# BARDI CO. LLC X-17A-5 (2019-01-22) — Broker-dealer annual report

- Company: BARDI CO. LLC
- Form: X-17A-5
- Filed: 2019-01-22
- Period: 2018-12-31
- Accession: 0001561729-19-000001
- CIK: 1561729
- File #: 8-69190
- Material weakness: No
- Auditor: Anson, Brian, W.
- Auditor location: Tarzana, CA
- Contact: Christiano Manfre
- Phone: 3109939960
- Signed by: Christiano Manfre (CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/1561729/000156172919000001/full.pdf

---

{0}------------------------------------------------

**ECURITIE !TEO TATES DEXCHA GECOMMI Washington D.C. 20549**  IO

| 0MB APPROVAL             |                |
|--------------------------|----------------|
| 0MB Number:              | 3235-0123      |
| Expires:                 | March 31, 2018 |
| Estimated average burden |                |
| hours oer resnonse 12.00 |                |

8- 69190

SEC FILE NUMBER

# **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill**

**FACI G PAGE Information Required of Brokers and Dealer Pursuant to ection 17 of the ecurities Exchange Act of 1934 and Rule 17a-5 Thereunder** 

| TIFICATIO                                           | OFFICIAL USE ONLY                                                                                                                                                                                                                                                                                                                                              |  |
|-----------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
| Cf PAL PLACE OF BU !NE S: (Do not u e P.O. Box No.) | FIRM I.D. NO.                                                                                                                                                                                                                                                                                                                                                  |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     | 90071                                                                                                                                                                                                                                                                                                                                                          |  |
|                                                     | (Zip Code)                                                                                                                                                                                                                                                                                                                                                     |  |
|                                                     | 310-993-9960                                                                                                                                                                                                                                                                                                                                                   |  |
|                                                     | (Area Code - Telephone umber)                                                                                                                                                                                                                                                                                                                                  |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
| California                                          | 91356                                                                                                                                                                                                                                                                                                                                                          |  |
|                                                     | (Zip Code}                                                                                                                                                                                                                                                                                                                                                     |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     |                                                                                                                                                                                                                                                                                                                                                                |  |
|                                                     | (No. and Street)<br>California<br>(State}<br>NAME AND TELEPHO E NUMBER OF PERSON TO CO TACT IN REGA RD TO THIS REPORT<br>CCOUNT ANT IDE TIFICATIO<br>TNDEPENDENT PUBLIC ACCOU TA T who e opinion is contained in this Report*<br>(Name - if111div1d11al, s/ale fast.firs/, middle name)<br>Accountant not resident in United States or any of its possessions. |  |

*•Claims for exemption ji-om the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of/acts and circumstances relied on as the basis/or the exemption. See Section 240. ! 7a-5(e)(2)* 

> Potential person s who are to respond to the collection of information contained in this form are not required to respond

{1}------------------------------------------------

a customer, except as follows:

SEC 1410 (06-02) unl e th e form di plays a currently va lid 0MB control number.

#### **OATH OR AFFIRMATION**

| Chri Manfre<br>I,                                                                                  | swear (or affirm) that, to the best ofmy knowledge                                                                                       |
|----------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------|
| and belief the accompanying financial statement and supporting schedules pertaining to the firm of |                                                                                                                                          |
| Ba di Co. LLC                                                                                      | of<br>, a<br>December 3 I                                                                                                                |
| ____<br>___________<br>__<br>_<br>_<br>_ , 2018                                                    | . are true and correct. I further swear (or affirm) that neither the                                                                     |
|                                                                                                    | company nor any partner. proprietor, principal omcer or director has any proprietary inlere tin any account classified solely as that of |

Notary Public

*flh'J-)~G,* u <=, *I)* 1 ,z..=-c r-oq~ -

Title

This repo1i \*\* contain (check all applicable boxes):

- 181 (a) Facing Page.
- 181 (b) Statement ofFinancial Condition.
- 181 (c) tatementoflncome(Los ).
- <sup>181</sup>(d) tatement of Changes in Financial Condition.
- 181 (e) Statement of Change in tockho lders' Equity or Partners' or ole Proprietors' Capital.
- D (t) Statement of Changes in Liabilities ubord inated to Claims of Creditor .
- **<sup>181</sup>**(g) Computation of et Capital.
- 181 (h) Computation for Determination of Re erve Requirements Pursuant to Ru le I 5c3-3.
- 181 (i) Information Relating to the Possession or Control Requirements Under Ru le 15c3-3 .
- D U) A Reconciliation, including appropriate explanation of the Computation of et Capital Under Rule I 5c3- I and the Computation for Determination of the Reserve Requirement Under xhibit **A** of Rule I 5c3-3.
- <sup>181</sup>(k) A Reconci liation between the audited and unaudited tatements of Financial Condition with respect to methods of consol idation.
- 181 (I) An Oath or Affirmation.
- 0 (m) A copy of the IPC upplemental Report.
- D (n) A report describing any materia l inadequacies found to exist or found to have exi ted since the date of the previous audit.

*••For conditions of confidential treatment of certain portions of this filing, see section 240. I 7a-5(e)(3).* 

{2}------------------------------------------------

**CALIFORNIA JURAY WITH AFFIANT STATEMENT GOVERNMENT CODE§ 8202**  ¢ See Attached Document (Notary to cross out lines 1-6 below) D e 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 Cal\_mnia **fln**  County of *as* - ~ U!S • **CYNTHIA A. CASAS Notary Public** • **C1llfornl1 z j** Los Angeles County z **<sup>z</sup>**Commission# 2155047 ~ **t** • • • • **.Ml <sup>S</sup> 0 Tmci tx~re ~ai ~ 8 }&<sup>2</sup> d**  Seal Place Notary Seal Above Subscribed and sworn to (or affirmed) before me on this /"']\_\_ day ot--Z--X\ol,°e 20J9-. by Q Date Month Year (1) ~ bf'.\6 rY1 µ\_J\-f't:L- (and72) \_\_\_\_\_ -------r- ·-----), Name¢ of Signer¢) proved to me on t~~basis of satisfactory evidence to be the erson1,3I who appeared before me. **""'=:::---------------OPTIONAL---------------** CAc,\_ Tho his section is optional, completing this information can deter alteration of the document or **<sup>j</sup>**- **t7.** du/ent reattachment of this form to an unintended document. **Description of Attached D'?ltttmE~-** Title or Type of Document: --- -------=---.:::,---- Document Date: \_\_\_\_\_\_ \_ Number of Pages: \_\_ Signer(s) Other Than Named Above: - ======----==--- ----- **mWC¢0(;..<:<,'CC<!<X><,-c.<,'U(,.•C(;C<;C(,~<C<,'<,;<,,~~"Q{,<Ci,,'CO(:lO~~'CP(;<;(;PC!!~!'C'Ql~;Q',;"~~ <sup>~</sup> ~Q:;)!!~~**  ©2014 National Notary Association • www.NationalNotary.org · 1-800-US NOTARY (1-800-876-6827) Item #5910

{3}------------------------------------------------

18401 Burbank Blvd., Suite 120, Tanana, CA 91356 • Tel. (818) 636-5660 • Fax (818) 401-8818

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTfNG FIRM**

To the Shareholder's and Board of Members ofBardi Co., LLC

#### **Opinion on the Financial Statements**

I have a~dited the accompanying statement of financial condition of Sardi Co., LLC as of December 31, 2018, the related statements of income, changes in member's equity, and cash flows for the year then ended, and the related notes (collectively referred to as the financial statements). In my opinion, the financial statements present fairly, in all material respects, the financial position of Sardi Co., LLC 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 ofBardi Co., LLC 's management. My responsibility is to express an opinion on Bardi Co., LLC 's financial statements based on my audit. I am a public accounting finn registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and am required to be independent with respect to Sardi Co. 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.

l conducted my audit in accordance with the standards of the PCAOB. Those standards require that I plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. My 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. My audit also included evaluating the accounting principles used and significant estimates made by management, as evaluating the overall presentation of the financial statements. I believe that my audit provides a reasonable basis for my opinion.

#### **Supplemental Information**

The information contained in Schedule I, TI, and III ("Supplemental Information") has been subjected to audit procedures performed in conjWlction with the audit of the Company's financial statements. The Supplemental Information is the responsibility of the Company's management. My 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 infonnation presented in the Supplemental Information. In forming my opinion on the Supplemental Information, I evaluated whether the upplemental Information, including its form and content is presented in conformity with 17 C.F.R. § 240.l?a-S. In my opinion, Schedules I, II, and III are fairly stated, in all material respects, in relation to the financial statements taken as a whole.

B~

Certified Public Accountant I have served as Bardi Co., LLC 's auditor since 2017. Tarzana, California January 16, 2019

{4}------------------------------------------------

## **Bardi Co., LLC Statement** of **Financial Conditions December 31, 2018**

| Assets                                |              | 2018          |
|---------------------------------------|--------------|---------------|
| Cash                                  |              | \$<br>66,358  |
| Marketable securitie , at fair value  |              | 18,718        |
| Loan to<br>hareholder                 |              | 20,000        |
| Accounts Receivables                  |              | 235           |
| F[NRA CRD                             |              | 132           |
| Deposits                              |              | 5,200         |
| Vehicle                               |              | 21 ,765       |
|                                       | Total a sets | \$<br>132,408 |
|                                       |              |               |
| Liabilities and Members' Equity       |              |               |
| Current I iabi Ii ties                |              |               |
| Accounts Payables                     |              | \$<br>5,500   |
| Business Credit Card                  |              | 131           |
| Deferred revenues                     |              | 88,747        |
| Total current liabilities             |              | 94,378        |
| Members' equity                       |              |               |
| Members' equity                       |              | 38,030        |
| Total members' equity                 |              | 38,030        |
| Total liabilities and members' equity |              | \$<br>132,408 |

{5}------------------------------------------------

### **Bardi Co., LLC Statement of Income (Loss) For the Year Ended December 31, 2018**

#### **Revenue** :

| \$<br>223,791 |
|---------------|
| 4,643         |
| {4,476)       |
| 223,958       |
|               |
| 699           |
| 96,084        |
| 826           |
| 1,221         |
| 8,688         |
| 9,108         |
| 4,750         |
| 32,860        |
| 135           |
| 33,103        |
| 1,235         |
| 11,663        |
| 200,371       |
| 23,587        |
|               |
| {8002         |
| {800)         |
| 22,787        |
| \$            |

{6}------------------------------------------------

### **Bardi Co., LLC Statement of Changes in Members' Equity For the Year Ended December 31, 2018**

|                            | Total |        |
|----------------------------|-------|--------|
| Balance December 31, 2017  | \$    | 15,243 |
| Members Contribution       |       |        |
| et Income (loss)           |       | 22,787 |
| Balance, December 31, 2018 | \$    | 38,030 |

{7}------------------------------------------------

### **Bardi Co., LLC Statement of Cash Flows For the Year Ended December 31, 2018**

|                                                   |    | 2018             |  |
|---------------------------------------------------|----|------------------|--|
| Operating activities                              |    |                  |  |
| Net income (loss)                                 | \$ | 22,787           |  |
| Realized (gain) loss on marketable securiti es    |    | (4,643)<br>4,476 |  |
| Unreal ized (gain) loss marketable ecurities      |    | 1,235            |  |
| Depreciation                                      |    |                  |  |
| Adjustments to reconcile net income (lo ) to      |    |                  |  |
| net cash provided by operating activities:        |    |                  |  |
| Change in working capital component :             |    |                  |  |
| Accounts Receivable                               |    | (35)             |  |
| Loan to<br>hareholders                            |    | (20,000)         |  |
| F!NRA CRD                                         |    | (80)             |  |
| Credit Card                                       |    | 131              |  |
| Accounts Payable                                  |    | 3,500            |  |
| Deferred Revenues                                 |    | 18,070           |  |
| et ca h provided (used) by operating activities   |    | 25,440           |  |
| Inve ting Activities                              |    |                  |  |
| Vehicle                                           |    | (23,000)         |  |
| Lease Deposit                                     |    | (344)            |  |
| Purchase of Securities                            |    | (7,825)          |  |
| ct cash provided (used) by investment activities; |    | (31,169)         |  |
| Financing Activities                              |    |                  |  |
| Capital Contribution                              |    |                  |  |
| Net cash provided (u ed) by financing activities: |    |                  |  |
| et Increase (decrease) in cash and equivalents    | \$ | (5,729)          |  |
| Cash at 12/3 I/ 17                                | \$ | 72,086           |  |
| Cash at 12/3 1 /18                                | \$ | 66,358           |  |
|                                                   |    |                  |  |
| Supplementary Information:                        |    |                  |  |
| Cash paid for interest                            | \$ |                  |  |
| Cash paid for income taxes                        | \$ | 800              |  |

{8}------------------------------------------------

## Bardi Co., LLC otes to Financial Statements December 31, 2018

#### Note 1 - Organization and ature of Busine s

Bardi Co., LLC (the "Company") was formed in the State of California on September 13, 2012. The Company is a registered broker-dealer with the ecurities and Exchange Commission (SEC), the Financial Industry Regulatory Authority ("Fl RA") and the Securities Investor Protection Corporation (" IPC").

### **ote 2** - **Significant Accounting Policie**

**Basis of Presentation** -The Company conducts the following types ofbusines as a ecurities brokerdealer, which comprises several classes of services, including:

- Private placements of securities
- Jnvestment banking

**Use of Estimates** - The preparation of financial statements in conformity witl1 accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.

**ecurities Owned** - Profit and loss arising from all securities and commodities transactions entered into for the account and risk of the Company are recorded on a trade date basis and marked to market.

**Revenue Recognition** - lnve tment banking fees are contingent on, and are recognized upon, the successful completion of a project. Investment banking fees are generated from services related to a limited number of transactions. Due to the nature of the Company's business the size of any one tran action may be ignificant to the Company's operations for the period . From time to time, the Company is engaged with agreements that entail refundable retainers· in such cases, retainers are recognized as revenues only once the service is actually provided to the client.

Recent accounting standards as to revenue recognition impact most industries including broker-dealers. The complex arrangements between broker-dealer and their clients pose difficult issues for the new standards, effective in 2019 for calendar reporting non-public entities. The Company believes that its current practices are in conformity with such requirements, albeit industry task forces continue to research pecific accounting issues within these standards.

**Income Taxes** - The Company, with consent of its Member, has elected to be a California Limited Liability Company. For tax purposes the Company is treated like a partnership, therefore in lieu of busine s income taxes, the Member is taxed on the Company's taxable income. Therefore, no provision or liability for Federal Income Taxes is included in these financial statements. The State of California has a simi lar treatment. although there exists a provision for a gross receipts tax and a minimum Franchise Tax of \$800.

The accounting principle generally accepted in the United States of America provide accounting and disclosure guidance about positions taken by an organization in its tax returns that might be uncertain.

{9}------------------------------------------------

## **Bardi Co., LLC 'otes to Financial Statements December 31, 2018**

Management has con idered it tax position and believes that all of the positions taken by the Company in its Federal and tate organization tax returns are more likely than not to be sustained upon examination. The Company is subject to examinations by U.S. Federal and tate tax authorities from 2015 to present, generally for three years after they are filed.

### **Note 3** - **Fair Value**

FA 8 ASC 820 defines fair value, establishes a framewo rk for measuring fair value, and establishes a fair value hierarchy. which prioritize the inputs to valuation techniques. Fair value is the price that would be received to sell an as et 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 occur in the principal market for the asset or liability or, in the absence of a principal market, the most advantageou market. Valuation techniques that are con i tent with the market income or cost approach, as specified by F ASB A C 820, are used to measure fair value. The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels:

- Level I inputs are quoted prices (unadj usted) in active mark t for identical assets or liabilities the Company has the abi lity to acce s.
- Level 2 inputs are inputs (other than quoted prices included within level I) that are observable for the asset or liability. either directl y or indirectly.
- Level 3 are unobservable inputs for the as et or liability and rely on management's own assumptions about the assumptions that market participants would use in pricing the asset or liability. (The unobservable inputs should be developed based on the best infonnation available in the circumstances and may include the Company's own data.)

The following table presents the Company's fair value hierarchy for those assets and liabilities measured at fair value on a recurring basis as of December 31 , 2018:

|              | Level I   | Level2 | Level 3 | Total    |
|--------------|-----------|--------|---------|----------|
| Fixed Income | \$5,609   |        |         | \$5,609  |
| Common Stock | \$ 13,109 |        |         | \$13 109 |
| Total        | \$18,718  |        |         | \$18,718 |

#### **Fair Value Mea urements on a Recurring Basis As of December 31 2018**

#### **Note 4** - **Concentration of Risk**

Amounts held in financial institutions occasionally are in excess of the Federal Deposit Insurance Corporation and ecurities lnve tor Protection Corporation limits. The organization deposits its cash in high qua li ty financial institutions, and management believes the organization is not exposed to significant credit risk on those amount .

{10}------------------------------------------------

## **Bardi Co., LLC Notes to Financial Statements December 31, 2018**

#### **Note 5** - et **Capital Requirement**

The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule I 5c3-1), 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 I. Rule I 5c3-I also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed IO to I. At December 31 , 2018, the Company had net capital of \$8,367, which wa \$3,367 in exces of its required net capital of \$5,000. The Company's net capital ratio was 11 .28 to l.

### **ote 6- Operating Lease Commitments**

During fiscal year 20 I 8. the Company has leased two different office spaces in two separate locations. From January I, 2018 through December 31 , 2018 the Company leased one office space for approximately \$900 every month. On June I I, 2018, the Company entered into a new twelve-month noncancellable operating lease for another office space, commencing June 11 , 2018 and expiring June 30, 20 19.

At December 31, 2018, future minimum lease payments under these agreements were as follows:

For the Year Ending December 31.2019: \$24,067

Rent expense for the year ended December 3 I, 2018 was \$32,860.

### **Note** 7 - **Exemption from the SEC Rule 15c3-3**

Ru le 15c3-3(k)(2)(i) provides an exemption from the EC's o-called "customer protection rule" for firms that: carry no margin accounts; promptly transmit all customer funds and deliver all securities received in connection with their broker-dealer activities; do not otherwise hold funds or securities for, or owe money or securities to, customers; and effectuate al I financia l transactions with customers through one or more bank accounts designated as" pecial Account for the Exclusive Benefit of Customers" of the Company.

### **ote 8** - **Unearned Revenues**

In 201 8, the Company recorded unearned revenues for a total of \$88,747 a related to three clients who paid refundable retainer fees. The Company anticipates that such revenues will be recognized in full duri ng ti cal year 2019.

#### **Note 9** - **Loan to Shareholder**

In July 2018 the Company loaned to Chris Manfre shareholder and CEO, \$20,000 with a five-year promissory note with an interest payable on the unpaid principle of 5.05% per annum. The loan was initially secured by a 2015 Chevrolet Sonic. However, a of November 30, 2018, the promi sory note became callable and secured by marketable securities with value of\$83,965.

{11}------------------------------------------------

#### **ote 10** - **ubsequent Events**

The management has reviewed the results of operations for the period from its year end December 31, 2018 through January 16, 2019, the date the financial statements were available to be issued, and have determined that no adjustments are necessary to the amounts reported in the accompanying financial statements nor have any subsequent event occurred, the nature of which would require disclosure.

{12}------------------------------------------------

## **Bardi Co., LLC chedule** I - **Computation of et Capital Requirement December 31, 2018**

| Computation of et<br>apital under Rule l 5c3- l of the Securities and |               |
|-----------------------------------------------------------------------|---------------|
| Exchange Commission:                                                  |               |
|                                                                       |               |
| Total Members' equity from financial<br>condition                     | \$<br>38 030  |
| Deduction and charges:                                                |               |
| Non-allowable other assets                                            | (27,097)      |
| et capital before haircut charges                                     | 10,933        |
| Haircut on securities:                                                |               |
| Marketable securitie                                                  | (2,567)       |
| Net Capital                                                           | \$<br>8,367   |
|                                                                       |               |
| Aggregate Indebtedness:                                               |               |
| Accrued expenses                                                      | \$<br>94,378  |
| Total aggregate                                                       |               |
| indebtedness                                                          | \$<br>94,378  |
| Computation of Basic<br>et Capital<br>Requirement:                    |               |
| Minimum net capital                                                   |               |
| required                                                              | \$<br>5,000   |
| et capital                                                            | 8,367         |
| Excess net capital                                                    | \$<br>3,367   |
| Excess net capita I at                                                |               |
| 120%                                                                  | \$<br>(6,071) |
| Ratio: Aggregate indebtedness to net<br>capital                       | 11 .28        |
|                                                                       |               |
| Reconciliation with Company' Computation:                             |               |
| Members' equity as reported in<br>Company's Part LI                   |               |
| Focus report (unaudited)                                              | \$<br>38,030  |

{13}------------------------------------------------

## **Bardi Co., LLC Schedule JI - Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 December 31 , 2018**

**A** computation of reserve requirement is not applicable to Bardi Co., LLC a the Company qualifie for exemption under Rule l 5c3-3 (k) (2) (i).

{14}------------------------------------------------

## **Bardi Co., LLC Schedule** III - **Information Relating to Posses ion or Control Requirements under Rule 15c3-3 December 31, 2018**

Information relating to possession or control requirements is not applicable to Bardi Co., LLC as the Company qualifies for exemption under Rule I 5c3-3 (k) (2) (i).

{15}------------------------------------------------

18401 Burbank Blvd., Suite 120, Tarzana, CA 91356 · Tel. (818) 636-5660 • Fax (818) 401-8818

### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

Board of Members Bardi Co., LLC Los Angeles, California

I have reviewed management's statements, included in the accompanying Exemption Report in which (1) Bardi Co., LLC, identified the following provisions of 17 C.F.R. § 15c3-3(k) under which Bardi Co., LLC claimed an exemption from 17 C.F .R. §240. l 5c3-3: (k) (2) (i) (the "exemption provision") and (2) Bardi Co., LLC, stated that Bardi Co., LLC, met the identified exemption provision throughout the most recent fiscal year without exception. Bardi Co., LLC's management is responsible for compliance with the exemption provision and its statements.

My 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 Bardi Co., LLC's compliance with the exemption provision. 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, I do not express such an opinion.

Based on my review, I am 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 Rule l 5c3-3 under the Securities Exchange Act of 1934 .

. ~ W. Anson

Brian Certified Public Accountant Tarzana, California January 16, 2019

{16}------------------------------------------------

![](_page_16_Picture_0.jpeg)

January 16, 2019

Re: SEA Rule l 7a-5(d) (4) Exemption Report

Pursuant to the referenced rule, the following info1mation i provided.

Under its membership agreement with FINRA and pursuant to Rule 15c3-3, the Company conducts business on a fully di closed basis and does not execute or clear ecuritie transactions for customer .

Bardi Co. LLC met the Section 204 15c3-3 (k) (2) (i) exemption for the year 2018 .

Sincerely,

Christiano anfre' Managing Director and FinOp

t-n5<sup>1</sup> h 1ree1 Ilonr28, lt,sAngdes.CA\/tU71 P 32~-S,7 -9lJ6!J f 877-77-1-1126 inlnlc~bard1co1.,,m


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