,104     |
| Net Cash Used In Operating Activities          |   | (24, 139)  |
| Net Change in Cash and Cash Equivalents        |   | (24,139)   |
| Beginning Balance of Cash and Cash equivalents |   | 391,715    |
| Ending Balance of Cash and Cash equivalents    |   | \$ 367,576 |

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### NOTE 1: SIGNIFICANT ACCOUNTING POLICIES

#### NATURE OF BUSINESS

Northwest Financial Group LLC (the Company) is a credit union service organization (CUSO) organized in the Commonwealth of Virginia. The Company is registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulatory Authority (FINRA). The Company's principal operations are located in Herndon, Virginia, and is a wholly owned subsidiary of NW Capital Management LLC (NWCM). NWCM is a wholly owned subsidiary of Northwest Federal Credit Union (NWFCU).

The term of the Company is perpetual. As a limited liability company, the member's liability is limited to amounts reflected in its member account.

The Company files an exemption report pursuant to interpretations provided by FAO 74 of the SEC Release No. 34-70073 because it limits its business activities to referring customers to a third party and did not carry or hold customer funds during the year. The Company operates as a limited broker-dealer on its own behalf and is approved to exclusively refer securities transactions to other broker-dealers.

#### FINANCIAL STATEMENTS/USE OF ESTIMATES

The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the financial statements and the reported amounts of revenues and expenses during the period then ended. Actual results could differ from those estimates. The significant accounting principles and policies used in the preparation of these financial statements, together with certain related information, are summarized within.

The Company identified an error in its accounting for prior year leases in the current vear. The Company made a correction through an adjustment to member's equity as of January 1, 2023 in the amount of \$10,322 which is the cumulative effect on retained earnings. The impact on 2022 net income has not been determined.

#### REVENUE RECOGNITION

The Company overates under a networking agreement with LPL Financial whereas all securities business is referred to and transacted through representatives of LPL Financial. LPL Financial carries all brokerage accounts for the Company and maintains

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and preserves all related books and records of the Company's accounts. Commission fees recognized by the Company are primarily comprised of referral fees. The Company's sole performance obligation is to refer customers to LPL. The referral fees can be the result of executed trail fee income and from services provided by LPL. The referral performance obligation is satisfied at a point in time, when the referral is made; however, revenue allocated to the performance obligation is constrained. Revenues associated with executed trades are constrained until trade date as they are not known until executed trades occur. At trade date, the constraint is removed and revenue is recognized for transactions. Revenues associated with asset based fees (trail fees) are constrained due to the dependence on unpredictable market movements. Revenues associated with asset based fees, which are fees charged as a percentage of assets under management for services provided, are recognized when the constraint is removed.

#### CASH AND CASH EQUIVALENTS

Cash and cash equivalents include amounts due from NWFCU and banks which may, at times, exceed federally insured limits. Cash consists of deposits with banks and all highly liquid investments, with maturities of three months or less, that are not segregated and deposited for regulatory purposes.

COMMISSIONS AND FEES RECEIVABLE CURRENT EXPECTED CREDIT LOSSES (CECL) In June 2016, the FASB issued guidance (FASB ASC 326) which significantly changed how entities will measure credit losses for most financial assets and certain other instruments that aren't measured at fair value through net income. The most significant change in this standard is a shift from the incurred loss model to the expected loss model. Under the standard, disclosures are required to provide users of the financial statements with useful information in analyzing an entity's exposure to credit risk and the measurement of credit losses. Financial assets held by the company that are subject to the guidance in FASB ASC 326 were commissions and fees receivable. Commissions and fees receivable are generally referral fees that have been earned, but not yet received.

The Company accounts for estimated credit losses on financial assets measured at an amortized cost basis and certain off-balance sheet credit exposures in accordance with FASB ASC 326-20, Financial Instruments - Credit Losses. FASB ASC 326-20 requires the Company to estimate expected credit losses over the life of its financial assets and certain off-balance sheet exposures as of the reporting date based on relevant information about past events, current conditions, and reasonable and supportable forecasts.

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Financial assets measured at amortized cost basis that are not eligible for the collateral maintenance practical expedient. For financial assets measured at amortized cost basis that are not eligible for the collateral maintenance practical. expedient (and any unsecured amounts for instruments applying the practical expedient), the Company estimates expected credit losses over the life of the financial assets as of the reporting date based on relevant information about past events, current conditions, and reasonable and supportable forecasts.

# FAIR VALUE OF FINANCIAL INSTRUMENTS

ASC 820-10 provides standards and disclosures for assets and liabilities that are measured and reported at fair value. As defined in ASC 820-10, 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 (exit price). ASC 820-10 requires disclosure that establishes a framework for measuring fair value and expands disclosure about fair value measurements. The statement requires fair value measurements be classified and disclosed in one of the following categories:

Level 1: Unadjusted quoted prices in active markets that are accessible at the measurement date for identical, unrestricted assets or liabilities. An active market for the asset or liability is a market in which transactions for the asset or liability occur with sufficient frequency and volume to provide pricing information on an ongoing hasis.

Level 2: Measured based upon inputs that are observable, either directly or indirectly, for the asset or liability other than quoted market prices included in Level 1. These inputs include; a) quoted prices for similar asset or liabilities in active markets b} quoted prices for identical or similar assets or liabilities in markets that are not active c) inputs other than quoted market prices that are observable and d) inputs that are derived primarily from or corroborated by observable market data by correlation or other means.

Level 3: Measured based on unobservable inputs for the asset or liability for which there is little, if any, market activity for the asset or liability at the measurement date. This includes management's own assumptions about the assumptions that market participants would use in pricing the asset or liability. The inputs are

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developed based on the best information available in the circumstances, which might include management's own data.

As required by ASC 820-10, financial assets and liabilities are classified based on the lowest level of input that is significant to the fair value measurement. The Company's assessment of the significance of a particular input to the fair value measurement requires judgment and may affect the valuation of the fair value of assets and liabilities and their placement within the fair value hierarchy levels. The Company has no assets or liabilities that are measured and reported at fair value as of December 31, 2023.

Certain financial instruments that are not carried at fair value on the statement of financial condition are carried at amounts that approximate fair value due to their short-term nature and generally negligible risk. These instruments include cash, commissions and fees receivable, other assets, accounts payable, and other accrued liabilities.

### INCOME TAXES

The Company is formed as a Limited Liability Company and has elected to be disregarded for income tax purposes; therefore, the Company itself is not a taxable entity. The Income Taxes Topic of the FASB ASC clarifies accounting for uncertainty in income taxes reported in the financial statements. The interpretation provides criteria for assessment of individual tax positions and a process for recognition and measurement of uncertain tax positions. Tax positions are evaluated on whether they meet the more likely than not standard for sustainability on examination by tax authorities. The Company has no uncertain tax positions that qualify for either recognition or disclosure in the financial statements. Additionally, no interest or penalties have been recorded in the accompanying financial statements related to uncertain tax positions.

NOTE 2: EMPLOYEE BENEFITS

### 401(K) PROFIT SHARING PLAN

Participation in the NWCM 401(k) profit sharing plan is available to all Company employees who are 18 years of age or older. Employee contributions to the plan are subject to certain limits established by the Internal Revenue Service. Participants are

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always 100% vested in their voluntary contributions. The Company may make a discretionary matching contribution equal to a uniform percentage of an employee's salary deferral and/or a discretionary profit sharing contribution. Company contributions vest at 33% after one year of service, 67% after two years of service and 100% after three years of service. During the year ended December 31, 2023, the Company contributed a matching contribution up to 7% of employee compensation. No profit sharing contribution was made. Total expense for the 401(k) profit sharing plan approximated \$40,939 for the year ended December 31, 2023.

#### DEFERRED COMPENSATION

NWCM has established a deferred compensation plan for certain executives of NWCM and its subsidiaries in accordance with Internal Revenue Service Code Section 409. This non-qualified deferred compensation plan will be payable in accordance with terms of the underlying agreement. The Company's total expense for the plan was \$6,430 for the year ended December 31, 2023. Because the assets funding the plan are NWCM assets and the liabilities are NWCM liabilities they are included on the statement of financial condition of NWCM.

### NOTE 3: RELATED PARTY TRANSACTIONS

During the normal course of business, the Company shares office space and certain operating expenses with NWCM and NWCM's subsidiaries. The Company is charged monthly by NWCM for its share of expenses pursuant to the executed expense sharing agreement between the parties. The Company's total shared expenses with NWCM under the expense sharing agreement totaled approximately \$249,257 for the year ended December 31, 2023.

| Statement of Income Category |   | Amount  |
|------------------------------|---|---------|
| Compensation and Benefits    | S | 24,931  |
| Professional Services        |   | 175,768 |
| Office Operations            |   | 47,888  |
| Miscellancous                |   | 670     |
|                              | 문 | 249,257 |

Pursuant to the executed expense sharing agreement, the Company shares certain payroll related expenses with Northwest Financial Advisors LLC (NWFA), a related

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party through common ownership. These expenses, as well as commission expenses, are paid by NWFA and charged to the Company on a monthly basis. The Company's total shared expenses with NWF A totaled approximately \$314,599 for the year ended December 31, 2023.

NWCM has entered into a support services agreement with NWFCU to provide human resources support, information technology services, security and other services. The Company is allocated a portion of these shared services with NWCM pursuant to the expense sharing agreement. The Company's allocation of these services totaled \$17,026 included within the Professional Services expense line item on the Statement of Operations for the year ended December 31, 2023.

Included in accounts payable and other accrued liabilities are amounts due to NWCM and NWFA totaling \$113,332 and \$33,752 respectively, as of December 31, 2023.

The Company had funds on deposit at NWFCU totaling \$20,466 included within cash and cash equivalents on the Statement of Financial Condition as of December 31, 2023.

A significant number of the Company's clients are also members of NWFCU and many of the Company's clients are referred by NWFCU.

## NOTE 4: NET CAPITAL REQUIREMENTS

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC 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. As of December 31, 2023, the Company had net capital of \$238,842 which was \$229,722 in excess of its required net capital of \$9,120. The Company's ratio of aggregate indebtedness to net capital was 0.57 to 1.

### NOTE 5: CONCENTRATIONS

Many of the Company's customers work or reside in Washington, D.C. and the surrounding areas.

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#### NOTE 6: SUBSEQUENT EVENTS

Management has evaluated subsequent events through March 25, 2024, the date the financial statements were available to be issued. Management has not identified any items requiring recognition or disclosure.

#### NOTE 7: COMMITMENTS, CONTINGENCIES AND GUARANTEES

There Company had no commitments, contingencies or guarantees as of December 31,2023 that might result in a loss of future obligation.

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# NORTHWEST FINANCIAL GROUP LLC COMPUTATION OF AGGREGATE INDEBTEDNESS AND NET CAPITAL UNDER RULE 15C3-1 SCHEDULE I AS OF DECEMBER 31,2023

| AGGREGATE INDEBTEDNESS:                        |   |           |
|------------------------------------------------|---|-----------|
| Accounts Payable                               | S | 125,183   |
| Other Accrued Liablilities                     |   | 11,616    |
| Total aggregate indebtedness                   | 3 | 136,799   |
| NET CAPITAL:                                   |   |           |
| Total membership capital from the              |   |           |
| Statement of Financial Condition               | 3 | 293,582   |
| Discretionary Bonus                            |   | 14,850    |
| Adjusted Membership Capital                    | S | 308,432   |
| Deductions:                                    |   |           |
| Nonallowable assets:                           |   |           |
| Commissions and Fees Receivable                |   | 15,365    |
| Prepaid and Other Assets                       |   | 54,225    |
| Total non allowable assets                     |   | 69,590    |
| Net capital                                    | S | 238,842   |
| COMPUTATION OF BASIC NET CAPITAL REQUIREMENT;  |   |           |
| Minimum required net capital                   | 5 | 9,120     |
| Excess net capital                             | 5 | 229,722   |
| Ratio of aggregate indebtedness to net capital |   | 0.57 to 1 |

There following reconciles the preceding computation and the Company's

corresponding unaudited Part IIA of Form X-17a-5 as of December 31, 2023

| liem                                           | Per Schedule I | Per FOCUS | Difference |
|------------------------------------------------|----------------|-----------|------------|
| Membership Capital                             | 293.582        | 282,095   | 11.487     |
| Adjusted Membership Capital                    | 308,432        | 296,945   | 11,487     |
| Net Capital                                    | 238,842        | 227,355   | 11,487     |
| Total Aggregate Indebtedness                   | 136,799        | 148,286   | (11,487)   |
| Minimum required net capital                   | 9.120          | 11.863    | (2,743)    |
| Excess net capital                             | 229.722        | 215,492   | 14,230     |
| Ratio of aggregate indebtedness to net capital | 0.57           | 11.65     | 0.08)      |

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## NORTHWEST FINANCIAL GROUP LLC COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15C3-3 SCHEDULE II DECEMBER 31, 2023

This computation is not applicable to Northwest Financial Group LLC, as the Company, which is a referring broker dealer, qualifies for exemption under Rule 15c3-3, including exemptions pursuant to other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073, at December 31, 2023

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## NORTHWEST FINANCIAL GROUP LLC INFORMATION FOR POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15C3-3 SCHEDULE III DECEMBER 31, 2023

Information relating to possession or control requirements is not applicable to Northwest Financial Group LLC, as the Company, which is a referring broker dealer, qualifies for exemption under Rule 15c3-3, including exemptions pursuant to other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073, at December 31, 2023.

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#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

We have reviewed managements, included in the accompanying Northwast Financial Group LLC Exemption Report for Northwest Financial Group, LLC (the "Company"), in which:

(1) The Company did not claim an exemption from 17 C.F.R. § 240.15c3-3 under the provisions of 17 C.F.R. § 15c3-3(k).

(3) The Company identified the following identified conditions pursuant to Footnore 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17@-5 under which the Company is eligible to file an Exemption Report because the Company's business activities are limited to receiving Iransaction-based compensation for referring securities transactions to other broker-dealers, and the Company 1) did not directly or indirectly receive, hold, or otherwise owe funds or secunties for or to customers; 2) this not carry accounts of or for customers; and 3) did not carry PAB accounts (as defined in Rute 15c3-3) (the "dentified conditions") throughout the year ended December 31, 2023, without exception

The Company's management is responsible for compliance with the exemption provisions and its statements.

Our newlew was conducted in accordance with the standards of the Public Company Accountling Oversight Board (Unlied States) and, accordingly, included inquiries and other required procedures to obtain evidence about The Company's campliance with the exemptions. A review is substentially leas in scope than an examination, the objective of which is the expression of an opinion on management's alsolements. Appordingly, we do not express such an opinion.

Beaed 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 conditions set forth in Footnote 74 of SEC Release No.34-70073 adopting arnendments to 17 C.F.R. § 240 17a-5.

Crowe LLP

New York, New York March 25, 2024

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Northwest Financial Group LLC Exemption Report

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

- (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3, and
- (2) The Company is filing this Exemption Report relying on Foothote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. 5240.17a-5 because the Company limited its business activities exclusively to receiving transaction-based compensation for referring securities transactions to other broker-dealers, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year.
- (3) The Company had no exceptions to note for the fiscal year ended December 31, 2023.

Northwest Financial Group, LLC

I, Karen Benedict, affirm that, to my best knowledge and belief, this Exemption Report is true and correct.

Title: SVP/FinOp March 25, 2024

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Crown LLP Lockpandeni Hambar Growa Global

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

To the Management and the Board of Directors of Northwest Financial Group, LLC

We have performed the procedures in Rule 17a-5(e)(4) under the Securities Exchange Act of 1334 and in the Securities Investor Protection (SIPC) Series 800 Rules, which are enumerated below on the accompanying General Assessment Resortcliation (Form SIPC-7) for the year ended December 31, 2023. Management of Northwest Financial Group, LLC (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 Company's compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2023. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be sutable for any other purpose. The procedures partomed may not address all the liems 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 sciely the responsibility of these parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the parpose for which this report has been requested or for any other purpose.

The procedures we performed and the associated findings are as follows:

- \*. Compared the listed assessment payments in Form SIPC-7 with respective cash disbursements record 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, 2023, with the Total revenue amounts reported in Form SIPC-7 for the year ended December 31, 2023 noting no differences;
- 3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers supporting the adjustments noting no differences;
- 4. Recalculated the arthmetical accuracy of the calculations reliected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments noting no differences, and
- 6. Compered 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 conduction our engagement in accordance with attestation standards as the American Institute of Certfied Public Accountants and in accordance with the standards of the Public Company Accounting Oversight Board (United States). We were not engaged to, and did not conduct an examination or 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, 2023. Accordingly, we do not express such an opinion or condusion. Had we parformad additional procedures, other matters might have come to our attention that would have been reported to you.

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We are required to be independent of the Company and to meet our other ethical responsibilities, in accordance with the relevant elhical requirements related to our agreed-upon procedures engagement.

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

Crowe ШР

New York, New York March 26, 2024

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| SECURITIES INVESTOR PROTECTION CORPORATION<br>121<br>Mail Code: 8967 P.O. Box 7247 Philadelphia, PA 19170-0001<br>General Assessment Reconciliation<br>[30-REV 12/18<br> Read carefully the Institucitions in your Working Capy before completing this Forms.<br>TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS<br>1. Name of Mamber, address, Designation Asthonity, 1934 Act replated in which lists year ends on<br>Note: Il any of the information shown on the<br>mading label requires correction, please e-mail<br>any corrections to form@sipe.org and sc<br>Indecate on the form filed.<br>Mame and telephone number of passon to<br>contact respecting this form.<br>Karen Banedict 703-810-1072x105 |
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|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| +2.060.22                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                |
| 1,052,30                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
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|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| 1,007,92                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| E. Interest computed on late payment (see instruction E) for ___ days at 20% per annum                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |
| 1,007492                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| 3. Subsidiations (S) and predecessors (P) included in this form (give name and 1934 Act replation number);                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
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|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
| Northwest Financial Group LLC                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            |
| (Report of Confidere) in a frinters on other argues and only                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |
| (Rariegabed Reporture)<br>SVP Investments/FINOD                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |

{23}------------------------------------------------

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

beginning 01-01-2020 and ending a com Eliminate sents Ren No. 1 1 378.479 2a. Total revenue (FOCUS Line 12/Paril IIA Line 9, Code 4030) 2b. Additions . (1) Total revanual tom the eacurities besident of subsidiaries (except foreign subsidiaries) and predecars not incread above (2) Net loss from principal Iransactions in securities in trading accounts (3) Not loss lions principal fransactions in commodillas in Irading accounts (4) Interest and dividend expense deducted in decarmining tiem 28. (6) Net loss how management of as participalites in the underwilling of distribution of accurities. (6) Expenses offical then advertising, printing, registration these deducted in addemialing nei profil from management of or participation in underwriting or dostribution of securities. (7) Nel loss from secondies in investment accounts. Total additions 2c. Deductions. [1] Renenues from the dietribution of shares of a ringistered open end investment company or usil larestmant truet, from the sale of variable annuites, tron the besiness of insurance, from Investment advisorr services sendered to registered investment company or insumer company separate accommis, and from transactions in seburily fuluees products. (2) Revenues from commodity transactions. (3) Commessions, floor brokerage and clearance paid to other SIPC mambers in connection with securities transaci 089. (4) Rambursements for postage in consection with proxy adicisation (5] Hat gain from secendres in invasiment accounts. 16) 100% of commissions and markups aaroed from in (i) corlificates of deposed and les Transury bells, baskers acceptances or commercial paper that mature nines months or loss from issuance dalla. (7) Direct expenses of pristing and legal leas incurred in connection with other revenue related to the securities business (terence deliated by Section [6][9][L) of the Act). (8) Other reveaus not related olities directly or indirectly to the securities business. (See Instruction C) (Oeductions in excess of \$100,000 require documentation) (B) || Total Interest and drindend expense | FOGUS Line 22/PART ||B. Lang 13, Code 4375 plus line 2644 | above) but not in ascess of tolal interest and dividend income fii) 40% of margin interest earned or customers securities accounts (40% of FOCUS una 5. Code 3960). Enter the greater of line (i) or (i) Total deductions .373.479 2d. SIPC Nol Operating Revenues 000.77 20. Gonelal A66855Mont @ .0015 (to page 1, line 2, A.)


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