# MENTOR SECURITIES, LLC X-17A-5 (2021-02-25) — Broker-dealer annual report - Company: MENTOR SECURITIES, LLC - Form: X-17A-5 - Filed: 2021-02-25 - Period: 2020-12-31 - Accession: 0001438312-21-000001 - CIK: 1438312 - File #: 8-67923 - Material weakness: No - Auditor: LMHS, P.C. - Auditor location: Norwell, MA - Contact: Mark T Manzo - Phone: 2015191905 - Website: nationalnotary.org - Signed by: Davis Blaine (Chairman) Original filing: https://www.sec.gov/Archives/edgar/data/1438312/000143831221000001/menauditreport.pdf --- {0}------------------------------------------------ # Mentor Securities, LLC Financial Statements and Supplementary Information For the Year Ended December 31, 2020 (Confidential Pursuant to Rule 17a-5(e)(3)) {1}------------------------------------------------ UNITEDSTATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMBAPPROVAL 0MB Number: 3235-0123 Expires: October 31, 2023 Estimated average burden hours per response .... . . 12.00 # **ANNUAL AUDITED REPORT FORM X-17A•5 PARTIII** SEC FILE NUMBER 8~67923 **FACING PAGE Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder** | | REPORT FOR THE PERIOD BEGINNINGQ1/Q1/2Q2Q
AND ENDING 12/31/2020 | | | | |--------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------|---------|------------------------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | Securities,
NAME OF BROKER-DEALER: Mentor
LLC
ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | OFFICIAL USE ONLY
FIRM I.D. NO. | | | | | | | | | N.
Westlake
Suite
200
Blvd.,
204 | | | | | | | (No. and Street) | | | | | Westl&ke/Ufablge | | | 91362 | | | (City) | (State) | | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT | | | | | | | | | (Area Code - Telephone Number) | | | | B. ACCOUNT ANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | LMHS,
P.C. | | | | | | | (Name - if individual, state lasl,first, middle name) | | | | | 80
Washington
St
, Bldg
S | Norwell | MA | 02061 | | | (Address) | (City) | (State) | (Zip Code) | | | CHECK ONE: | | | | | | It/
j
Certified Public Accountant | | | | | | Public Accountant | | | | | | D | | | | | | Accountant not resident in United States or any of its possessions. | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | | | | | | | *\*Claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.17a-5(e)(2)* SEC 1410 (11·05) **Potential persons who are to respond to the collection of Information contained** In **this form are not required to respond unless the form displays a currently valid 0MB control number.** {2}------------------------------------------------ #### **OATH OR AFFIRMATION** | 1, Davis Blaine | , swear (or affirm) that, to the best of | |------------------------|-----------------------------------------------------------------------------------------------------------------| | | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of | | Mentor Securities, LLC | as
------' | | ----------------- | ---------------------- | of December 31, are trne and co1Tect. I further swear (or affirm) that neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows: | Chairman | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Title | | Lilt!
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tary Public | | This report** contains (check all applicable boxes):
0
(a) Facing Page.
0
(b) Statement of Financial Condition.
~ (c) Statement oflncome (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement
of Comprehensive Income (as defined in §210.1-02 of Regulation S-X).
Statement of Changes in Financial Condition. | | Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. | | Statement of Changes in Liabilities Subordinated to Claims of Creditors. | | Computation of Net Capital.
Computation for Determination of Reserve Requirements Pursuant to Rule l 5c3-3. | | Information Relating to the Possession or Control Requirements Under Rule 15c3-3. | | A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule I 5c3-l and the
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | | 0
(k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of
consolidation. | | 0
An Oath or Affinnation .
(1) | | D
(m) A copy of the SIPC Supplemental Report.
D
(n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. | | **
For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3). | {3}------------------------------------------------ #### **CALIFORNIA JURAT WITH AFFIANT STATEMENT GOVERNMENT CODE** § **8202** i;;zJ See Attached Document (Notary to cross out lines 1-6 below) D See Statement Below (Lines 1-6 to be completed only by document signer[s], not Notary) Signature of Document Signer No. 1 Signature of Document Signer No. 2 (if any) A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate Is attached, and not the truthfulness, accuracy, or validity of that document. State of California County of \_.L=o=s'-'A-"n'-'-'g"'e,.\_,l=e.,.\_s \_\_ \_ Subscribed and sworn to (or affirmed) before me / & day of *[,t,/orvlJ.'(1./* by Date Monti{ on this I 20.li\_, Year **1············f** STEVEN U. BAUTISTA : • Notary Public - Californ ia 2 i Los Angeles County ss , .. Commission # 2205691 - My Comm. Expires Aug 13, 2021 proved to me on the basis of satisfactory evidence to be the person(S') who appeared efore me. *(1)\_ ........ D~ a -"- v -'--' i's"---\_6c,c\_/.c..c....1'+-1 ~n -=v \_ \_\_ \_* (and (2) \_ \_ \_\_\_\_\_\_\_\_\_\_ ), Name(s) of Signer(s) Sea/ Place Notary Seal Above **OPTIONAL** Though this section is optional, completing this information can deter alteration of the document or fraudulent reattachment of this form to an unintended document. **Description of Attached Document** Title or Type of Document: *Oafh or* /JUi n-1t-t /-rffa. Document Date: \_\_\_ \_\_\_ \_ Number of Pages: \_ \_ Signer(s) Other Than Named Above: \_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_ ©2014 National Notary Association• www.NationalNotary.org • 1-800-US NOTARY (1-800-876-6827) Item #5910 {4}------------------------------------------------ # **Mentor Securities, LLC** #### **December 31, 2020** #### **Table of Contents** | Report of Independent Registered Public Accounting Finn | | |---------------------------------------------------------------------------------------------------------------------------|------| | Statement of Financial Condition | 2 | | Statement of Operations | 3 | | Statement of Changes in Members' Equity | 4 | | Statement of Cash Flows | 5 | | Notes to the Financial Statements | 6-10 | | Supplemental Information | | | Schedule I: | | | Computation of Net Capital Under Rule l 5c3-l
of the Securities and Exchange Commission | 11 | | Reconciliation with Company's Net Capital Computation | 12 | | Schedule II: | | | Computation for Determination of Reserve Requirements
Under Ruic 15c3-3 of the Securities and Exchange Commission | | | Schedule Ill: | | | Information Relating to Possession or Control Requirements
Under Rule 15c3-3 of the Securities and Exchange Commission | 13 | | Review Report oflndependent Registered Public Accounting Finn | 14 | | Management's Assertion Regarding Exemption - Non-Covered Firms) | 15 | {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) *Report of Independent Registered Public Accounting Firm* To the Member Mentor Securities, LLC Westlake Village, CA #### *Opi11io11 011 the Fi11a11cial Stateme11ts* We have audited the accompanying statement of financial condition of Mentor Securities, LLC, as of December 3 1, 2020, and the related statements of operations, changes in members' equity and cash flows for the year then ended, and the related notes (collectively refe1Ted to as the "financ ial statements"). In our opinion, the financial statements present fairly , in all material respects, the financial position of Mentor Securities, LLC as of December 31 , 2020, and the results of its operations and its cash flows for the year then ended December 3 1, 2020, in confo rmity with accounting principles generally accepted in the United States of America. #### *Basis for Opi11io11* These financial statements are the responsibility of the entity's management. Our responsibility is to express an opinion on these fin ancial 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 Mentor 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 fin ancial statements are free of materi al misstatement, whether due to error or fraud. Our audit included pcrfonning procedures to assess the risks of materi al misstatement of the fin ancial statements, whether due to error or fraud, and perfonning procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financi al 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. #### *S11pple111e11tal Infor111atio11* The supplemental information appearing on page l4 has been subjected to audit procedures perfom1ed in conjunction with the audit of Mentor Securities, LLC's fin ancial statements. The supplemental in formation is the responsibility of Mentor Securities, LLC management. Our audit procedures included detennining whether the supplemental infomrntion 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 in fo rmation presented in the supplemental information. In forming our op inion on the supplemental information, we evaluated whether the supplemental in formation, including its fo1111 and content, is presented in conformity with C.F.R. *§240.17a-5.* In our opinion, the supplemental infom1ation is fa irly stated, in all materi al respects, in relation to the financial statements as a whole. LM HS, P.C. \Ve have served as the Company's auditor since 2020. Norwell, Massachusetts 2/ 15/202 1 ![](_page_5_Picture_13.jpeg) {6}------------------------------------------------ # **MENTOR SECURITIES, LLC** # **Statement of Financial Condition December 31, 2020** #### ASSETS | Cash and cash equivalents [Note 2]
Prepaid Expenses | | 22,856
8,948 | |------------------------------------------------------------|----|-----------------| | Total assets | \$ | 31,804 | | LIABILITIES AND MEMBERS' EQUITY | | | | Liabilites: | | | | Current liabilities
Accounts payable & Accrued expenses | \$ | 4,146 | | Total liabilities | | 4,146 | | | | | | Members' equity : | | | | Members' equity | | 27,658 | | Total members' equity | | 27,658 | | Total liabilities and members' equity | \$ | 31,804 | *The accompanying notes are an integral part of these.financial statements* {7}------------------------------------------------ # **MENTOR SECURITIES, LLC** # **Statement of Operations For the year ended December 31, 2020** #### REVENUE | Retainer fees
35,000
Interest Income
81
Other Income
1,543
Total revenue
\$
101,474
EXPENSES:
Professional fees
28,318
\$
Commission expense
60,300
Rent expense
1,800
Other operating expenses
10,610
Total expenses
101,028
\$
NET INCOME BEFORE INCOME TAXES
\$
446
LLC fees & CA annual minimum tax [Note 4]
\$
7,956
NET LOSS
\$
(7,510) | Success fees | \$ | 64,850 | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|----|--------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | *The accompanying notes are an i11tegral part of these financial statements* {8}------------------------------------------------ # **MENTOR SECURITIES, LLC Statement of Changes in Member's Equity For the year ended December 31, 2020** | | | Member's
Equity | | Net
Gain | Contributions
(Distributions) | Total
Member's
Equity | | |---------------------------------------------------------------------------------------------------|----|--------------------|----|-------------|----------------------------------|-----------------------------|-----------------------------| | Beginning balance January 1, 2020
Member's contributions
Net Loss
Member's distributions | \$ | 21,168 | | (7,510) | 14,000 | \$ | 21,168
14,000
(7,510) | | Ending balance December 31, 2020 | \$ | 21,168 | \$ | (7,510) \$ | 14,000 | \$ | 27,658 | *Tl,e accompanying notes are an integral part of these financial statements* {9}------------------------------------------------ # **MENTOR SECURITIES, LLC Statement of Cash Flows For the year ended December 31, 2020** # CASH FLOWS FROM OPERA TING ACTIVITIES | Net Loss | \$
(7,510) | |-----------------------------------------------|----------------| | Adjustments to reconcile net loss to net cash | | | provided/(used) by operating activities: | | | (Increase) decrease in: | | | Prepaid Expenses | (5,094) | | Increase (decrease) in: | | | Accounts Payable & Accmed Expenses | (3,196) | | | | | Total adjustments | \$
(8,290) | | Net cash used in operating activities | \$
(15,800) | | | | | CASH FLOWS FROM INVESTING ACTIVITIES | | | Contributions | 14,000 | | Distributions | | | Net cash provided by investing activities | \$
14,000 | | | | | Decrease in cash | \$
(1,800) | | beginning of year
Cash - | \$
24,656 | | end of period
Cash - | \$
22,856 | *The accompanying notes are an integral part of these financial statements* {10}------------------------------------------------ ### **Note 1: Organization** Mentor Securities, LLC (the "Company") was organized in the State of California on April 27, 2007. The Company is currently registered as a broker-dealer under Section l 5(b) of The Securities Exchange Act of 1934, a member of the Financial Industry Regulatmy Authority [''FINRA"] and the Security Investor Protection Corporation ["SIPC"]. The Company is engaged in business as a securities broker-dealer, which provides several classes of services, including private placements and merger and acquisitions. Under its membership agreement with FINRA the Company will not claim an exemption from SEA Rule 15c3-3. The Company is a Non-Covered firm that relies on Footnote 74 to SEC Release 34-70073. The Company does not hold or carry customer funds or securities. ### **Note 2: Summary of Significant Accounting Policies** # **Basis of Presentation** The accompanying financial statements of the Company have been prepared in accordance with accounting principles generally accepted in the United States of America. The Company uses accrual method of accounting. ## **Use of estimates** The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the rep011ed amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the financial statements as well as the reported amount of revenues and expenses during the reporting period. Actual results could differ from these estimates. ### **Cash and Cash Equivalents** The Company considers all highly liquid instruments with an original maturity of three months or less when purchased to be cash equivalents. As of December 31, 2020, the Company had a cash balance of \$22,856. ### **Revenue Recognition** The company receives fees in accordance with terms stipulated in its engagement contracts. Fees are recognized as earned. The Company also receives success fees when transactions are completed. Success fees are recognized when earned, which means the Company has no further continuing obligations and collection is reasonably assured. Retainer fees that are not subject to refund are recognized when received subject to the terms of engagement. {11}------------------------------------------------ ### **Revenue Recognition (Continued)** ### A. Significant accounting policy Revenue is measured based on a consideration specified in a contract with a customer, and excludes any sales incentives and amounts collected on behalf of third parties. The Company recognizes revenue when it satisfied a performance obligation by transferring control over a product or service to a customer. Taxes and regulatory fees assessed by a government authority or agency that are both imposed on and concurrent with a specified revenue-producing transaction, that are collected by the Company from a customer, are excluded from revenue. ### B. Nature of services Fees earned: This includes fees earned from affiliated entities; investment banking fees, **M&A** advisory; account supervision and investment advisory fees; administrative fees, revenue from research services; rebates from exchanges/ECN and A TS; l 2b-l fees; Mutual fund fees other than concessions or 12b-1 fees; execution service fees; clearing services; fees earned from customer bank sweep into FDIC insured products or from '40Act companies and networking fees from '40 Act companies. ### C. Changes in Accounting Policy: The Company adopted Topic 606 "Revenue from Contracts with Customers" with a date of January 1, 2018. As a result, it has changed its accounting policy for revenue recognition as detailed below. The Company applied Topic 606 using the cumulative effect method - i.e. by recognizing the cumulative effect of initially applying Topic 606 as an adjustment to the opening balance of equity at January I, 2018. This was immaterial. Therefore, any prior reporting infonnation has not been adjusted and continues to be repo1ied under Topic 606. The Company provides advisory services on mergers and acquisitions (M&A). Revenue for advisory arrangements is generally recognized at the point in time that performance under the arrangement is completed (the closing date of the transaction) or the contract is cancelled. However, for certain contracts, revenue is recognized over timer for advisory arrangements in which the perfonnance obligations arc simultaneously provided by the Company and consumed by the customer. In some circumstances, significant judgment is needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract. Retainers and other fees received from customers prior to recognizing revenue are reflected as contract liabilities. At December 31, 2020, the Company maintains that no such contract liabilities existed nor were there any circumstances whereby significant judgement was needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract. {12}------------------------------------------------ # **Professional fees** As of December 31, 2020, the Company paid \$28,318 in professional fees, which included legal, accounting, analysis, and consulting services. ### **Comprehensive Income:** The Company adopted SF AS No. 130, "Reporting Comprehensive Income," which requires that an enterprise report, by major components and as a single total, the changes in equity. There were no comprehensive income items for the year ended December 31 , 2020. The finn did not have any adjustments that would have made comprehensive income different from net income. ### **Note 3: Securities owned** As of the statement of financial condition date the Company does not own any corporate stocks or debt instruments. ### **Note 4: Income taxes** The Company, with the consent of its members, has elected to be a California Limited Liability Company. For tax purposes the Company is treated like a pa1inership, therefore in lieu of business income taxes for Federal and State income tax, all income or loss "flows through" to the member's individual income tax returns. However, provisions are made for the State of California's annual minimum tax and LLC fees that are reflected in these financial statements. As the tax obligations are passed through to its members, any audit or review considerations related to Internal Revenue Under section 650l(a) of the Internal Revenue Code (Tax Code) and section 30l.6501(a)-l(a) of the Income Tax Regulations (Tax Regulations), the IRS is required to assess tax within 3 years after the tax return was filed with the IRS. Service assessments and statute of limitations thereof are borne by the Company's members. # **Note 5: Fair Value** The Company adopted Financial Accounting Standards ("SF AS") ASC 820 Measurements and Disclosures, for assets and measured at fair value on a recurring basis. The ASC 820 had no effect on the Company's financial. ASC 820 accomplishes the following key objectives: - Defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date; - Establishes a three-level hierarchy (the "Valuation Hierarchy") for fair value measurements; {13}------------------------------------------------ ### **Note 5: Fair Value Continued** • Requires consideration of the Company's creditworthiness when valuing liabilities; and expands disclosures about instruments measured at fair value. The Valuation Hierarchy is based upon the transparency of inputs to the valuation of an asset or liability as of the measurement date. A financial instrument's categorization within the Valuation Hierarchy is based upon the lowest level of input that is significant to the fair value measurement. The three levels of the Valuation Hierarchy and the distribution of the Company's financial assets within it are as follows: - Level 1 inputs to the valuation methodology are quoted pnces (unadjusted) for identical assets or liabilities in active markets. - Level 2 inputs to the valuation methodology included quoted prices for similar assets and liabilities in active markets, and inputs that are observable for the asset or liability, either directly or indirectly, for substantially the full term of the financial instrument. - Level 3 inputs to the valuation methodology are unobservable and significant to the fair value measurement. Certain financial instruments are carried at cost on the statement of financial condition, which approximate fair value due to their short-term highly liquid nature. These instruments include cash and cash equivalents, accounts receivable, accrued expenses and other liabilities and deferred revenue. ### **Note 6: Net capital requirements** Pursuant to the Basic Uniform Net Capital prov1s10ns of the Securities and Exchanges Commission, the Company is required to maintain a minimum net capital, as defined, in such provision. Further, the provisions require that the ratio of aggregate indebtedness, as defined, to net capital shall not exceed 15 to 1. Net capital and the related net capital ratio may fluctuate on a daily basis. At December 31 , 2020 the Company had net capital and net capital requirements of \$18,710 and \$5,000 respectively. The Company's aggregate indebtedness to net capital ratio was .22 to I which is less than 15: l. ### **Note** 7: **Related party transactions** The Company shares office space with an entity related by common management. The Company pays rent to one of its members for this office space. During the year December 31, 2020 the Company paid \$1,800 to its member under this agreement. At December 31, 2020, the Company owed its Parent, The Mentor Group, LLC, \$2,650. {14}------------------------------------------------ # **Note 8: Commitments and Contingencies** As of the audit date there are no contingencies, guarantees of debt, and the like. Rental commitment which includes administrative services is \$150.00/month or \$1,800/year. # **Note 9: Subsequent Events** Management has evaluated subsequent events through February 15, 2021, the date which the financial statements were available to be issued. As a result of the COVID-19 outbreak in the United States, the financial and operational challenges have risen. The Company has been able to enact procedures to abate the financial and operational effects of the outbreak without a reduction in workforce. Although these challenges are expected to be temporary, the extent of the financial impact and other possible impacting matters going forward are unknown at this time. {15}------------------------------------------------ # **Schedule I** # **Mentor Securities, LLC** # **Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission As of December 31, 2020** | NET CAPITAL | | | |------------------------------------------------------------|-------|--------------| | Total partners' equity | | \$
27,658 | | Deduct member's equity not allowable for net capital | | | | Total member's equity qualified for net capital | | 27,658 | | Deductions: | | | | Nonallowable assets | | | | Prepaid expenses | 8,948 | | | | | 8,948 | | Net capital before haircuts on securities positions | | 18,710 | | Haircuts on securities | | | | | | | | NET CAPITAL | | \$
18,710 | | AGGREGATE INDEBTEDNESS | | | | Other payable and accrued expenses, and others | 4,146 | | | | | 4,146 | | Total aggregate indebtedness | | \$
4,146 | | COMPUTATION OF BASIC NET CAPITAL REQUIREMENT | | | | Minimum net capital required: | | 276 | | Minimum dollar required: | | \$
5,000 | | | | | | Excess net capital | | \$
13,710 | | Net capital less greater of I 0% of aggregate indebtedness | | | | or 120% of minimum dollar amount | | \$
4,314 | | | | | | Ratio: Aggregate indebtedness to net capital | | .22 to 1 | {16}------------------------------------------------ # **Schedule** I # **Mentor Securities, LLC** # **Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission As of December 31, 2020** | Net capital, as reported in Company's Part IIA (unaudited)
FOCUS report | \$
18,710 | |----------------------------------------------------------------------------|--------------| | Adjustments:
Net capital per above | \$
18,710 | | | | {17}------------------------------------------------ # **MENTOR SECURITIES, LLC December 31, 2020** # **Schedule II Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission** The Company does not claim an exemption under paragraph (k) of 17 C.F.R. 240. 15c3-3. The Company is a Non-Covered firm that relies on Footnote 74 of the SEC Release No. 34-70073 # **Schedule III Information Relating to Possession or Control Requirements Under Rule 15c3-3** The Company does not claim an exemption under paragraph (k) of 17 C.F.R. 240. 15c3-3. The Company is a Non-Covered firm that relies on Footnote 74 of the SEC Release No. 34-70073 *The accompanying notes are an integral part of these financial statements* 13 {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) #### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Board of Directors and Shareholders Mentor Securities, LLC We have reviewed management's statements, included in the accompanying Exemption Report, in which (I) Mentor Securities, LLC. indicated that Mentor Securities, LLC. may file an Exemption Report because it had no obligations under 17 C.F .R. §240. I 5c3-3, as its business activities are exclusively to private placements of securities and business advisory services relating to corporate finance transactions. The Company (I) 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; (2) did not carry accounts ofor for customers; and (3) did not can-y PAB accounts (as defined in Rule l 5c3-3) and (2) Mentor Securities, LLC stated that Mentor Securities, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. Mentor 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 Mentor 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 17 C.F.R. §240. l 5c3-3 under the Securities Exchange Act of 1934. LMH, P.C. Norwell, Massachusetts February 15, 2021 ![](_page_18_Picture_8.jpeg) {19}------------------------------------------------ ![](_page_19_Picture_0.jpeg) Mentor Securities LLC 200 N. Westlake Blvd., Suite 204 Westl ake Village CA 9 1362, USA 8 18.99 1.4 150 I Fax : 8 18.99 1.4904 www. rn entorsecurities.com Member FINRAJS/PC ### **Mentor Securities, LLC Exemption Report December 31, 2020** Mentor Securities, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240. **l** 7a-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: (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34- 70073 adopting amendments to 17 C.F.R. § 240. **l** 7a-5 because the Company limits its business activities exclusively to private placements of securities and business advisory services relating to corporate finance transactions. The Company (1) 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; (2) did not carry accounts ofor for customers; and (3) did not cany PAB accounts (as defined in Rule **l** 5c3-3) throughout the most recent fiscal year without exception. Mentor Securities, LLC I, Davis Blaine, swear (or affirm) that, to my best knowledge and belief, this Exemption Repo11 is true and CotTect. By: {5JF(UJM ~ Davis R. Blaine Chairman Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.