# OAK HILLS SECURITIES, INC. X-17A-5 (2025-01-07) — Broker-dealer annual report

- Company: OAK HILLS SECURITIES, INC.
- Form: X-17A-5
- Filed: 2025-01-07
- Period: 2024-09-30
- Accession: 0001415871-25-000001
- CIK: 1415871
- File #: 8-67740
- Type: Broker-dealer
- Material weakness: No
- Auditor: M&K CPAs, PLLC
- Auditor location: The Woodlands, TX
- Contact: Brian Megenity
- Phone: 7702636003
- Email: bmegenity@bdcaonline.com
- Website: bdcaonline.com
- Signed by: Donald Dillingham (CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1415871/000141587125000001/ohsaud.pdf

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|                                                                                                                                       | UNITED STATES                                                                         | 0MB APPROVAL                                                                                              |
|---------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------|
|                                                                                                                                       | 0MB Number: 3235-0123<br>SECURITIES AND EXCHANGE COMMISSION<br>Expires: Nov. 30, 2026 |                                                                                                           |
|                                                                                                                                       | Estimated average burden<br>hours per response: 12                                    |                                                                                                           |
|                                                                                                                                       | ANNUAL REPORTS                                                                        | SEC FILE NUMBER                                                                                           |
|                                                                                                                                       | FORM X-17A-5                                                                          |                                                                                                           |
|                                                                                                                                       | PART Ill                                                                              |                                                                                                           |
|                                                                                                                                       |                                                                                       |                                                                                                           |
|                                                                                                                                       | FACING PAGE                                                                           | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 |
| FILING FOR THE PERIOD BEGINNING 1 0/ 1 /2'Q23                                                                                         |                                                                                       | AND ENDING 9/30/2024                                                                                      |
|                                                                                                                                       | MM/DD/VY                                                                              | MM/DD/YY                                                                                                  |
|                                                                                                                                       | A. REGISTRANT IDENTIFICATION                                                          |                                                                                                           |
| NAME oF FIRM: Oak Hills Securities, Inc.                                                                                              |                                                                                       |                                                                                                           |
| TYPE OF REGISTRANT (check all applicable boxes):<br>I!] Broker-dealer<br>D Check here if respondent is also an OTC derivatives dealer | □ Security-based swap dealer                                                          | □ Major security-based swap participant                                                                   |
|                                                                                                                                       |                                                                                       |                                                                                                           |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                   |                                                                                       |                                                                                                           |
| 121 NE 50TH STREET                                                                                                                    |                                                                                       |                                                                                                           |
|                                                                                                                                       | (No. and Street)                                                                      |                                                                                                           |
| OKLAHOMA CITY                                                                                                                         | OK                                                                                    | 73105                                                                                                     |
| (City)                                                                                                                                | (State)                                                                               | (Zip Code)                                                                                                |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                          |                                                                                       |                                                                                                           |
| Brian Megenity                                                                                                                        | 770-263-6003                                                                          | bmegenity@bdcaonline.com                                                                                  |
| (Name)                                                                                                                                | (Area Code - Telephone Number)                                                        | (Email Address)                                                                                           |
|                                                                                                                                       | B. ACCOUNTANT IDENTIFICATION                                                          |                                                                                                           |
|                                                                                                                                       |                                                                                       |                                                                                                           |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*                                                             |                                                                                       |                                                                                                           |
| M&K CPAS, PLLC                                                                                                                        |                                                                                       |                                                                                                           |
|                                                                                                                                       | (Name - if individual, state last, first, and middle name)                            |                                                                                                           |
| 24955 Interstate Hwy 45 Ste 400                                                                                                       | The Woodlands TX                                                                      | 77380                                                                                                     |
| (Address)                                                                                                                             | (City)                                                                                | (State)<br>(Zip Code)                                                                                     |
| 7/18/2006                                                                                                                             |                                                                                       | #2738                                                                                                     |
| (Date of Registration with PCAOB)(lf applicable)                                                                                      |                                                                                       | (PCAOB Registration Number, if applicable)                                                                |
|                                                                                                                                       | FOR OFFICIAL USE ONLY                                                                 |                                                                                                           |
| • Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public                |                                                                                       |                                                                                                           |

accountant must be supported by a statement of facts and circumstances relied on as the basis ofthe exemption. See 17 CFR 240.17a-S(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 a** currently **valid 0MB control number.** 

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#### OATH OR AFFIRMATION

| DONALD L. DILLINGHAM swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of OAK HILLS SECURITIES, INC. as of the same as of al30 \_ 2024\_\_ , is true and correct. I 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 a customer. Signature: FLOR Title: CEO VOC # 09005431 Notary Public EXP. 06/30/25 This filing\*\* contains (check all applicante boxes); ー (a) Statement of financial condition □ (b) Notes to consolidated statement of ધ્યારૂત્તિ ເດີກີບ ■ (c) Statement of income (loss) or, if there is offiel to morehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X). (d) Statement of cash flows. = (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. □ (f) Statement of changes in liabilities subordinated to claims of creditors. = (g) Notes to consolidated financial statements. (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. [i] Computation of tangible net worth under 17 CFR 240.18a-2. □ {j} Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. □ {k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. □ {{} Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3. ] (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. [ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. ■ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. | (p) Summary of financial data for subsidiated in the statement of financial condition. [q] Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. | {r} Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | {t} Independent public accountant's report based on an examination of the statement of financial condition. ■ (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. □ {v} Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240 18a-7, as applicable. | as applicable. | (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). 」(z) Other: \*\* To request confidential treatment of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18o-7(d)(2), os opplicoble

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FINANCIAL STATEMENTS AND SUPPLEMENTAL SCHEDULES

AS OF AND FOR THE YEAR ENDED

SEPTEMBER 30, 2024

TOGETHER WITH REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

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## OAK HILLS SECURITIES, INC. Table of Contents September 30, 2024

| Report of Independent Registered Public Accounting Firm                                                                                  |
|------------------------------------------------------------------------------------------------------------------------------------------|
| Financial Statements:                                                                                                                    |
| Statement of Financial Condition<br>Statement of Operations<br>Statement of Changes in Shareholder's Equity<br>Statement of Cash Flows   |
| Notes to Financial Statements                                                                                                            |
| Supplemental Schedules:                                                                                                                  |
| Schedule I - Computation of Net Capital and Aggregate Indebtedness<br>Under Rule 15c3-1 of the Securities Exchange Commission            |
| Schedule II - Computation for Determination of Reserve Requirements<br>Under Rule 15c3-3 of the Securities Exchange Commission           |
| Schedule III - Information Relating to the Possession or Control Requirements<br>Under Rule 15c3-3 of the Securities Exchange Commission |
| Report of Independent Registered Public Accounting Firm on Management's<br>Exemption Report                                              |
| Management's Assertion of Exemption                                                                                                      |

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#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member Oak Hills Securities, Inc.

#### Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Oak Hills Securities, Inc. as of September 30, 2024, the related statements of operations, changes in shareholder's 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 Oak Hills Securities, Inc. as of September 30, 2024, 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 Oak Hills Securities, Inc.'s management. Our responsibility is to express an opinion on Oak Hills Securities, Inc.'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 Oak Hills Securities, Inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB .

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

#### Auditor's Report on Supplemental Information

The Schedule I, Computation of Net Capital And Aggregate Indebtedness Pursuant To SEC Rule 15c3-1, has been subjected to audit procedures performed in conjunction with the audit of Oak Hills Securities, Inc.'s financial statements. The supplemental information is the responsibility of Oak Hills Securities, Inc.'s management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the Schedule I, Computation of Net Capital And Aggregate Indebtedness Pursuant To SEC Rule 15c3-1, is fairly stated, in all material respects, in relation to the financial statements as a whole.

/s/ M&K CPAS, PLLC

M&K CPAS, PLLC We have served as Oak Hills Securities, Inc.'s auditor since 2023 The Woodlands, TX January 7, 2025

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# STATEMENT OF FINANCIAL CONDITION AS OF SEPTEMBER 30, 2024

## ASSETS

| Cash and cash equivalents<br>Accounts receivable, net<br>Other assets | S | 1,296,825<br>226,000<br>21,355 |
|-----------------------------------------------------------------------|---|--------------------------------|
| TOTAL ASSETS                                                          | S | 1,544,180                      |
| LIABILITIES AND SHAREHOLDER'S EQUITY                                  |   |                                |
| Commissions payable<br>Accounts payable                               | S | 1,101,036<br>37,986            |
| TOTAL LIABILITIES                                                     |   | 1,139,022                      |
| Shareholder's equity:<br>Common stock, \$.01 par value;               |   |                                |
| 100 shares authorized, issued and outstanding                         |   |                                |
| Additional paid-in-capital                                            |   | 43,999                         |
| Retained earnings                                                     |   | 361,158                        |
| Total shareholder's equity                                            |   | 405,158                        |
| TOTAL LIABILITIES AND SHAREHOLDER'S EQUITY                            |   | 1,544,180                      |

The accompanying notes are an integral part of these financial statements.

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### STATEMENT OF CHANGES IN SHAREHOLDER'S EQUITY FOR THE YEAR ENDED SEPTEMBER 30, 2024

|                             | Common Stock |    |        |    |                                |                      |   |                         |
|-----------------------------|--------------|----|--------|----|--------------------------------|----------------------|---|-------------------------|
|                             | Shares       |    | Amount |    | Additional Paid-<br>In-Capital | Retained<br>Earnings |   | Shareholder's<br>Equity |
| BALANCE, SEPTEMBER 30, 2023 | 100          | ని |        | ని | 43.999                         | \$ 316,235           | S | 360,235                 |
| Distributions<br>Net income |              |    |        |    |                                | (90.000)<br>134.923  |   | (90,000)<br>134.923     |
| BALANCE, SEPTEMBER 30, 2024 | 1 ()()       |    |        |    | 43.999                         | \$ 361.158           | D | 405.158                 |

The accompanying notes are an integral part of these financial statements.

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# STATEMENT OF CASH FLOWS FOR THE YEAR ENDED SEPTEMBER 30, 2024

## CASH FLOWS FROM OPERATING ACTIVITIES:

| Net income                                                  | S     | 134,923   |
|-------------------------------------------------------------|-------|-----------|
| Adjustments to reconcile net income to net cash provided by |       |           |
| operating activities:                                       |       |           |
| (Increase) decrease in operating assets:                    |       |           |
| Accounts receivable                                         |       | (182,316) |
| Other assets                                                |       | (17,286)  |
| Increase (decrease) in operating liabilities:               |       |           |
| Commissions payable                                         |       | 280,357   |
| Accounts payable                                            |       | 32,169    |
| Net cash provided by operating activities                   |       | 247,847   |
| CASH FLOWS FROM INVESTING ACTIVITIES:                       |       |           |
| Proceeds from certificate of deposit                        |       | 50,615    |
| Net cash provided by investing activities                   |       | 50,615    |
| CASH FLOWS FROM FINANCING ACTIVITIES:                       |       |           |
| Distributions                                               |       | (90,000)  |
| Net cash used in financing activities                       |       | (90,000)  |
| NET INCREASE IN CASH AND CASH EQUIVALENTS                   |       | 208,462   |
| CASH AND CASH EQUIVALENTS, beginning of period              |       | 1,088,363 |
| CASH AND CASH EQUIVALENTS, end of period                    | ਦੇ ਦੇ | 1,296,825 |

The accompanying notes are an integral part of these financial statements.

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The Company considers estimates and variable consideration when determining the transaction price. This includes estimates related to the collectability of success fees and adjustments for potential refunds or credits. Changes in the scope or price of a contract are considered contract modifications. Any modifications are evaluated for their impact on revenue recognition, and adjustments are made accordingly. The Company identifies performance obligations in its contracts based on the nature of services provided to clients. Performance obligations primarily consist of executing transactions, providing investment advice, and related services.

Success Fees - Success fees are recognized when the Company has fulfilled its performance obligations, and the criteria for revenue recognition under ASC 606 are met. Success fees are typically contingent on the successful completion of a transaction or achievement of a specific milestone as defined in the contract with a business. Revenue recognition occurs at the point in time when the transaction or milestone is achieved.

Advisory fees - Advisory fees are recognized over time as the Company satisfies its performance obligations by providing ongoing services to a business. This includes but is not limited to, preparing presentation packages, identifying, and performing due diligence on prospective investors, advising the client regarding any negotiations and completing any other financial advisory services deemed necessary to complete the transaction. Advisory fees are recognized on a straight-line basis over the period during which the services are provided, reflecting the Company's performance.

Fair value measurements - The carrying amounts of the Company's financial instruments, which include, current assets and current liabilities, approximate their fair values due to their short maturities.

Advertising costs - Advertising costs are expensed as incurred. There were no advertising expenses for the year ended September 30, 2024.

Income Taxes - The financial statements do not include a provision for federal income taxes because the Company has elected to be treated as a pass-through entity for federal income tax purposes and, as such, is not subject to Federal income taxes. Rather, all items of taxable income, deductions and tax credits are passed through and are reported by its owners on their respective income tax returns. Accordingly, the Company is not required to take any tax positions in order to qualify as a passthrough entity. The Company is required to file tax returns with other taxing authorities. Accordingly, these financial statements do not reflect a provision for federal income taxes and the Company has no other tax positions which must be considered for disclosure.

Recent accounting pronouncements - Accounting standards that have been issued or proposed by Financial Accounting Standards Board ("FASB") or other standards setting bodies are not expected to have a material impact on the Company's financial position, results of operations or cash flows.

Subsequent events - Management has evaluated events through January 7, 2025, the date the financial statements were available to be issued.

### 3. NET CAPITAL REQUIREMENTS

As a registered broker/dealer and member of the FINRA, 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 aggregated indebtedness to net capital, both as defined, shall not exceed 15 to 1 and prohibits a broker dealer from engaging in securities transactions when its net capital falls below minimum requirements as defined by the Rule. At September 30,

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2024, the Company's net capital and required net capital were \$379,283 and \$75,935 respectively. The Company's ratio of aggregate indebtedness to net capital was 3.0 to 1.

## 4. RELATED PARTY TRANSACTIONS

Through common ownership and management, the Company is affiliated with Avondale Investments, LLC (Avondale) which is 100% controlled by the sole shareholder of the Company. Additionally, through common ownership, the Company is affiliated with several entities (the "CNG Entities") that provided success fee revenue to the Company during the year ended September 30, 2024 as follows:

- CNG Dickson-Ringling
- CNG 2023 Vehicles II .
- CNG 2023 Vehicles III o
- CNG 2023 Vehicles IV ●
- CNG 2023 Stations 0
- CNG 2024 Stations I ●
- CNG 2024 Stations II 0
- CNG 2024 Habitat Station .

The Company's sole shareholder owns less than 5% of any of the CNG Entities. The CNG Entities provided \$590,500 in success fees during the year, which represents 20% of total revenue recorded for the year ended September 30, 2024.

The Company leases office space from Avondale under an operating lease, with a term of twelve months, effective through June 30, 2025 for \$450 per month. The occupancy expense incurred for the year ended September 30, 2024 pursuant to the terms of the lease was \$5,400. Minimum future lease payments on this lease totals \$4,050.

Commissions paid to the Company's sole shareholder totaled \$135,600 during the year ended September 30, 2024. Distributions totaling \$90,000 were paid to the Company's sole shareholder during the year ended September 30, 2024.

## 5. COMMITMENTS AND CONTINGENCIES

Litigation - The Company from time to time may be involved in litigation relating to claims arising out of its normal course of business. Management believes that there are no claims or actions pending or threatened against the Company, the ultimate disposition of which would have a material impact on the Company's financial position, results of operations or cashflows.

Risk Management - The Company maintains various forms of insurance that Company's management believes are adequate to reduce the exposure to these risks to an acceptable level.

### 6. CONCENTRATIONS

For the year ended September 30, 2024, 98% of the Company's revenue was derived from four customers and 79% of commission expenses were earned by a single individual. Additionally, 100% of accounts receivable were due from a single customer.

\*

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SUPPLEMENTAL SCHEDULES

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## SCHEDULE I

## COMPUTATION OF NET CAPITAL AND AGGREGATE INDEBTEDNESS PURSUANT TO RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION

## FOR THE YEAR ENDED SEPTEMBER 30, 2024

## COMPUTATION OF NET CAPITAL

| Total shareholder's equity                                                  | S | 405,158      |
|-----------------------------------------------------------------------------|---|--------------|
| Deductions:                                                                 |   |              |
| Nonallowable assets                                                         |   | (25,875)     |
| Net capital before haircuts on securities                                   | A | 379,283      |
| Haircuts on securities                                                      |   |              |
| Undue concentration                                                         |   |              |
| Net capital                                                                 | ക | 379,283      |
| COMPUTATION OF BASIC NET CAPITAL REQUIREMENT                                |   |              |
| Minimum net capital requirement (6 2/3% of total<br>aggregate indebtedness) | S | 75,935       |
| Minimum dollar net capital requirement                                      | S | 5,000        |
| Net capital requirement                                                     | S | 75,935       |
| COMPUTATION OF AGGREGATE INDEBTEDNESS                                       |   |              |
| Total liabilities from statement of financial condition                     |   | \$ 1,139,022 |
| Net capital in excess of minimum requirement                                | S | 303,348      |
| Percentage of aggregate indebtedness to net capital                         |   | 300%         |

Note: There are no material differences between the above computation and the computation of net capital under Rule 15c3-1 as of September 30, 2024 as reported by Oak Hills Securities, Inc. on January 7, 2025 on Form X-17A-5. Accordingly, no reconciliation is deemed necessary.

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### SCHEDULE II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF SEPTEMBER 30, 2024

With respect to the Computation for Determination of Reserve Requirements under Rule 15c3-3, the Company does not claim an exemption from Rule 15c3-3 in reliance upon footnote 74 of SEC Release No. 34-70073 dated July 30, 2013, and as discussed in Question 8 of the related FAQ released by SEC staff. The Company does not hold customer funds or securities.

### SCHEDULE III INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF SEPTEMBER 30, 2024

With respect to the Information Relating to Possession and Control Requirements under Rule 15c3-3, the Company does not claim an exemption from Rule 1 5c3-3 in reliance upon footnote 74 of SEC Release No. 34-70073 dated July 30, 2013, and as discussed in Question 8 of the related FAQ released by SEC staff. The Company does not hold customer funds or securities.

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#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member Oak Hills Securities, Inc.

We have reviewed management's statements, included in the accompanying Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, in which (1) Oak Hills Securities, Inc. (the Company) did 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 Footnote 74 of the SEC Release 34-70073 adopting amendments to 17 C.F.R. §240.17a-5 because the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients, referring securities transactions to other broker-dealers; participating in distributions of securities in accordance with the requirements of paragraph (a) or (b)(2) of Rule 15c2-4, and 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 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a 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 15c3-3) throughout the most recent fiscal year without exception.

Oak Hills Securities, Inc.'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 Oak Hills Securities, Inc.'s compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.

Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based upon the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240.17a-5, and related SEC Staff Frequently Asked Questions.

/s/ M&K CPAS, PLLC

M&K CPAS, PLLC The Woodlands, TX January 7, 2025

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## **OAK HILLS SECURITIES, INC. EXEMPTION REPORT YEAR ENDED SEPTEMBER 30, 2024**

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

The Company does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3 and the Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; receiving transaction-based compensation for identifying potential merger and acquisition opportunities for clients, referring securities transactions to other broker-dealers; participating in distributions of securities in accordance with the requirements of paragraph (a) or (b)(2) of Rufe 15c2-4, and 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 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a 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 15c3-3) throughout the most recent fiscal year without exception.

I, Donald Dillingham, swear that, to the best knowledge and belief, the Exemption Report is true and correct.

~

Donald Dillingham, President Oak Hills Securities, Inc.


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