# GTS SECURITIES LLC X-17A-5 (2025-03-03) — Broker-dealer annual report

- Company: GTS SECURITIES LLC
- Form: X-17A-5
- Filed: 2025-03-03
- Period: 2024-12-31
- Accession: 0001452765-25-000005
- CIK: 1452765
- File #: 8-68126
- Type: Broker-dealer
- Material weakness: No
- Auditor: Crowe LLP
- Auditor location: New York, NY
- Contact: Christian Tiriolo
- Phone: 212-715-5910
- Email: ctiriolo@gtsx.com
- Website: gtsx.com
- Signed by: Christian Tiriolo (Chief Financial Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1452765/000145276525000005/GTSS24Public.pdf

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PUBLIC

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12

SEC FILE NUMBER

8-68126

# ANNUAL REPORTS FORM X-17A-5 PART III

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 January 1, 2024 AND ENDING December 31, 2024                                                                                                                                                                                      |                                |                 |                                            |  |  |
|                                                                                                                                                                                                                                                                   | MM/DD/YY                       |                 | MM/DD/YY                                   |  |  |
|                                                                                                                                                                                                                                                                   | A. REGISTRANT IDENTIFICATION   |                 |                                            |  |  |
| NAME OF FIRM: GTS Securities, LLC                                                                                                                                                                                                                                 |                                |                 |                                            |  |  |
| TYPE OF REGISTRANT (check all applicable boxes):<br>Broker-dealer<br>Check here if respondent is also an OTC derivatives dealer                                                                                                                                   | L   Security-based swap dealer |                 |                                            |  |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                                                                                                                                               |                                |                 |                                            |  |  |
| 545 Madison Avenue, 15th Floor                                                                                                                                                                                                                                    |                                |                 |                                            |  |  |
|                                                                                                                                                                                                                                                                   | (No. and Street)               |                 |                                            |  |  |
| New York                                                                                                                                                                                                                                                          | NY                             |                 | 10022                                      |  |  |
| (City)                                                                                                                                                                                                                                                            | (State)                        |                 | (Zip Code)                                 |  |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                                                                                                                      |                                |                 |                                            |  |  |
| Christian Tiriolo                                                                                                                                                                                                                                                 | 212-715-5910                   |                 | ctiriolo@gtsx.com                          |  |  |
| (Name)                                                                                                                                                                                                                                                            | (Area Code - Telephone Number) | (Email Address) |                                            |  |  |
| B. ACCOUNTANT IDENTIFICATION                                                                                                                                                                                                                                      |                                |                 |                                            |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>Crowe LLP                                                                                                                                                                            |                                |                 |                                            |  |  |
| (Name - if individual, state last, first, and middle name)                                                                                                                                                                                                        |                                |                 |                                            |  |  |
| 485 Lexington Avenue, Floor 11                                                                                                                                                                                                                                    | New York                       | NY              | 10017                                      |  |  |
| (Address)                                                                                                                                                                                                                                                         | (City)                         | (State)         | (Zip Code)                                 |  |  |
| September 24, 2003                                                                                                                                                                                                                                                |                                | 173             |                                            |  |  |
| (Date of Registration with PCAOB)(if applicable)                                                                                                                                                                                                                  |                                |                 | (PCAOB Registration Number, if applicable) |  |  |
|                                                                                                                                                                                                                                                                   | FOR OFFICIAL USE ONLY          |                 |                                            |  |  |
| * Claims for exemption from the requirement that the annual reports of an independent public<br>accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17<br>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 unless the form displays a currently valid OMB control number.

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#### OATH OR AFFIRMATION

| Christian Tiriolo                                              |  |  |  | . swear (or affirm) that, to the best of my knowledge and belief, the |       |
|----------------------------------------------------------------|--|--|--|-----------------------------------------------------------------------|-------|
| financial report pertaining to the firm of GTS Securities, LLC |  |  |  |                                                                       | as of |
| 1 Ph 10 1                                                      |  |  |  |                                                                       |       |

12/31 , 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.

Notary Public

Signature: Title: COMMISSION Chief Financial Officer ES 6-19-202

This filing\*\* contains (check all applicable boxes):4

- (a) Statement of financial condition.
- (b) Notes to consolidated statement of financial condition.
- □ (c) Statement of income (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).
- [ (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.
- [ (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 capital or tangible 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 subsidiaries not consolidated 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.
- □ (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 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 fling, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18c-7(d)(2), as applicable.

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# GTS SECURITIES, LLC

## STATEMENT OF FINANCIAL CONDITION

DECEMBER 31, 2024

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![](_page_3_Picture_0.jpeg)

## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Manager and Member of GTS Securities, LLC New York, New York

#### Opinion on the Financial Statement

We have audited the accompanying statement of financial condition of GTS Securities, LLC (the "Company") as of December 31, 2024, and the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2024, in conformity with accounting principles generally accepted in the United States of America.

#### Basis for Opinion

This financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statement 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 the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our 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 statement is 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 statement, 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 statement. 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 statement. We believe that our audit provides a reasonable basis for our opinion.

Crowe LLP

We have served as GTS Securities, LLC's auditor since 2015.

New York, New York March 3, 2025

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## GTS SECURITIES, LLC STATEMENT OF FINANCIAL CONDITION December 31, 2024

| ASSETS                                           |                     |
|--------------------------------------------------|---------------------|
| Cash                                             | \$<br>34,009,490    |
| Securities owned, at fair value                  | 2,591,782,640       |
| Receivable from brokers                          | 18,755,737          |
| Memberships in exchanges owned, at adjusted cost | 1,312,300           |
| Goodwill                                         | 5,699,116           |
| Related party receivables                        | 7,023,017           |
| Other assets                                     | 13,870,021          |
| TOTAL ASSETS                                     | \$<br>2,672,452,321 |
|                                                  |                     |
|                                                  |                     |
| LIABILITIES AND MEMBER'S EQUITY                  |                     |

| LIABILITIES                                           |                     |
|-------------------------------------------------------|---------------------|
| Accrued expenses and other liabilities                | \$<br>25,489,868    |
| Payable to brokers                                    | 563,980,138         |
| Securities sold, but not yet purchased, at fair value | 1,771,695,573       |
| Accrued compensation                                  | 22,526,490          |
| TOTAL LIABILITIES                                     | 2,383,692,069       |
| MEMBER'S EQUITY                                       | 288,760,252         |
| TOTAL LIABILITIES AND MEMBER'S EQUITY                 | \$<br>2,672,452,321 |

The accompanying notes are an integral part of this financial statement.

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## **NOTE 1 – ORGANIZATION AND NATURE OF BUSINESS**

GTS Securities, LLC (the "Company") was organized in the state of Delaware as a limited liability company and is wholly owned by GTS Financial LLC (the "Parent"). As a registered broker-dealer with the Securities and Exchange Commission ("SEC"), the Company is a member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), CME Group (which includes memberships on the CME, IOM, IMM, GEM, and CBOT Exchanges) and various US securities exchanges. The Company currently operates on a fully disclosed basis through its brokers which include Goldman Sachs and Co., Marex Capital Markets Inc., BNP Paribas, and CF Secured, LLC (collectively, including the ones not named, the "Clearing Brokers"). The Clearing Brokers, operating pursuant to their respective clearing agreements, handle the clearing and settlement aspects of the Company's trading operations.

The Company does not carry customer accounts. The Company is a market-maker in listed equities and options on multiple US securities exchanges, a designated market marker ("DMM") on the NYSE in symbols assigned to the Company and a proprietary trading company.

In the normal course of its business, the Company enters into financial transactions where the risk of potential loss due to changes in market (market risk) or failure of the other party to the transaction to perform (credit risk) exceeds the amounts recorded for the transaction.

The Company's policy is to continuously monitor its exposure to market and counter-party risk through the use of a variety of automated systems and control procedures.

## **NOTE 2 – SIGNIFICANT ACCOUNTING POLICIES**

### *Use of Estimates*

The Company maintains its books and records on an accrual basis in accordance with accounting principles generally accepted in the United States of America ("GAAP"), which requires management to make estimates and assumptions in determining the reported amounts of assets and liabilities at the date of the financial statements. Actual results could differ from these estimates. It is reasonably possible that our estimate of liabilities from contingencies could change. The resulting change in these estimates could be material to the financial statements.

### *Cash*

The Company maintains its cash in financial institutions which, at times, may exceed federally insured limits. The Company has not experienced any losses in such accounts and believes it is not subject to any significant credit risk on its cash.

## *Fair Value*

FASB ASC 820 defines fair value, establishes a framework for measuring fair value, and establishes a hierarchy of fair value inputs. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transaction to sell the asset or transfer the liability occurs in the principal market for the asset or liability or, in the absence of a principal market, the most advantageous market. Valuation techniques that are consistent with the market, income or cost approach, as specified by FASB ASC 820, are used to measure fair value.

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## **NOTE 2 – SIGNIFICANT ACCOUNTING POLICIES** (Continued)

The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value in three broad levels:

- *Level 1*  Quoted prices (unadjusted) in active markets for identical assets or liabilities that the Company can access at the measurement date.
- *Level 2*  Inputs other than quoted prices included within Level 1 that are observable for the asset or liability either directly or indirectly.
- *Level 3*  Unobservable inputs for the asset or liability.

The availability of observable inputs can vary from security to security and is affected by a wide variety of factors, including, for example, the type of security, the liquidity of markets, and other characteristics particular to the security. To the extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgment. Accordingly, the degree of judgment exercised in determining fair value is greatest for instruments categorized in Level 3.

The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety is determined based on the lowest level input that is significant to the fair value measurement in its entirety.

Fair value is a market-based measure considered from the perspective of a market participant rather than an entity-specific measure. Therefore, even when market assumptions are not readily available, the Company's own assumptions are set to reflect those that the Company believes market participants would use in pricing the asset or liability at the measurement date.

*Exchange-Traded Equity Securities and Corporate Bonds* – Exchange-traded equity securities and corporate bonds are generally valued based on quoted prices from the exchange. Certain exchange traded funds are valued based on the intrinsic value of the securities that make up the fund rather than the value of the fund itself. To the extent these securities are actively traded, valuation adjustments are not applied, and they are categorized in Level 1 of the fair value hierarchy; otherwise, they are categorized in Level 2 or Level 3 of the fair value hierarchy.

#### *Trading Activity*

Purchases and sales of securities are recorded on a trade-date basis.

#### *Exchange Memberships*

The Company's exchange memberships, which represent ownership interests in the CME Group exchanges listed in Note 1 above and provide the Company with the right to conduct business on the exchanges, are recorded at cost or, if an other than temporary impairment in value has occurred, at a value that reflects management's estimate of the impairment. At December 31, 2024, the fair value of exchange memberships was \$1,312,900.

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## **NOTE 2 – SIGNIFICANT ACCOUNTING POLICIES** (Continued)

#### *Current Expected Credit Losses*

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

The Company's receivables from brokers include amounts receivable from unsettled trades and cash deposits. The Company's trades and contracts are cleared through the Clearing Brokers and settled daily between the Clearing Brokers and the Company. Because of this daily settlement, the amount of unsettled credit exposures is limited to the amount owed to the Company for a very short period of time.

The Company's related party receivables are from related parties as described in Note 6. The Company has full knowledge of the related parties and has determined the likelihood of nonpayment is minimal. As such, the Company has no expected credit loss related to the related party receivables.

#### *Goodwill and Intangible Assets*

Intangible assets are recorded as part of acquisitions the Company made. Intangible assets are amortized over their estimated useful lives and are reviewed for impairment on an annual basis when impairment indicators are present. The estimated useful lives of intangible assets are five to six years and are amortized using the straight-line method. At December 31, 2024, intangible assets had been fully amortized from a gross value of \$7,588,666.

The Company carries goodwill based on its value at acquisition. The Company's annual goodwill asset impairment testing as of December 31, 2024 did not indicate any impairment.

#### *Contingent Liabilities*

The Company evaluates annually the fair value of any contingent liability and adjusts as needed. Refer to Note 9 for information relating to contingent liabilities.

#### *New Accounting Pronouncement*

In July 2023, the FASB issued ASU 2023-07, Segment Reporting (Topic 280): Improvements to Reportable Segment Disclosures, which requires all public entities, including those with a single reportable segment, to disclose additional information about a reportable segment's expenses in interim and annual periods, among other requirements. The new guidance does not change how a public entity identifies its operating segments, aggregates those operating segments, or applies the quantitative thresholds to determine its reportable segments.

The Company adopted Topic 280 in January 2024 as required for public entities, including non-public registered broker-dealers for fiscal years beginning after December 15, 2023. The adoption of FASB ASU 2023-07 did not have a material impact on the Company's financial statements or schedules.

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## **NOTE 2 – SIGNIFICANT ACCOUNTING POLICIES** (Continued)

The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services, including market making and proprietary trading. The Company has identified its CEO and COO as the chief operating decision makers ("CODM"), who chiefly uses net income to evaluate the results of the business and to manage the Company. Additionally, the CODM uses excess net capital (see Note 8), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or make distributions. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies.

## **NOTE 3 – FAIR VALUE MEASUREMENTS**

The Company's assets and liabilities recorded at fair value have been categorized based upon a fair value hierarchy as described in Note 2. The following table presents information about the Company's securities owned, at fair value, and securities sold, but not yet purchased, at fair value as of December 31, 2024:

|                                       | Level 1          | Level 2          | Total            |
|---------------------------------------|------------------|------------------|------------------|
| Assets (at fair value):               |                  |                  |                  |
| Equities                              | \$ 2,429,391,580 | \$<br>-          | \$ 2,429,391,580 |
| Fixed income                          | 83,588,560       | 78,802,500       | 162,391,060      |
| Total assets (at fair value):         | \$ 2,512,980,140 | \$<br>78,802,500 | \$ 2,591,782,640 |
|                                       |                  |                  |                  |
| Liabilities (at fair value): Equities |                  |                  |                  |
| Equities                              | \$ 1,722,828,775 | \$<br>-          | \$ 1,722,828,775 |
| Fixed income                          | 48,866,798       | -                | 48,866,798       |
| Total Liabilities (at fair value):    | \$ 1,771,695,573 | \$<br>-          | \$ 1,771,695,573 |

As part of the Company's acquisition of the trading desks described in Note 9, the Company had a contingent liability, which the Company deemed a Level 3 liability in the fair value hierarchy. As of January 1, 2024, the Company valued this earn-out accrual at approximately \$5,000,000. During the year ended December 31, 2024, this amount was fully paid out and the Company no longer has a contingent liability.

## **NOTE 4 – INCOME TAXES**

For purposes of federal, state and local income taxes, the Company's status as a separate tax entity is disregarded. As such, the operations of the Company are treated as held directly by its sole member, the Parent. Accordingly, the Parent is responsible for reporting the Company's federal, state and local taxable income or loss and has elected not to push down the federal, state and local effects of income taxes to the Company. There are no federal, state and local tax sharing arrangements between the Company and the Parent. Additionally, there are no obligations for the Company to fund the federal, state and local tax liabilities, if any, of the Parent. The Company is included in the consolidated federal, state and local income tax returns filed by the Parent.

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#### **NOTE 5 – RULE 15C3-3**

The Company is exempt from the provisions of Rule 15c3-3 under paragraph (k)(2)(ii) in that the Company carries no customer accounts.

#### **NOTE 6 – RELATED PARTY TRANSACTIONS**

The Company has a service agreement with Strike Technologies LLC, an affiliate under common ownership, for a variety of services used in the Company's operations as prescribed in the agreement. Under this agreement, Strike Technologies LLC, an affiliated company, provides infrastructure technology and software development and support to the Company.

The Company has an expense sharing and reimbursement agreement with GTS Execution Services LLC ("GTEX"), an affiliated broker-dealer under common control. Through this agreement, the two brokerdealers reimburse each other for personnel costs shared between the two broker-dealers and reimburses for other costs shared between the two entities. As of December 31, 2024, approximately \$6,963 remains receivable and is included in related party receivables on the statement of financial condition.

The Company acts as an executing broker for GTEX. As such, GTEX is charged a fee for trades in which the Company acts as the executing broker. As of December 31, 2024, approximately \$68,059 remains receivable and is included in related party receivables on the statement of financial condition. Additionally, the Company pays GTEX for certain trades of shared clients. As of December 31, 2024, the Company had \$3,693 payable and is included as an offset to related party receivables on the statement of financial condition.

The Company also has multiple license agreements with GTS Group US LLC ("GTSG"), an affiliated company and owner of 100% of the Parent. Under these agreements, GTSG provides office space to the Company and for expense reimbursement for trading and related expenses.

In October 2023, the Company entered into a note with GTSG for a principal sum of \$50,000,000 at an interest rate of eight percent (8%) per annum. The remaining principal balance of \$28,750,000 was fully satisfied as of December 31, 2024, including all accrued interest payable.

In May 2021, the Company entered into a revolving credit agreement with LVS Partners Limited, an indirect equity owner of GTSG, for a principal sum of \$50,000,000 at an interest rate of 10%. During the year ended December 31, 2024, the Company repaid the \$10,000 that was still payable as of December 31, 2023 and repaid all interest due.

In July 2022, GTS International Limited, an indirect owner of GTSG, entered into a demand note with the Company for a principal sum of \$80,000,000 at an interest rate of six percent (6%) per annum. The remaining principal balance of \$34,125,000 was fully satisfied as of December 31, 2024. As of December 31, 2024, there is an interest receivable of approximately \$3,473,167 remaining in related party receivables on the statement of financial condition.

In October 2023, the Company issued a demand note for a principal sum of \$50,000,000 to GTS Europe AG, an entity under ultimate ownership of GTS Worldwide at an interest rate of 3.75%. As of December 31, 2024, the remaining principal of \$50,000,000 has been fully satisfied. As of December 31, 2024, there is an interest receivable of \$2,265,411 remaining in related party receivables on the statement of financial condition.

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## **NOTE 7 – RECEIVABLE FROM AND PAYABLE TO BROKERS**

As of December 31, 2024, receivable from and payable to brokers primarily represents amounts due to/from the Company for cash held by the Clearing Brokers, open equity in futures transactions and cash held as collateral for certain transactions. Amounts receivable from the Clearing Brokers may be restricted to the extent that balances were for proceeds for securities sold, but not yet purchased. At December 31, 2024, approximately \$18,755,737 was receivable from the Clearing Brokers was substantially in cash. Total required collateral at the brokers was approximately \$143,562,315, which is met by cash and liquid securities held at brokers. At December 31, 2024, approximately \$563,980,138 was payable to the Clearing Brokers.

## **NOTE 8 – NET CAPITAL REQUIREMENTS**

The Company is subject to the Securities and Exchange Commission's Net Capital Rule 15c3-1, which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31, 2024, the Company had net capital of \$188,617,900, which exceeded the minimum requirement of \$1,209,435 by \$187,408,465. The Company's ratio of aggregate indebtedness to net capital was .10 to 1 as of December 31, 2024.

## **NOTE 9 – COMMITMENTS AND CONTINGENCIES**

In the normal course of its business, the Company indemnifies certain service providers, such as clearing and custody agents, against specified potential losses in connection with providing services to the Company. The maximum potential amount of future payments relating to these that the Company could be required to make under these indemnifications cannot be estimated. However, the Company believes that it is unlikely it will have to make material payments under these arrangements and, as of December 31, 2024, has not recorded any contingent liability in the financial statements for these indemnifications.

In the normal course of business, the Company is subject to regulatory proceedings arising in connection with the conduct of its operations. These matters could result in censures, fines, or other sanctions. As of December 31, 2024, the Company recorded \$500,000 of contingent liability in the financial statements for all open regulatory proceeding.

In connection with a prior acquisition, the Company had a contingent liability based on trading performance. The Company paid the final \$5,000,000 payment during the year ended December 31, 2024. As of December 31, 2024, the Company no longer has a contingent liability relating to the prior acquisition.

### **NOTE 10 – DERIVATIVE CONTRACTS**

In the normal course of business, the Company enters into derivative contracts for trading purposes. Typically, these derivative contracts are traded much like their equities counterpart through the Company's trading strategies and are not utilized to economically match the equities trading objectives of the Company. The Company's derivative trading activities involve the purchase and sale of equity derivative contracts and foreign exchange contracts. The Company records its derivative activities on a mark-to-market basis and changes in market values are reflected in the statement of income.

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## **NOTE 10 – DERIVATIVE CONTRACTS** (Continued)

Generally, these financial instruments represent future commitments to purchase or sell other financial instruments at specific terms and future dates. Each of these contains varying degrees of off-balance sheet risk whereby changes in the market value of the securities underlying the financial instruments or the Company's satisfaction of the obligations may exceed the amount recognized in the statement of financial condition.

Positions in derivatives are carried at fair value and are based on quoted market prices (Level 1). Trading activity gains and losses from derivative contracts are included in net trading income on the statement of income.

As of December 31, 2024, the approximate gross contractual or notional amounts of derivative financial instruments are as follows:

|                                       | Gross notional<br>amount assets |             | Gross notional     |             |  |
|---------------------------------------|---------------------------------|-------------|--------------------|-------------|--|
|                                       |                                 |             | amount liabilities |             |  |
| Foreign exchange derivative contracts | \$                              | 475,610,409 | \$                 | 392,757,206 |  |
| Foreign exchange forwards             |                                 | 15,785,194  |                    | 3,901,679   |  |
| Total                                 | \$                              | 491,395,603 | \$                 | 396,658,885 |  |

The fair value of foreign exchange derivative contracts and foreign exchange forwards are netted each other with the net amount of approximately \$7,128,063 is included in payable to brokers on the statement of financial condition.

## **NOTE 11 – TRANSACTIONS WITH AFFILIATES**

The Parent has a minority interest investment in a third-party broker-dealer (the "Borrower" or "Affiliate"). In May 2019, the Company issued a demand note to the Borrower. The principal of the demand note is \$3,000,000 and has an interest rate of 3% per annum on the unpaid balance. The entire principal and any accrued interest is fully and immediately payable upon demand of the Company. The Company has not requested payment as of December 31, 2024. The principal and accrued interest associated with the demand note are found in other assets on the statement of financial condition. Unrelated and in addition to the demand note with the Affiliate, the Company has a revenue sharing agreement with the Affiliate.

## **NOTE 12 – SUBSEQUENT EVENTS**

There were capital withdrawals totaling \$46,575,000 through March 3, 2025.


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