# PARKMAN WHALING SECURITIES LLC X-17A-5 (2024-02-23) — Broker-dealer annual report

- Company: PARKMAN WHALING SECURITIES LLC
- Form: X-17A-5
- Filed: 2024-02-23
- Period: 2023-12-31
- Accession: 0001413492-24-000001
- CIK: 1413492
- File #: 8-67723
- Type: Broker-dealer
- Material weakness: No
- Auditor: EEPB Company
- Auditor location: Houston, TX
- Contact: Thomas Hensley
- Phone: 713-333-8400
- Email: thensley@parkmanwhaling.com
- Website: parkmanwhaling.com
- Signed by: Thomas Hensley (Chief Financial Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1413492/000141349224000001/2023auditreportparkman-.pdf

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| UNITED STATES<br>SECURITIES AND EXCHANGE COMMISSION<br>Washington,<br>D.C.                                                                                                                                     |                                  | OMB APPROVAL<br>OMB Number: 3235-0123<br>Expires: Nov. 30,<br>2026 |                             |  |  |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------|--------------------------------------------------------------------|-----------------------------|--|--|
| 20549                                                                                                                                                                                                          |                                  | Estimated average burden<br>hours per response:<br>12              |                             |  |  |
| ANNUAL<br>REPORTS                                                                                                                                                                                              |                                  | SEC FILE NUMBER                                                    |                             |  |  |
| X-17A-5<br>FORM                                                                                                                                                                                                |                                  | 8-67723                                                            |                             |  |  |
|                                                                                                                                                                                                                | PARTIN                           |                                                                    |                             |  |  |
| FACING PAGE<br>Information Required Pursuant to Rules 17a-5,<br>17a-12,<br>and 18a-7 under the Securities Exchange Act of 1934                                                                                 |                                  |                                                                    |                             |  |  |
| 01/01/2023<br>FILING FOR THE PERIOD BEGINNING<br>AND ENDING<br>MM/DD/YY                                                                                                                                        |                                  | 12/31/2023<br>MM/DD/YY                                             |                             |  |  |
|                                                                                                                                                                                                                | A.<br>REGISTRANT IDENTIFICATION  |                                                                    |                             |  |  |
|                                                                                                                                                                                                                |                                  |                                                                    |                             |  |  |
| Parkman<br>NAME OF FIRM.<br>:                                                                                                                                                                                  | Whaling                          | Securities<br>LLC                                                  |                             |  |  |
| TYPE OF REGISTRANT (check all applicable boxes):<br>B<br>Broker-dealer<br>Security-based swap dealer<br>Major security-based<br>swap participant<br>Check here if respondent is also an OTC derivatives dealer |                                  |                                                                    |                             |  |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS:                                                                                                                                                                        | (Do not use a P.O.               | box no.)                                                           |                             |  |  |
| Travis<br>600<br>Street,                                                                                                                                                                                       | Suite<br>600                     |                                                                    |                             |  |  |
|                                                                                                                                                                                                                | (No. and Street)                 |                                                                    |                             |  |  |
| Houston                                                                                                                                                                                                        |                                  | TX                                                                 | 77002                       |  |  |
| (City)                                                                                                                                                                                                         |                                  | (State)                                                            | (Zip Code)                  |  |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                                                                   |                                  |                                                                    |                             |  |  |
| Thomas<br>Hensley                                                                                                                                                                                              | 713-333-8400                     |                                                                    | thensley@parkmanwhaling.com |  |  |
| (Name)                                                                                                                                                                                                         | (Area Code -Telephone<br>Number) |                                                                    | (Email Address)             |  |  |
| B.<br>ACCOUNTANT IDENTIFICATION                                                                                                                                                                                |                                  |                                                                    |                             |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in<br>this filing*<br>EEPB<br>Company                                                                                                                |                                  |                                                                    |                             |  |  |
| (Name -if<br>individual,<br>state last,first,and<br>middle name)                                                                                                                                               |                                  |                                                                    |                             |  |  |
| 2950<br>North<br>Loop<br>Suite<br>West,                                                                                                                                                                        | Houston<br>1200                  | TX                                                                 | 77092                       |  |  |
| (Address)                                                                                                                                                                                                      | (City)                           | (State)                                                            | (Zip Code)                  |  |  |
| 11/05/2003                                                                                                                                                                                                     |                                  | 879                                                                |                             |  |  |
| (PCAOB Registration Number,if<br>(Date of Registration with PCAOB)(if applicable)<br>applicable)                                                                                                               |                                  |                                                                    |                             |  |  |
|                                                                                                                                                                                                                | FOR OFFICIAL USE ONLY            |                                                                    |                             |  |  |

\* Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by <sup>a</sup> statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(l)(ii),if applicable.

Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays <sup>a</sup> currently valid OMB control number.

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#### **OATH OR AFFIRMATION**

| ( Thomas Hensley

j swear (or affirm) that, to the best of my knowledge and belief, the *<sup>j</sup>* as of financial report pertaining to the firm of Parkman Whaling Securities LLC 12/31 2023

. ,is true and correct. <sup>I</sup> further swear (or affirm) that neither the company nor any partner, officer,director,or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of <sup>a</sup> customer.

Notary Public *<sup>J</sup>* **EDNA BARRAGAN SANCHEZ**

#### **This filing\*\* contains (check all applicable boxeSp /**

- H (a) Statement of financial condition.
- (b) Notes to consolidated statement of financial condition.
- S (c) Statement of income (loss) or,if there is other comprehensive income in the period(s) presented, <sup>a</sup> statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- H (d) Statement of cash flows.
- S (e) Statement of changes in stockholders' or partners' or sole proprietor'<sup>s</sup> equity.
- (f) Statement of changes in liabilities subordinated to claims of creditors.
- S (g) Notes to consolidated financial statements.
- H (h) Computation of net capital under <sup>17</sup> CFR 240.15c3-lor <sup>17</sup> CFR 240.18a-l, as applicable.
- (i) Computation of tangible net worth under <sup>17</sup> CFR 240.18a-2.
- (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to <sup>17</sup> CFR 240.15c3-3.
- (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit <sup>B</sup> to <sup>17</sup> CFR 240.15c3-<sup>3</sup> or Exhibit A to 17 CFR 240.18a-4, as applicable.
- (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- **B** (m) Information relating to possession or control requirements for customers under <sup>17</sup> CFR 240.15c3-3.
- (n) Information relating to possession or control requirements for security-based swap customers under <sup>17</sup> CFR 240.15c3-3(p)(2) or <sup>17</sup> CFR 240.18a-4, as applicable.
- **B** (o) Reconciliations,including appropriate explanations,of the FOCUS Report with computation of net capital or tangible net worth under <sup>17</sup> CFR 240.15c3-l,<sup>17</sup> CFR 240.18a-l,or <sup>17</sup> CFR 240.18a-2,as applicable,and the reserve requirements under <sup>17</sup> CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable,if material differences exist, or <sup>a</sup> statement that no material differences exist.
- (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- **B** (q) Oath or affirmation in accordance with <sup>17</sup> CFR 240.17a-5, <sup>17</sup> CFR 240.17a-12, or <sup>17</sup> CFR 240.18a-7, as applicable.
- (r) Compliance report in accordance with <sup>17</sup> CFR 240.17a-<sup>5</sup> or <sup>17</sup> CFR 240.18a-7, as applicable.
- **B** (s) Exemption report in accordance with <sup>17</sup> CFR 240.17a-<sup>5</sup> or <sup>17</sup> CFR 240.18a-7, as applicable.
- (t) Independent public accountant'<sup>s</sup> report based on an examination of the statement of financial condition.
- **B** (u) Independent public accountant'<sup>s</sup> report based on an examination of the financial report or financial statements under <sup>17</sup> CFR 240.17a-5,17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- (v) Independent public accountant'<sup>s</sup> report based on an examination of certain statements in the compliance report under <sup>17</sup> CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- **B** (w) Independent public accountant'<sup>s</sup> report based on <sup>a</sup> review of the exemption report under <sup>17</sup> CFR 240.17a-<sup>5</sup> or <sup>17</sup> CFR 240.18a-7, as applicable.
- (x) Supplemental reports on applying agreed-upon procedures,in accordance with <sup>17</sup> CFR 240.15c3-le or <sup>17</sup> CFR 240.17a-12, as applicable.
- (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or <sup>a</sup> statement that no material inadequacies exist,under <sup>17</sup> CFR 240.17a-12(k).
- (z) Other:

Chief Financial Officer

. ..y;

I

**My Notary ID » 128117456 Expires December 3, 2025** j \* :

*<sup>\*\*</sup>To request confidential treatment of certain portions of this filing, see <sup>17</sup> CFR 240.17a-5(e)(3) or <sup>17</sup> CFR 240.18a-7(d)(2), as applicable.*

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# **PARKMAN WHALING SECURITIES LLC**

**FINANCIAL STATEMENTS**

**DECEMBER 31, 2023**

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# **C O N T E N T S**

| Page                                                                                     |   |
|------------------------------------------------------------------------------------------|---|
| Report of Independent Registered<br>Public Accounting Firm                               | 2 |
| Balance Sheet<br>3                                                                       |   |
| Statement of Operations and Member's<br>Equity,<br>A                                     |   |
| Statement of Cash Flows<br>5                                                             |   |
| Notes to Financial Statements,<br>6-7                                                    |   |
| Schedule I<br>,8                                                                         |   |
| Schedule II<br>9                                                                         |   |
| Report of Independent Registered Public Accounting Firm and<br>Exemption Report<br>10-11 |   |

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![](_page_4_Picture_0.jpeg)

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Directors of Parkman Whaling Securities LLC

#### **Opinion on the Financial Statements**

We have audited the accompanying balance sheet of Parkman Whaling Securities LLC as of December <sup>31</sup>, <sup>2023</sup>, the related statements of operations and member'<sup>s</sup> equity, and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of Parkman Whaling Securities LLC as of December <sup>31</sup>, <sup>2023</sup>, 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 Parkman Whaling Securities LLC'<sup>s</sup> management. Our responsibility is to express an opinion on Parkman Whaling Securities LLC'<sup>s</sup> financial statements based on our audit. We are <sup>a</sup> public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to Parkman Whaling Securities LLC in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on <sup>a</sup> 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 <sup>a</sup> reasonable basis for our opinion.

#### **Auditor'<sup>s</sup> Report on Supplemental Information**

The Computation of Net Capital under Rule <sup>15</sup>C3-<sup>1</sup> of the Securities and Exchange Commission, and The Computation for Determination of Reserve Requirements and Information Relating to Possession or Control Requirements under Rule <sup>15</sup>C3-<sup>3</sup> of the Securities and Exchange Commission, has been subjected to audit procedures performed in conjunction with the audit of Parkman Whaling Securities LLC'<sup>s</sup> financial statements. The supplemental information is the responsibility of Parkman Whaling Securities LLC management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with <sup>17</sup> C.F.R. §240.17a-5. In our opinion, the Computation of Net Capital under Rule <sup>15</sup>C3-<sup>1</sup> of the Securities and Exchange Commission, and The Computation for Determination of Reserve Requirements and Information Relating to Possession or Control Requirements under Rule <sup>15</sup>C3-<sup>3</sup> of the Securities and Exchange Commission is fairly stated, in all material respects, in relation to the financial statements as a whole.

EEPB We have served as Parkman Whaling Securities LLC'<sup>s</sup> auditor since 2023. Houston, Texas February 9, 2024

**2950 North Loop West. Suite 1200 | Houston, TX 77092 | (p) 713 622.0016 | (f) 713.622.5527 | www.eepb.com An Independent Member of DrK International**

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| ASSETS                                                   |                       |
|----------------------------------------------------------|-----------------------|
| Cash and cash equivalents<br>Prepaid expenses -<br>other | \$<br>16,552<br>7,584 |
| TOTAL ASSETS                                             | \$<br>24,136          |
| LIABILITIES AN)MEMBER'S EQUITY                           |                       |
|                                                          |                       |
| Accounts payable<br>Member's<br>equity                   | \$<br>4,550<br>19,586 |

See accompanying notes.

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# **PARKMANWHALING SECURITIES LLC STATEMENT OF OPERATIONS AISD MEMBER S EQUITY FOR THE YEAR EfPED DECEMBER 31, 2023**

| REVENUES:                                                                                                                                                | \$ |                                                |
|----------------------------------------------------------------------------------------------------------------------------------------------------------|----|------------------------------------------------|
| EXPENSES:                                                                                                                                                |    |                                                |
| Office and administrative<br>services fee - Member<br>Office license fee - Member<br>Professional fees<br>Registration fees<br>Other administrative fees |    | 168,670<br>35,830<br>71,850<br>10,342<br>1,075 |
| TOTAL EXPENSES                                                                                                                                           |    | 287,767                                        |
| NET LOSS                                                                                                                                                 |    | (287,767)                                      |
| Member's equity, beginning<br>of year                                                                                                                    |    | 137,853                                        |
| Capital Contributions                                                                                                                                    |    | 169,500                                        |
| Member's equity, end of year                                                                                                                             | j  | 19,586                                         |

See accompanying notes.

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# **PARKMAN WHALING SECURITIES LLC STATEMENT OFCASH FLOWS FOR THE YEAR EhDED DECEMBER 31, 2023**

| CASH FLOWS FROM OPERATING<br>ACTIVITIES<br>Cash paid for administrative<br>fees and expenses<br>Net cash used<br>in operating activities | \$<br>(580,432)<br>(580,432) |
|------------------------------------------------------------------------------------------------------------------------------------------|------------------------------|
| CASH FLOWS FROM FINANCING<br>ACTIVrTIES<br>Contribution from Member<br>Net cash provided by financing<br>activities                      | 65,000<br>65,000             |
| NET DECREASE IN CASH AND<br>CASH EQUIVALENTS                                                                                             | (515,432)                    |
| CASH AND CASH EQUIVALENTS<br>AT BEGINNING OF YEAR                                                                                        | 531,984                      |
| CASH AND CASH EQUIVALENTS<br>AT END OF YEAR                                                                                              | \$<br>16,552                 |
| RECONCILIATION OF NET LOSS<br>TO NET CASH PROVIDED BY<br>OPERATING ACTIVITIES<br>Net loss                                                | \$<br>(287,767)              |
| Non-cash member contributions<br>Change in operating assets<br>and liabilities:                                                          | 104,500                      |
| Increase in prepaid expenses<br>Decrease in accounts payable                                                                             | (493)<br>(396,672)           |
| Net cash used in operating activities                                                                                                    | \$<br>(580,432)              |

See accompanying notes.

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#### Note 1

#### 1. ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

Parkman Whaling Securities LLC (the "Company") is <sup>a</sup> Texas limited liability company,formed on June <sup>19</sup>, <sup>2008</sup>. The Company is located in Houston, Texas and is <sup>a</sup> wholly-owned subsidiary of Parkman Whaling LLC (the "Member"). The Company'<sup>s</sup> revenues are derived primarily from advisory services. The Company is <sup>a</sup> registered broker-dealer with the Securities and Exchange Commission and is <sup>a</sup> member of Financial Industry Regulatory Authority (FINRA). The Company is considered "Non-Covered Firm" exempt from <sup>17</sup> <sup>C</sup>.F.R. § 240.15c3-<sup>3</sup> and is filing an Exemption Report relying on footnote <sup>74</sup> to SEC Release <sup>34</sup>-70073, and as discussed in Q&<sup>A</sup> <sup>8</sup> of the related FAQ issued by the SEC staff.

The following is <sup>a</sup> summary of significant accounting policies consistently followed by the Company.

Revenue Recognition - Revenue from contracts with customers includes fees from investment banking services. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at <sup>a</sup> 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'<sup>s</sup> progress under the contract; and whether constraints on variable consideration should be applied due to uncertain future events.

The Company earns fees in exchange for the services it provides and recognizes revenue when the Company has completed its contractual obligations and collection is reasonably assured.

Estimates - The preparation of accrual basis financial statements in conformity with accounting principles generally accepted in the United States of America (GAAP) requires the Company to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.

Statement Presentation - The unclassified balance sheet is presented in accordance with industry standards.

Cash and Cash Equivalents - The Company considers all highly liquid debt instruments with an original maturity of three months or less to be cash equivalents.

Income Taxes - The Company'<sup>s</sup> income, losses, and tax credits will be included in the income tax return of the Member. Accordingly,the Company does not record <sup>a</sup> provision for federal income taxes. Texas margin tax is accrued and included as <sup>a</sup> component of management fee and administrative expense. For the year ended December <sup>31</sup>, 2023,the Company had no margin tax expense.

The Company believes that all significant tax positions utilized by the Company will more likely than not be sustained upon examination. As of December <sup>31</sup>, <sup>2023</sup>, the tax years that remain subject to examination by the major tax jurisdictions under the statute of limitations are from the year 2020 forward (with limited exceptions).Tax penalties and interest,if any, would be accrued as incurred and would be classified as tax expenses in the statement of income and member'<sup>s</sup> equity.

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#### 2**.** AGREEMENTS AND COMMITMENTS

The Company entered into an office and administrative services agreement with Parkman Whaling LLC whereby Parkman Whaling LLC provides administrative and operational services, facilities, furniture and pays overhead expenses of the Company. The Company also entered into an office license agreement to utilize office space for <sup>a</sup> monthly rent allocation of \$18,<sup>780</sup> for the period of January and \$1,<sup>550</sup> for the period of February through December <sup>2023</sup>.

Office and administrative services and office license fees for <sup>2023</sup> were \$204,500. Parkman Whaling LLC contributed capital to the Company in the amount of \$169,500, comprised of cash of \$65,<sup>000</sup> and \$104,<sup>500</sup> of offset fees charged by Parkman Whaling LLC related to office administrative and operational services and office license fees during the year ended December 31, 2023.

## 3. NET CAPITAL REQUIREMENTS

Pursuant to the net capital provisions of Rule <sup>15</sup>c3-lof the Securities Exchange Act of <sup>1934</sup>,the Company is required to maintain <sup>a</sup> minimum net capital, as defined under such provisions. Net capital and the related net capital ratio may fluctuate daily.

At December <sup>31</sup>, <sup>2023</sup> the Company had net capital of \$12,<sup>002</sup> and <sup>a</sup> net capital requirement of \$5,000. The Company'<sup>s</sup> ratio of aggregate indebtedness to net capital was .<sup>38</sup> to <sup>1</sup> at December <sup>31</sup>, <sup>2023</sup>. The Securities and Exchange Commission permits <sup>a</sup> ratio of aggregate indebtedness to net capital for the Company of no greater than 15 to 1.

## **4.** CONCENTRATIONS AND CREDIT RISK

The Company'<sup>s</sup> demand bank account balance, which was \$16,<sup>552</sup> at December <sup>31</sup>, <sup>2023</sup>,is insured by the Federal Deposit Insurance Corporation (FDIC) up to \$250,000. It is the Company'<sup>s</sup> practice to utilize high net worth financial institutions to minimize its credit risk.

Generally, no collateral or other security is required to support trade receivables.

## 5. SUBSEQUENT EVENTS

The Company has evaluated subsequent events through February <sup>9</sup>,2024,the date the financial statements were available to be issued. No subsequent events occurred, which require adjustment or disclosure to the financial statements at December <sup>31</sup>, 2023.

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# **PARKMAN WHALING SECURITIES LLC SCHEDULE I COMPUTATION OF ICT CAPITAL UNDER RULE 15C3-1 OF THE SECURITIES AM) EXCHANGE COMMISSION DECEMBER 31, 2023**

| NET CAPITAL                                                                 |              |
|-----------------------------------------------------------------------------|--------------|
| Total member's equity qualified for net<br>capital                          | £<br>19,586  |
| Deductions and/or charges<br>Nonallowable assets:                           |              |
| Prepaid expenses                                                            | 7,584        |
| Net capital                                                                 | \$<br>12,002 |
| COMPUTATION OF BASIC NET CAPITAL<br>REQUIREMENTS                            |              |
| Minimum net capital required (6 2/3% of<br>total aggregate<br>indebtedness) | £<br>303     |
| Minimum dollar net capital requirement                                      | £<br>5,000   |
| Net capital requirement (greater of<br>above two minimum                    |              |
| requirement amounts)                                                        | £<br>5,000   |
| Excess net capital                                                          | £<br>7,002   |
|                                                                             |              |
| Ratio: Aggregate indebtedness to net capital                                | .38 to 1     |

Note: The above computation does not differ materially from the computation of net capital under Rule <sup>15</sup>c3-<sup>l</sup> as of December <sup>31</sup>, <sup>2023</sup>, filed with the Securities and Exchange Commission by the Company on Part DA of Form X-17a-5.

See report of independent registered public accounting firm.

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## **PARKMAN WHALING SECURITIES LLC SCHEDULE II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS AND INFORMATION RELATING TO POSSESSION OR CONTROL OF SECURITIES UNDER RULE 15C3-3 OF THE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31, 2023**

#### Exemption Provisions

The Company is considered "Non-Covered Firm"exempt from <sup>17</sup> <sup>C</sup>.F.R. § 240.15c3-<sup>3</sup> and is filing an Exemption Report relying on footnote <sup>74</sup> to SEC Release 34-70073,and as discussed in Q&<sup>A</sup> <sup>8</sup> of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to: (1) private placements of securities (including private investment in public equity transactions that will be handled on <sup>a</sup> best-efforts basis); (2) mergers and strategic advisory transactions,valuation advisory,fairness opinions,general strategic advice,and advice to the public and private entities and individuals on the purchase/sale of assets for cash or securities; and (3) recapitalization and reorganization advisory assignments.

See report of independent registered public accounting firm.

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## **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

**To the Board of Directors of Parkman Whaling Securities LLC**

**We have reviewed management'<sup>s</sup> statements, included in the accompanying Rule <sup>15</sup>c3-<sup>3</sup> Exemption Report pursuant to SEC Rule <sup>17</sup>a-5, in which (1) Parkman Whaling Securities LLC (the Company) did not claim an exemption under paragraph (k) of <sup>17</sup> <sup>C</sup>.F.R. §240.15c3-3, and (2) the Company is filing this Exemption Report relying on Footnote <sup>74</sup> of the SEC Release No. 34-70073 adopting amendments to <sup>17</sup> C.F.R. § 240.17a-<sup>5</sup> because the Company limits its business activities exclusively to (1) private placements of securities (including private investment in public equity transactions that will be handled on <sup>a</sup> best-efforts basis); (2) mergers and strategic advisory transactions, valuation advisory, fairness opinions, general strategic advice, and advice to the public and private entities and individuals on the purchase/sale of assets for cash or securities; and (3) recapitalization and reorganization advisory assignments.**

**In addition, the Company did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule <sup>15</sup>c2-<sup>4</sup> and/or funds received and promptly transmitted for effecting transactions via subscriptions on <sup>a</sup> subscription way basis where the funds are payable to the issuer or its agent and not to the Company; did not carry accounts of or for customers; and did not carry PAB accounts (as defined in Rule <sup>15</sup>c3-3) throughout the most recent fiscal year without exception.**

**Parkman Whaling Securities LLC'<sup>s</sup> management is responsible for compliance with the provisions contemplated by Footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 and related SEC Staff Frequently Asked Questions 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 Parkman Whaling Securities LLC'<sup>s</sup> compliance with the exemption provisions. <sup>A</sup> review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management'<sup>s</sup> 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'<sup>s</sup> statements referred to above for them to be fairly stated, in all material respects, based upon the Company'<sup>s</sup> business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to <sup>17</sup> C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions.**

**EEPB Houston, Texas February 9, 2024**

**2950 North Loop West. Suite 12001Houston. TX 770921 (p) 713.622.00161 (I) 713.622.55271www.eepb.com An Independent Member of DrK International**

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# **Parkman Whaling Securities LLC**

**600 Travis Street, Suite 600 / Houston, Texas 77002 713-333-8400**

# **Exemption Report**

**Parkman Whaling Securities LLC** (the "Company") is <sup>a</sup> registered broker-dealer subject to Rule <sup>17</sup>a-<sup>5</sup> promulgated by the Securities and Exchange Commission (<sup>17</sup> <sup>C</sup>.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-<sup>5</sup>(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 <sup>17</sup> C.F.R. § <sup>240</sup>. <sup>15</sup>c3-3, and

(2) The Company is considered "Non-Covered Firm" exempt from <sup>17</sup> C.F.R. § 240.15c3-3, and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073, and as discussed in Q8(A <sup>8</sup> of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to:(1) private placements of securities (including private investment in public equity transactions that will be handled on <sup>a</sup> best-efforts basis) (2) mergers and strategic advisory transactions, valuation advisory, fairness opinions, general strategic advice, and advice to the public and private entities and individuals on the purchase/sale of assets for cash or securities;and (3) recapitalization and reorganization advisory assignments.

(3)The Company (1)did notdirectly or indirectly receive,hold,or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule <sup>15</sup>c3-3),throughout the most recent fiscal year without exception.

## **Parkman Whaling Securities LLC**

<sup>I</sup>,Thomas Hensley,swear (or affirm) that,to my best knowledge and belief,this Exemption Report is true and correct.

Thomas Hensley, Chief Financial As of February 9, 2024


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