# SENDERO SECURITIES, LLC X-17A-5 (2023-02-23) — Broker-dealer annual report - Company: SENDERO SECURITIES, LLC - Form: X-17A-5 - Filed: 2023-02-23 - Period: 2022-12-31 - Accession: 0001427708-23-000003 - CIK: 1427708 - File #: 8-67834 - Type: Broker-dealer - Material weakness: No - Auditor: Phillip V. George, PLLC - Auditor location: Celeste, TX - Contact: Lori Darchicourt - Phone: 3172101076 - Email: idarchicourt@sendero.com - Website: sendero.com - Signed by: Lori Darchicourt (CFO/FinOp) Original filing: https://www.sec.gov/Archives/edgar/data/1427708/000142770823000003/sendero2022edgar2.pdf --- {0}------------------------------------------------ UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 > ANNUAL REPORTS FORM X-17A-5 > > PART III | Estimated average burden
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12 | |-------------------------------------------------------| | SEC FILE NUMBER | | 8-67834 | OMB APPROVAL OMB Number: 3235-0123 Expires: Oct. 31, 2023 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 01/01/22 | | 12/31/22
AND ENDING | | | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------|------------------------|-----------------|--------------------------------------------| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF FIRM: Sendero Securities, LLC | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
Broker-dealer Security-based swap dealer Major security-based swap participant
Check here if respondent is also an OTC derivatives dealer | | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | 250 W. Nottingham, Suite 300 | | | | | | | (No. and Street) | | | | | San Antonio | | Texas | | 78209 | | (City) | | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | Lori Darchicourt | 317.210.1076 | | | Idarchicourt@sendero.com | | (Name) | (Area Code - Telephone Number) | | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
Phillip V. George, PLLC | | | | | | 5179 CR 1026 | (Name - if individual, state last, first, and middle name)
Celeste | | X | 75423 | | (Address) | (City) | | (State) | (Zip Code) | | 02/24/2009 | | | 3366 | | | (Date of Registration with PCAOB)(if applicable) | | | | (PCAOB Registration Number, if applicable) | | | FOR OFFICIAL USE ONLY | | | | | | | | | | accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(ii), if applicable. Persons who are to respond to the collection of information contained in this form are not required to respond uniess the form displays a currently valid OMB control number. {1}------------------------------------------------ #### OATH OR AFFIRMATION #### | Lori Darchicourt swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Sendero Securities, LLC 12/31 , 2 022 \_\_ 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. ![](_page_1_Picture_5.jpeg) Title: CFO/FinOp #### This filing \*\* contains (check all applicable boxes): - (a) Statement of financial condition. - [ (b) Notes to consolidated statement of financial condition. - (c) Statement of income (loss) or, if there is other comprehensive 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. - [i) 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. - (I) 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 worth under 17 CFR 240.15c3-1, 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 subsidiaries not consolidated in the statement of financial condition. - (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 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 report or 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. - [x] Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.17a-12, 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 240.18a-7(d)(2), as applicable. {2}------------------------------------------------ #### FINANCIAL REPORT #### DECEMBER3I,2O22 {3}------------------------------------------------ ### CONTENTS | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOLINTING FIRM | | | |-------------------------------------------------------------|----|--| | | | | | FINANCIAL STATEMENTS | | | | Statement of Financial Condition | 2 | | | Statement of Income | J | | | Statement of Changes in Member's Equity | 4 | | | Statement of Cash Flows | 5 | | | Notes to Financial Statements | | | | Schedule l: Supplemental Information Pursuant to Rule 17a-5 | 10 | | | | | | | REPORT OF TNDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 12 | | | Exemption report | | | {4}------------------------------------------------ ### PHILLIP V. GEORGE, PLLC CERTIFIED PUBLIC ACCOUNTANT ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Member Sendero Securities, LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Sendero Securities, LLC as of December 31, 2022, the related statements of income, changes in member's equity, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of Sendero Securities, LLC as of December 31, 2022, 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 Sendero Securities, LLC's management. Our responsibility is to express an opinion on Sendero Securities, LLC'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 Sendero 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 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 supplemental information contained in Schedule I has been subjected to audit procedures performed in conjunction with the audit of Sendero Securities, LLC's financial statements. The supplemental information is the responsibility of Sendero Securities, LLC'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 supplemental information contained in Schedule I is fairly stated, in all material respects, in relation to the financial statements as a whole. PHILLIP V. GEORGE, PLLC We have served as Sendero Securities, LLC's auditor since 2008. Celeste, Texas February 23. 2023 5179 CR 1026 Celeste, TX 75423 (214) 358-5150 Fax (214) 358-02222 phil@pvgeorge.com {5}------------------------------------------------ #### Statement of Financial Condition December 31,2,022 #### ASSETS | Cash | \$ | 68,490 | |------------------|----|---------| | Receirables | | 45,600 | | Prepaid Expenses | | 8,1 28 | | Clearing Deposit | | 64,36r | | Total Assets | | 186,579 | #### Liabilities and Member's Equiry Liabilities | Accrued Expenses | 8,098 | | |---------------------------------------------------------------|---------------|--| | Offices and Administrative Services Fees payable-Related paty | 4,012 | | | Total Liabilities | 12,1 10 | | | Member's fuuit-v | 17 4,469 | | | Total Liabilities and Member's Equiry | t86,579
\$ | | {6}------------------------------------------------ Statement of Income Year Ended December 3t, ZOZT #### Revenue | Placernent Fees | \$
t82,290 | |---------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------| | Interest | 1,055 | | Total Revenue
Expenses | t83,345 | | Office and Adminisrative Service Fees - Related party
Regulatory Fees
Professional Fees
Other Expenses
Total 0perating Expenses | 48,144
6,060
33,302
6,670
94,176 | | Net Income | \$
89,169 | {7}------------------------------------------------ ## Statement of Changes in Member's Equity Year Ended December 31, 2022 | Member's Equity, December 31, 2021 | ಳಿ | 210,300 | |------------------------------------|----|-----------| | Net Income | | 89,169 | | Distributions to Member | | (125,000) | | Member's Equity, December 31, 2022 | S | 174,469 | See notes to financial statements. {8}------------------------------------------------ #### Statement of Cash Flows Year Ended December 3t,2022 | Cash Flows from Operating Activities: | | |-------------------------------------------|----------------| | Net Incorne | \$
89, 1 69 | | Adjustments to Reconcile Net Incorne to | | | Net Cash provided by Operating Activities | | | Change in Assers and Liabilities | | | Decrease in Receir.ables | 9,323 | | Decrease in Prepaid Expenses | 406 | | Increase in Clearing Deposit | (1,055) | | Decrease in Accrued Expenses | (922) | | Net Cash Provided by Operating Activities | 96,92t | | Cash Flows from Financing Activities | | | Disrributions to Member | ( 125,000) | | Net Decrease in Cash | (28,079) | | Cash at Beginning of Year | 96,569 | | Cash at End of Year | \$
68,490 | #### Supplemental Disclosure of Cash Florv lnformation: There was no cash paid during the year for interest ot income taxes. See notes to tinanciai statements. 5 {9}------------------------------------------------ ### SENDERO SECUzuTIES, LLC NOTES TO FINANCIAL STATEMENTS DECEMBER3l,2A22 ## NOTE A . ORGANIZATION AND SUMMARY OF SiGNIFICANT ACCOUNTING POLICIES Organization and Nature of Business; Sendero Securities, LLC (the "Cornpany") is a limited liability company organized under the laws o{ dre State of Texas in May 2007. The Company is a wholly owned subsidiary o{ Sendero Parrners, LLC ("Parent"), a Texas limited liability company. The Company is registered as a broker/dealer widr the Securities and Exchange Commission ("SEC") and is a membet of the Financial Industry Regulatory Authority ("FINRA") and the Securities Im,estor Protection Corporation ("SIPC"). Tlre Cornpany operates under the exernptive provisions of Rule L5c3-3(k)(7)(ii) of the Securities Exchange Act o{ 1934 ("SEA"), and accordingly, is exempt from the remaining provisions of that Rule. For the Cornpany's other business activities, it is considerec{ a Non-Covered Finn exempt from SEA Rule 15c3-3. Tlle Company does not hold customer funds or securities, carry accounrs for customers or carry PAB accounts (as defined in Rule 15c3-3). The Company earrrs placement fees from altemative asset management firms ("Management Firms") {or prirate placernent investments of clients of Sendero 'Wealth Managernent ("SY/M"), an Investment Advisor, who is an affiliate of the Cornpany. The Company does not earn placement fees on all private placement investments. Placement fees earned are dependent on the contractual telationships with the respective Management Firms. The Management Firms are based in the United States. Additionally, the Company may operate as an introducing broker on a fully disciosed basis clearing transactions through its clearing broker/dealer, but during 702? did not have any customer accounts nor any customer ffansactions with its clearing broker/dealer. #### Summarv of Sienificant Accounting Policies: Use of Estimates: The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires rnanagement to rnake estirnates 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 dre reporting period. Acrual results could differ from those estimates. Fair Value of Financial Instruments, Substantially all the Company's financial asser and liabllity amounts are short-term in nature and accordingly' are recorded at fair value or arnounts drat approximate fair r,alue. {10}------------------------------------------------ ## SENDERO SECURITIES, LLC NOTES TO FINANCIAL STATEMENTS DECEMBER3l,2022 ## NOTE A - ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued) Revenue Recoqnition, Revenue from contracts with customers includes placement fees. The recognition and measureulent of revenue is based on the assessrnent of individual contract terlns. Significanr judgrnent is required to deterrnine whether perforrnance obligations are satis{ied at a point in time or over time; hou. to allocate ffansaction prices '\*'here rnultiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; and',r.,hether consffaints on variable consideration should be applied due to uncertain future events. Placement fees consist of rnanagement fees and performance fees. Sen'ices are ptovided by alternarive asser management firms ("Management Firms") on a daily basis. The Company believes the performance obiigation on managelnent fees is satisfied over time because the Company is receiving and consuming the benefits as they are provided by the Management Firms. The Company's rnanagerrent fees are based on a predetermined fixed percentage applied to fees collected by the Management Firms. Management fees are recognized monthly as they relate specifically to the senices provicled in that period, which are distinct ftom ttre sen'ices provided in other periods. Management fees are received quarterly in arrears. As additional consideration, the Company receives performance fees drat vary based on specified perflormance measures, for example, rvhen a fund exceeds a specified benchmark or contractual hurdle over a contractual performance period. Performance fees are earned once account returns have exceeded these specified performance measures and are calculated as a percentage of account returns. Performance fees are considered variable consideration as the uncertainty is dependent on the value of the assets at future points in time (at the end of each calendar year) as well as meeting a specified compound lrurdle rate, both of w]rich are highly suscepdble to factors outside the Cornpany's influence. Performance fees are recognized at the end of each calendar year once it is probable that a significant reversal will not occllr. Income Taxes, The Company is a single member limited iiability company and is treated as a disregarded entiry for federal income tax purposes. The taxabie income or loss of the Company is included in the partnership income tax rerurn of tlre Parent. Therefore, federal income taxes are not payable by, or provided for, the Company. The Company is subject to state franchise taxes {11}------------------------------------------------ ### SENDERO SECURITTES, LLC NOTES TO FINANCIAL STATEMENTS DECEMBER3I.2O2z #### NOTEB-CLEARINGBROKER The Company has a clearing agreement with Pershing, LLC ("Pers[ring") to perflorm clearing sen'ices should the Company open customer accounts at Pershing. The agreement with Pershing requires the Cornpany to ma-intain a rninimum of \$60,000 in an account with Pershing. ### NOTE C - NET CAPITAL REQUIREMENTS The Cornpany is subject to the SEC Uniform Net Capital Rule (SEC Rule 15c3-1) which requires the maintenance of minimum net capital and requires that the ratio of indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31,2022, the Cornpany had net capital of \$120,7+1, which u,'as \$70,741 in excess of dre required net capital of \$50,000. The Company's net capital ratio was 0.10 to 1. ## NOTE D - CONCENTRATION OF CREDIT RISK AND REVENUE The Cornpany has placement fees due from one lllinois-based Management Firm toaling \$45,600 or 100% of its total receivables, and approximately Z5o/o o{ its total assets at December 31, 7022. For tlre year ended Decernber 31, 2027, the Company earned placement fees from this same Management Firm totaiing \$182,290, or approximately 99o/" of total revenue. ## NOTE E - REIATED PARTY TRANSACTIONS/ECONOMIC DEPENDENCY/CONCENTRATION OF REVENUE AND SERVICES Ttre Company is under the conrrol of its Parent and economically depenc{ent on another related entity, S\fM, an Investment Advisor. T[re existence of that control and dependency creates operating resulrc and a financial position significantly different than if the companies were autonomous. Transactions between the Company and S\7M were not consummated on terms equivalent to arms-length transactions. A11 of the Company's placement fees are earned from clients of S\fM {12}------------------------------------------------ ### SENDERO SECTIRITIES, LLC NOTES TO FINANCIAL STATEMENTS DECEMBER31,2022 ## NOTE E . REIATED PARTY TRANSACTIONS/ECONOMIC DEPEND ENCY/CONCENTRATION O F REVENUE AN D SERVTCES (Continued) The Company and S\fM have entered into an Office and Administrative Services Agreement as amended and restated most recently on January l, Z02L which automatically renewed on ]anuary l, 2023. This agreernent is automatically renewable, unless cancelled by either party. S.!U7M provides the Company with certain office {acilities and senices under this Agreernent, including but not limited to rent, office equipment and supplies, utilides, telephone, and salaries (excluding cornmissions). S\7M uray also pay ceftain expenses on behalf of the Company. S!7M allocates a pro,rata portion of such expenses incurred by S\UM on behalf of the Cornpany. In rnaking such allocation, S\7M equates the proportional cost of each faciliry or senice n'ith the proportional use or benefit derived by the Company. The expense allocation may change with the respective use and benefit of facilities and senices. Expenses allocated to and incurred on behaif of the Company under this Agreement during 2022 totaled \$48,144, of u,hich \$4,0t2 is payable at Decenrber 31,2022. ## NOTE F - CONTINGENCIES There are currently no asserted claims or legal proceedings against the Cornpany, however, the narure of the Company's business subjects it to various clairns, regulatory examinations, and other proceedings in the ordinary course of business. The ultirnate outcorne of any such future action against the Company could har.e an adverse impact on the financial condition, results o{ operations, or cash flows of the Company. ## NOTE G - SUBSEQUENT EVENTS The Company has evaluated subsequent events through February 23,2023, the date which the financial staternents were arailable to be issued. {13}------------------------------------------------ #### Schedule I ## SENDERO SECURITIES, LLC ### Supplemental Information Pursuant to Rule 17 a-5 December 31, 2022 | Total member's equity qualified for net capital | S | 174,469 | |---------------------------------------------------------------|------|-----------| | | | | | Deductions and/or charges | | | | Non-allowable assets: | | | | Receivables | | 45,600 | | Prepaid Expenses | | 8,128 | | Total deductions and/or charges | | 53,728 | | | | | | Net Capital | A | 120,741 | | Aggregate indebtedness | | | | Accrued Expenses | A | 8,098 | | Office and Administrative Services Fees Payable-Related Party | | 4,012 | | | | | | Total aggregate indebtedness | 5 | 12,110 | | | | | | Computation of basic net capital requirement | | | | Minimum net capital required (greater of \$50,000 or | | | | 6 2/3% of aggregate indebtedness) | ન્દિ | 50,000 | | | | | | Net capital in excess of minimum requirement | ತಿ | 70,741 | | Ratio of aggregate indebtedness to net capital | | 0.10 to 1 | See accompanying report of Independent Registered Public Accounting Firm {14}------------------------------------------------ ## Schedule I ## (Continued) SENDERO SECURITIES, LLC Supplemental Information Pursuant to Rule 17a-5 December 3\,2OZZ ### Reconciliation o{ Computation of Net Capital The computation of net capital does not differ from the computation of net capital under Rule 15c3-1 as of December 31,7072 as filed by Sendero Securities, LLC on Form X 17,d 5. Accordingly, no reconciliation is necessary. ## Statement Regarding Changes in Liabilities Subordinated to Claims of General Creditors No statement is required as no subordinated liabilities existed at any time during the year ## Statement Regarding Exemption from Reserve Requirements and Possession or Control Requirements The Company operates pursuant to section (kxzxi, exemptive provisions of Ruie l5c3-3 of the Securities Exchange Act o{ 1934. Under these exemptive provisions, the Computation of Determination of the Reserve Requirements and Information Relating to the Possession or Controi Requirements are not required. '!fle do not accept customer funds or securities and will not have possession of any customer funds or securities in connection with our activities. Therefore, in reliance on footnoteT4to SEC Release 34-70073 and as discussed in Q&A 8 of the related FAQ issued by SEC staff, the Companywill not claim an exemption from SEA Rule 15c3-3 as a "Non-Covered Firm". See accompanying report of lndependent Registered Public Accounting Firm {15}------------------------------------------------ ## PHILLIP V. GEORGE, PLLC CERTIFIED PUBLIC ACCOUNTANT #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Member Sendero Securities, LLC We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Sendero Securities, LLC identified the following provision of 17 C.F.R. §15c3-3(k) under which Sendero Securities, LLC claimed the following exemption from 17 C.F.R. §240.15c3-3:(2)(i) exemption provision and (2) Sendero Securities, LLC stated that Sendero Securities, LLC met the identified exemption provision throughout the most recent fiscal year without exception. The Company is also filing this Exemption Report because the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. \$ 240.17a-5 are limited to limited to private placement of securities. 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 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. Sendero Securities, LLC's management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Sendero Securities, LLC's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934 and the Company's other 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. pVilla, puc PHILLIP V. GEORGE, PLLC Celeste, Texas February 23, 2023 {16}------------------------------------------------ # Sendero Securities, LLC Exemption Report December 3L, 2022 Sendero Securities, LLC (the "Cornpany") is a registered brokerdealer subjectto Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. 5240.17a-5, "Reports to be made by certain brokers and dea[ers"). This Exernption Report was prepared as required by 17 C.F.R. S 240. 17a-5(dX1) and (4). To the best of its knowledge and belief, the Company states the following: (1) The Company claimed an exemption from 17 C.F.R. S 240.15c33 under the following provisions of 17 C.F.R. S 240.l5c3-3 (k),(2Xii) (2) The Company met the identified exemption provisions in 17 C.F.R. S 240.15c33 (k) throughout the most recent fiscal year without exception. (3) The Company is also filing this Exemption Report because the Company's other business activities contemplated by Footnote 74 of the SEC Release No.34-70073 adopting amendments to 17 C.F.R. S 240.17a-5 are limited to private placement of securities, and the Company (1) aia 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 (bXz) of Rule 15c24 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); (2) dia 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 without exception. Sendero Securities, LLC I, Lori K. Darchicourt, swear (or affirm) that, to my best knowledge and belief, this Exemption is true and correct. By, Title: Chief Financial Officer February ltr, 2o2g Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.