# RICHMAN GROUP SECURITIES, INC X-17A-5 (2019-02-28) — Broker-dealer annual report - Company: RICHMAN GROUP SECURITIES, INC - Form: X-17A-5 - Filed: 2019-02-28 - Period: 2018-12-31 - Accession: 0001494659-19-000001 - CIK: 1494659 - File #: 8-68632 - Material weakness: No - Auditor: McBee & Co. PC - Auditor location: Dallas, TX - Contact: Rhenee Roge - Phone: 2145363676 - Signed by: Keith H. Adams (President) Original filing: https://www.sec.gov/Archives/edgar/data/1494659/000149465919000001/2018rgsiauditreport2.pdf --- {0}------------------------------------------------ UNITEDSTATES SECURITIESANDEXCHANGECOMMISSlON Wasblni,on, D.C. 20549 0MB APPROVAL 0MB Number. 3235-0Ji3 upires: August 31, 2020 Estimated av.,,.ge burden hours oer resoonse .. ... . 12.00 # **ANNUAL AUDITED REPORT FORM X-17A-S PARTIII** | SEC ALE NUMBER | |----------------| | a.68632 | **FACING** PAGE **Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities E1:change Act of 1934 and Rule 17a-5 Thereunder** | REPORT FOR THE PERIOD BEGINN1NG _ | 18.::._
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AND ENDING_c1c.=2.:/3=-1::./: | 18:: _ | _ | |--------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------|-------------------------------------|----------------------------------|---| | | MM/DDIYY | | MM/DDIYY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: | Richman Group Securities, Inc. | | OFFICIAL USE ONLY | | | ADDRESS OF PRINCIPAL PL.ACE OF BUSINESS: (Do no1 use P.O. Box No.)
19621 FM 1431, Suite 404 | | | FIRM 1.0. NO. | | | | (No. und Street) | | | | | Jonestown | Texas | | 78645 | | | (City) | (Sate) | | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Keith H. Adams | | | (512) 249-9252 | | | | | | | | | | B. ACCOUNTANT IDENTIFICATION | | (Arco. Code - Telephone Num.ber) | | | McBee & Co., PC | | | | | | 718 Paulus Ave. | (Name - If rnd;,.,;J,wl, stale last, /int, mtddlt nam•) | | | | | (Address) | Dallas
(City) | TX
(Sate) | 75214
(Zip Code) | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report•
CHECK ONE:
Certified Public Accountant
Public Accountant | | | | | | B
Accountant not resident in United States or any of its possessions. | | | | | *"Claims for exemption from the requirement that the annual r~port be covered by the opinion of an independent public accountafll must* l>e *supported by a statem4nt of facts and circumstances relied on as the basis for the exemption. See Section U0.17a-S(e)(2)* > **PotentJol peraona who •ro to roepond to the collectlon of Information contained In thla form are not required to respond unleu the form dlaplaya a currently val Id OM8 control number.** SEC 1410 (Ol>02) {1}------------------------------------------------ #### **OATH OR AFFIRMATlO'.'i** | [1,e-~.,vt.v,
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neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account
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(t) Statement of Changes in Liabilities Subordinated to Claims of Creditors .
(h) Computation for Determination of Reserve Requirements Pursuant to Rule I Sc3-3 .
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Computation for Determination of the Reserve Requirements Under Exhibit A of Rule l5c3-3.
0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of
consolidation. | my knowle4ge and belief the accompanying financial statemem and supporting schedules pertaining to the firm of
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classified solely as that of a customer, except as follows:
This repon " contains (check all applicable boxes):
0 (a) Facing Page .
., (b} Statement of Financial Condition .
., (c) Statement of Income (Loss) .
., (d) Statement of Changes in Financial Condition .
., (c) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' capital.
., (g) Computation of Net Capital.
., (i) Information Relating to the Possession or Control Re~uirements Under Rule l 5c3-3.
0 (j) A Reconciliation, including appropriate explanation of the Compulalion of Ket Capital Under Ruic I Sc3 | • swear (or affirm) that, to the bes1 of | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 0 (n) A report describing any material inadequacies fo¥nd to exist or found to havccxistcdsince the date of the previous audit. | 0 (I) An Oath or Affirmation.
0 (m) A copy of the SIPC Supplemental Report. | | {2}------------------------------------------------ #### **TABLE OF CONTE:NTS** #### **DECEMBER 31, 2018** | | PAGE | |-------------------------------------------------------------------------------------------------------------|------| | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 1 | | FlNAi'ICIAL STATEMENTS | | | ST/\ TEl\ffiNT OF FINANCIAL CONDITION | 2 | | STATEMENT OF OPERATIONS | 3 | | STATEMENT OF CHANGES lN STOCKHOLDER'S EQUITY | 4 | | STATEMENT OF CASH FLOWS | 5 | | NOTES TO HNANCI/\L STATEMENTS | 6-9 | | SUPPORTING SCHEDULES: | | | SCHEDULE I: COMPUTATION OF NET CAPITAL UNDER RULE 15c3-
1
OF THE SECURITIES Al"ID EXCHANGE COMMISSION | 10 | | SCHEDULE II: COMPUT /\ TION FOR DETERMINATION OF RESERVE
REQUIREMENTS UNDER RULE 15c3-3 OF TI-IE | | | SECURITIES ANTI EXCHANGE COMMISSION | 11 | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
ON MANAGEMENT'S EXEMPTION REPORT | 12 | | | | | BROKRR-DEALER ANNUAL EXEMPTION REPORT | 13 | {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) **A PmfK..~bn..,I C.Orpn-~t'lor CcrtifiCI.: Public** Account:.nt..\_ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM #### To the President and Board of Directors of Richman Group Securities, Inc. #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Richman Group Securities, Inc. as of December 31, 2018, the related statements of operations, changes in stockholder's equity, and cash flows for the year t hen ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fa irly, in all material respects, the financial position of Richman Group Securities, Inc. as of December 31, 2018, 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 Richman Group Securities, lnc.'s management. Our responsibility is to express an opinion on Richman Group Securities, lnc.'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 the Richman Group Securities, Inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the fi nancial 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 prlnclples 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. #### Supplemental Information The supplemental information contained In Schedule I, Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission and Schedule II, Computation for Determination of Reserve Requirements Under Rule 1Sc3-3 of the Securities and Exchange Commissiori. has been subjected to audit procedures performed in conjunction with the audit of Richman Group Securities, lnc.'s financial statements. The sui:,plemental information is the responsibility of Richman Group Securities, lnc.'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, Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission, and Schedule II, Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission is fairly stated, in all material respects, in relation to the financial statements as a whole. ~~/ McBee & Co, PC We have served as Richman Group Securities, lnc.'s auditor since 2013. Dallas, Texas February 25, 2019 **7 18 Paulw;** Av lm~ **• 0311.l:., T4..•x;,1.s75214 • (ph) 21-l.823..3500 • www.mcbceco.co m L>allas I Keller/Southlake** {4}------------------------------------------------ # **RICHMAN GROUP SECURITIES, INC. STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31 , 2018** ### **ASSETS** | Cash | \$
9,414 | |-------------------------------------|--------------| | Centralized Registration Depository | 859 | | TOT AL ASSETS | \$
10,273 | ## **LIABILITIES AND STOCKHOLDER'S EQUITY** ### **Stockholder's Equity** | Common Stock, 100,000 Shares Authorized, No Par Value, | | |--------------------------------------------------------|--------------| | I ,000 Shares Issued and Outstanding, \$1 Stated Value | 1,000 | | Additional paid-in capital | 427,963 | | Accumulated Deficit | (418,690) | | Total Stockholder's Equity | 10,273 | | TOTAL LIABILITIES AND STOCKHOLDER'S EQUITY | \$
10,273 | {5}------------------------------------------------ # **RICHMAN GROUP SECURITIES, INC. STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 2018** ## **EXPENSES** | Regulatory | \$
12,063 | |--------------------------------------------|----------------| | Occupancy, Operating and Overhead (Note 8) | 27,384 | | TOT AL EXPENSES | \$
39,447 | | NETLOSS | \$
(39,447) | See Notes to Financial Statements {6}------------------------------------------------ #### **STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY** #### **FOR THE YEAR ENDED OF.C£MUER31, 2018** | | | Common
Stoek | | Additional
Paid-in-Capital | | Accumulated
Deficit | | Total | |-----------------------------------------------------------------------------------|----|-----------------|----|-------------------------------|----|------------------------|---------|--------------| | Balance, l'>ecembtr 31, 2017 | s | 1,000 | \$ | 385,762 | s | (379,243) | s | 7,5 19 | | Cash capital contributions | | | | 5,000 | | | | 5,000 | | Non-cash capital contributions of
occupancy, o~rating and overhead
expenses | | | | 37,201 | | | | 37,201 | | Net Loss | | | | | | (39,447) | \$ | (39,447) | | Balan«, December 31, 2018 | \$ | 1.000 | s | 427,963 | \$ | (418.690) | ~\$ ___ | _ 1_0_.2_13_ | See Notes to FinMcial Statements 4 {7}------------------------------------------------ # **RICHMAN GROUP SECURITIES, INC. STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2018** ## **CASH FLOWS FROM OPERATING ACTIVITIES:** | Net Loss | \$
(39,447) | |------------------------------------------------------------------------------------|----------------| | Adjustments to Reconcile Net Loss to Net Cash
Provided by Operating Activities: | | | Non-cash capital contributions of occupancy,
operating and overhead expenses | 37,201 | | Change in operating assets and liabilities: | | | Decrease in accrued liabilities | \$
(3,500) | | Net Cash Used in Operating Activities | (5,746) | | CASH FLOWS FROM INVESTING ACTIVITIES: | | | Cash contributions | 5,000 | | Net Cash Provided by Investing Activities | 5,000 | | NET DECREASE IN CASH AND CASH EQUIVALENTS | (746) | | Beginning of Year | 11,019 | | End of Year | \$
10,273 | | SUPPLEMENTAL CASH FLOW INFORMATION | | | Non-cash Activity: | | | Payables converted to contributions | \$
37,201 | See Notes to Financial Statement~ 5 {8}------------------------------------------------ 19621 FM 1431 / Suite404 / Jonestown I Texas / 78645 I (512)249-'1252 *I* fax(512)249-9253 ## **RICHMAN GROUP SECURITIES, INC.** #### **NOTES TO FINANCIAL STATEMENTS** #### **1. ORGANIZATION AND NATURE OF BUSINESS** Richman Group Securities, Inc. (the "Company"), was incorporated in Texas, in 2011. The Company is a non-public broker-dealer registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA). The Company is also a member of the Securities Investor Protection Corporation ("SIPC"). As a direct participation broker-dealer selling joint ventures in oil and gas and private placement of securities, the Company does not hold customer funds or securities. In May 2018, pursuant to the State of Texas law, the sole Owner and sole Director of Richman Group Securities, Inc. agreed to the transfer of 100% of the shares and ownership of the Company to an independent third-party upon the FINRA approval of the third-party's Continuation of Membership Application **("CMA").** In August 2018, pursuant to the State of Texas law, the sole Director of Richman Group Securities, Inc. agreed to a permanent capital contribution in the amount of \$5,000.00 from the independent third-party for the CMA change of ownership application fee. #### **2. SIGNIFICANT ACCOUNTING POLICIES** #### **Basis of Presentation** The Company is engaged in the business of selling interests in oil & gas joint ventures organized by Pool Energy Corporation, a Texas corporation dba Richman Oil, the managing venture, for drilling oil and gas wells in the U.S and private placements of securities. #### **Use of Estimates** The preparation of financial statements in conformity with United States generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of the assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. #### **Revenue Recognition** #### **Investment Fees** The Company derives its revenue primarily by providing investment opportunities In oil and gas joint ventures to its clients. Revenue is recognized upon the closing of a transaction, more specifically at the point in time that the Company determines the customer obtains control over the promised good or service. It is **at** this time, the Company satisfies its performance obligations by transferring promised goods or services to customers. The amount of revenue recognized reflects the consideration to which the {9}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** Company expects to be entitled in exchange for those promised goods or services, as defined in each contract. #### ASU 2014-09 • ASC Topic 606, Revenue from Contracts with Customers On Jpnuary 1, 2018, the Company adopted ASC Topic 606, Revenue from Contracts with Customers ("Topic 606") using the modified retrospect ive method applied to those contracts which were not completed as of January 1, 2018. Results for reporting periods beginning after January 1, 2018 are presented under Topic 606, while prior period amounts are not adjusted and continue to be reported in accordance with our historic accounting under Topic 605. There was no impact to retained earnings as of January 1, 2018, as no revenue was recognized for the year ended December 31, 2018, after adopting Topic 606, as revenue recognition and timing of revenue did not change as a result of implementing Topic 606. #### Fair Value of Financial Instruments Cash, any prepaid expenses and registration deposits are short-term in nature and accordingly are reported in the statement of financial condition at fair value or carrying amounts that approximate fair value. #### Cash, Cash Equivalents and Restricted cash Cash consists of deposits with banks and all highly liquid investments, with maturities of three months or less, that are not segregated and deposited for regulatory purposes. Centralized Registration Deposit (CRD) funds and/or Flex-Funding Account Funds are reflected as cash equivalents in the accompanying statement of financial condition and for purposes of the statement of cash flows. #### Income Tax The Company has elected to be taxed as an \$-Corporation and is therefore treated as a flow-through entity for income tax purposes, similar to a partnership. As a result, the net taxable income of the Company and any related tax credits, for federal income tax purposes, are deemed to pass to the individual member and are included in the member's personal tax return even though such net taxable income or tax credits may not actually have been distributed. Accordingly, no tax provision has been made in the financial statements since the income tax is a personal obligation of the individual member. The Company is subject to state income tax. The Company recognizes and measures any unrecognized tax benefits in accordance with Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) 740, "Income Taxes". Under that guidance the Company assesses the likelihood, based on their technical merit, that tax positions will be sustained upon examination based on the facts, circumstances and information available at the end of each period. The measurement of unrecognized tax benefits is adjusted when new information is available, or when an event occurs that requires a change. As of December 31, 2018, the Company {10}------------------------------------------------ #### **NOTES** TO **FINANCIAL STATEMENTS** believes there are no uncertain tax positions that qualify for either recognition or disclosure in the financial statements. #### **3. NET CAPITAL REQUIREMENTS** The Company is subject to the SEC uniform net capital rule (Rule 1Sc3•1), which requires the maintenance of a minimum amount of net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1 (and the rule of the "applicable" exchange also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1). At December 31, 2018, the Company had net capital of \$9,414, which was \$4,414 In excess of its required net capital of \$5,000. The Company's net capital ratio was 00.0 to 1 for December 31, 2018. #### **4. LIABILITIES SUBORDINATED** TO **CLAIMS OF GENERAL CREDITORS** During the year ended December 31, 2018, there were no subordinated liabilities to the claims of general creditors. Accordingly, a statement of changes in liabilities subordinated to claims of general creditors has not been included in these financial statements. #### **S. SIPC SUPPLEMENTAL REPORTING** The Company is exempt from the filing of the SIPC Supplemental Report as net operating revenues are less than \$500,000. #### **6. CONCENTRATION OF CREDIT RISK** The Company's financial instruments that are subject to concentrations of credit risk primarily consist of cash. The Company places its cash with a high credit quality institution. At times, such cash may be in excess of the FDIC insurance limits. The Company believes that **it** is not exposed to any significant risk related to cash. #### **7. CONTINGENCIES** In t he ordinary course of conducting its business, the Company may be subjected to loss contingencies arising from lawsuits. Management believes that the outcome of such matters, if any, will not have a material impact on the Company's financial condition or resu Its of future operations. #### **8. RELATED PARTY TRANSACTIONS** The Company has an agreement with the Sole Shareholder whereby the Sole Shareholder, from time to time, provides goods and services to the Company as deemed necessary including, but not necessarily limited to, administrative services, office space, utilities, communications, state and federal registration requirements and regulatory assessments as set forth in the Expense Allocation Agreement. A record of every Company expense assumed by the sole shareholder will be entered on the Company's financial books and records and will be recorded as a permanent capital contribution. Repayment of these provisions is not required. If any amounts are due the sole shareholder, he will invoice the Company. These invoices will be recorded immediately on the Company's financial books and records and promptly paid. For the year ended December 31, 2018, the Company {11}------------------------------------------------ ### **NOTES TO FINANCIAL STATEMENTS** paid no expense allocation fees to the Sole Shareholder. The existence of this association creates operating results and a financial position significantly different than if the companies were autonomous. ### 9. COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS AND INFORMATION RELATING TO POSSESSION OR CONTROL REQUIREMENTS PURSUANT TO RULE 15c3-3 #### **EXEMPTION FROM RULE 1Sc3-3** The Company operates under the provisions of Paragraph (k)(2)(i) of Rule 1Sc3-3 of the SEC and, accordingly, is exempt from the remaining provisions of that Rule. Essentially, the requirements of Paragraph (k)(2)(i) provide that the Company will not hold customer funds or safe keep customer securities. Under these exemptive provisions, the Computation for Determination of Reserve Requirements and the disclosure of Information Relating to Possession or Control Requirements are not required. During the year ended December 31, 2018 and for the period from January 1, 2018 to February 22, 2019, in the opinion of management, the Company has maintained compliance with the conditions for the exemption specified in paragraph(k)(2)(i) of Rule 1Sc3-3. #### **10. RECENTLY ISSUED ACCOUNTING PRONOUNCEMENTS** Recently issued accounting standards that have been Issued or proposed by the FASB or other standards-setting bodies are not expected to have a material impact on the Company's financial position or results of operations. #### **11. SUBSEQUENT EVENTS** The Company has performed an evaluation of events that have occurred subsequent to December 31, 2018, and through February 25, 2019, the date of the filing of this report. As described in Note 1, the transfer of 100% of the shares and ownership of the Company to an independent third-party upon the FINRA is still pending the approval of the thirdparty's continuing membership application. The Company expects this approval and transition to occur in 2019. This has no effect on the financials of the firm and capital contributions will be provided as necessary to maintain capital compliance. {12}------------------------------------------------ ## **SCHEDULE!** ## **RICHMAN GROUP SECURITIES, INC.** # **COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2018** ### **COMPUTATION OF NET CAPITAL** | Total Stockholder's Equity Qualified for Net Capital | \$
I 0,273 | |----------------------------------------------------------------------------------------|---------------| | Deductions and/or Charges: | | | Other Assels | (859) | | Net Capital before Haircuts on Securities Positions | 9,414 | | Haircuts on Securities (computed, where applicable,
pursuant to Rule I Sc--3-1 (t)) | | | Net Capital | \$
9,414 | | AGGREGATE INDEBTEDNESS | \$ | | COMPUTATION OF BASIC NET CAPITAL REQUIREMENT | | | Minimum Net Capital Required
(6 2/3% of total aggregate indebtedness) | | | Minimum Dollar Net Capital Requirement of Reporting Broker or Dealer | \$
5,000 | | Minimum Net Capital Requirement | \$
5,000 | | Net Capital in Excess of Minimum Required | \$
4,414 | | Net Capital in Excess of Minimum Required at 1000% | \$
3,414 | | RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL | 0.0 TO I | | | | **RECONCILIATION WITH COMPANY'S COMPUTATION** No material differences existed between the audited computation of net capital pursuant to Rule 15c3-1 as of December 31, 2018 and the corresponding unaudited tiling of part 11A of the FOCUS Report/form X-17 A-5 filed by Richman Group Securities, Inc. {13}------------------------------------------------ ## **SCHEDULE II** ## **RICHMAN GROUP SECURITIES, INC.** # **COMPUTATION FOR DETERMINA Tl ON OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COM.MISSION AS OF DECEMBER 31, 2018** ## **EXEMPTIVE PROVISIONS** The Company operates under the provisions of Paragraph (k)(2)(i) of Rule I Sc3-3 of the SEC and, accordingly, is exempt from the remaining provisions of that Rule. Essentially, the requirements of Paragraph (k)(2)(i) provide that the Company will not hold customer funds or safe keep customer securities. Under these exemptive provisions, the Computation for Deten11ination of Reserve Requirements is not required. {14}------------------------------------------------ ![](_page_14_Picture_0.jpeg) A P'mfK~Xm.11 Co1"JX'11'7Slio:- Cc."t.il'iC\: Public At-'toun~nt:<. #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM #### To the President and **Board** of Directors of Richman Group Securities, Inc. We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Richman Group Securities, Inc. identified the following provisions of 17 C.F.R. §1Sc3-3{k) under which Richman Group Securities, Inc. claimed an exemption from 17 C.f .R. §240.15c3-3: {2)(i) {the "exemption provisions") and (2) Richman Group Securities, Inc. stated that Richman Group Securities, Inc. met the identified exemption provisions throughout the most recent fiscal year, December 31, 2018, without exception. Richman Group Securities, lnc.'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 Richman Group Securities, lnc.'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)(i) of Ruic 1Sc3•3 under the Securities Exchange Act of 1934. **McBee** & Co, l'C Dallas, Texas February 25, 2019 71~ PiH1h.1s Av,:nuc • Dallas, T(.•:,ms75214 • (ph) 214.823.3500 • www.mcbeeco.com O~Uas I Keller/Southlake {15}------------------------------------------------ 19621 FM 1431 I Suite404 I Jonestown / Texas I 78645 I (512)249-9252 I Fa.x(512)249-9253 ## **Richman Group Securities, Inc. 's Exemption Report** Riclunan Group Securities, Inc. (the "Company") is a registered broker-dealer su~jcct to Rule I 7a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240. I 7a-5, "Repons to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.l 7a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: - I. Richman Group Securities, Inc. claimed an exemption from 17 C.F.R. § 240.15c3-3 under the following provisions of 17 C.F.R. § 240. I Sc3-3 (k)(2)(i) for the fiscal year ended December 3 1, 2018. - 2. Richman Group Securities, Inc. met the identified exemption provisions .in 17 C.F.R. § 240. 15c3-3(k)(2)(i) throughout the most recent fiscal year of January I, 2018 to Oeet!mber 31, 2018, without exception. Richman Group Securities. Inc. 1, Keith H. Adams, affirm that, to my best knowledge and belie±: this Exemption Report is true and correct. Signature President Title January 2 1, 2019 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.