# BARDI CO. LLC X-17A-5 (2020-02-12) — Broker-dealer annual report - Company: BARDI CO. LLC - Form: X-17A-5 - Filed: 2020-02-12 - Period: 2019-12-31 - Accession: 0001561729-20-000001 - CIK: 1561729 - File #: 8-69190 - Material weakness: No - Auditor: Brian Anson - Auditor location: Tarzana, CA - Contact: Cristiano Manfre - Phone: 3109939960 - Email: info@bardico.com - Website: bardico.com - Signed by: Cristiano Manfre (Managing Director & FINOP) Original filing: https://www.sec.gov/Archives/edgar/data/1561729/000156172920000001/full1.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549** # **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill** | | 0MB APPROVAL | |-------------|---------------------------| | 0MB Number: | 3235-0123 | | Expires: | August 31, 2020 | | | Estimated average burden | | | hours cer response 12.00 | # SEC FILE NUMBER 8-69190 **FACING PAGE** **Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder** | REPORT FOR THE PERIOD BEGINNINGQ1/Q1/2019
AND ENDING 12/31/2019 | | | | | |--------------------------------------------------------------------------------------------------|--------------------------------------------------------|------------|--------------------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: Sardi Co. LLC | | | OFFICIAL USE ONLY | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)
633 W. 5th Street, Floor 26 | | | FIRM I.D. NO. | | | | (No. and Street) | | | | | Los Angeles | CA | 90071 | | | | (City) | {State} | {Zip Code) | | | | Chris Manire
310-993-9960 | B. ACCOUNTANT IDENTIFICATION | | (Area Code - Telephone Number) | | | INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained in this Report*
Brian W. Anson, CPA | | | | | | | {Name - if individual, state last, first, middle name} | | | | | 18401 Burbank Blvd #120 | Tarzana | CA | 91356 | | | (Address) | (City) | (State) | (Zip Code) | | | CHECK ONE: | | | | | | It/ I
Certified Public Accountant
ublic Accountant | | | | | | Accountant not resident in United States or any of its possessions. | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | *\*Claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.* J *7a-5(e)(2)* SEC 141 O {06-02) **Potential persons who are to respond to the collection of Information contained** in **this form are not required to respond unless the form displays a currently valid 0MB control number.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | I,
Chris Manfre | , swear (or affirm) that, to the best of | | |--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------|--| | Bardi Co. LLC | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
-------------------------------------------- | | | of December 31 | , as
are true and correct. I further swear (or affirm) that | | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows: **SEE.ATTACHED NOTARIAL CERTIFICATE** Title Notary Public This report\*\* contains (check all applicable boxes): - B (a) Facing Page. - **v** {b) Statement of Financial Condition. - **v** (c) Statement of Income (Loss). - **v** ( d) Statement of Changes in Financial Condition . - ., (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. - (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors . - ., (g) Computation of Net Capital. - ., (h) Computation for Determination of Reserve Requirements Pursuant to Rule I 5c3-3 . - ., (i) Information Relating to the Possession or Control Requirements Under Rule l5c3-3. **0** (j) A Reconciliation, including appropriate explanation of the Computation ofNet Capital Under Rule l 5c3-l and the Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. - **0** (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of consolidation. - § (I) An Oath or Affirmation. - (m) A copy of the SIPC Supplemental Report. - {n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. ° *For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).* {2}------------------------------------------------ #### **CALIFORNIA JURAT WITH AFFIANT STATEMENT GOVERNMENT CODE** § **8202** **@IOOlll."OO** ' 1 E il\$iB O /43 **OJ&,** l.iltJ ! E E E § § ~ **U a n** £ E 00: D O ):I~ ~ E B:lfflU!JfU **£00ffiRffi** ·'Q~e Attached Document (Notary to cross out lines 1- 6 below) psee Statement Below (Lines 1- 6 to be completed only by document signer[s], not Notary) ~----------------- - Signature of Document Signer No. 1 ure of Document Signer No. 2 (if any) A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. · State of California County of \ 1H an~,e,I ti LOURDES !RENE **CASTRO** Notary Public • **California** Los Angeles County Comm1ss1on # **211!9871** comm. **Expirea** Jul **15 2020 =-.... 9'"3'~** Place Notary Seal and/or Stamp Above Subscribed and sworn to (or affirmed) before me on this \ I day of 11 hru 11 r0 ' 20 *?1J,* by Datf;: Month 0 Year (1) \_\_.\_.\_.\_~ t........... 1, :h ............. J4---'-n4--'-'o'----'--"'- L .\_tvJ.\_\_\_\_.\_.,,\_\_\_,\_tl *b ........... h-+---'2,,,\_\_,\_ 1*\_ (an\_;!J2Y-\_\_\_\_\_\_\_ \_ \_\_\_ \_\_ ), Nam~Sign~ Signature asis of satisfactory evidence to ppeared before Completing this information can deter alteration of the document or fraudulent reattachment of this form to an unintended document. **Description of Attached Document** Title or Type of Document: anrn I *t1* \ Document Date: ~ t · I\ YD rv *I* 'frU d Iti *d* ~J µor± \ otUb or el£mnt1:b o IJ Number of Pages: \_ \_\_\_\_ \_ \_ Signer( Other Than Named Above: \_\_\_\_\_ \_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_ \_ © 2017 National Notary Association {3}------------------------------------------------ **BRIAN W. ANSON** *Cenified Public Accoun1ant* 1840 I Burbank Blvd., Suite 120, Tanana, CA 91356 • Tel. (818) 636-5660 • Fax (818) 401-8818 #### **REPORT OF INDEPE:\l>ENT REGISTERED PUBLIC ACCOUNTING FJ..&1\1** To the Shareholder's and Board of Members of Bardi Co., LLC #### **Opinion** on **the Financial Statements** I have audited the accompanying statement of financial condition of Sardi Co., LLC as of December 31 , 2019, 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 Bardi Co., LLC as of December 31, 2019, 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 sratements 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 Bardi 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. [ 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 arc 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 a lso included evaluating the accounting principles used and significant estimates made by management. as evaluating the overall prcsemarion of the financial statements. l believe that my audit provides a reasonable basis for my opinion. #### **Supplemental Information** The information contained in Schedule I. II, and ill ("Supplemental Information") has been subjected to audit procedures performed in conjunction with the audit of the Bardi Co., LLC's financia l statements. The Supplemental Information is the responsibility of the Bardi Co., LLC'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 perfonning procedures to test the completeness and accuracy of the information presented in the Supplemental lnformation. In fonning my opinion on the Supplemental lnformation, I evaluated whether the Supplemental [nformation, including its form and content is presented in conformity with 17 C.F.R. § 240. I 7a-5. In my opinion, Schedules l, rt, and Ill are fairly stated. in all mate rial respects, in relation to the financial statements taken as a whole. /41 Brian W. Anson Certified Public Accountant I have served as Bardi Co., LLC 's auditor since 2017. Tanana. California January 29. 2020 {4}------------------------------------------------ # **Bardi Co., LLC Statement of Financial Conditions December 31, 2019** | Assets | 2019 | |------------------------------------------------------------------|---------------| | | | | Cash | \$
89,294 | | Marketable Securities, at Fair Value | 19,964 | | Loan to Shareholders | 16,000 | | Accounts Receivables | 12,994 | | FINRA CRD | 383 | | Deposits | 5,450 | | Loan to Bardi Quam | 10 000 | | Total Assets | \$
154,085 | | Current liabilities
Accounts Payables
Business Credit Card | 1,568 | | Deferred Revenues | 68 647 | | Total Current Liabilities | 70,215 | | Members' Equity | | | Members' Equity | 83 870 | | Total Members' Equity | 83 870 | | Total Liabilities and Members' Equity | \$
154,085 | see Accompanying Notes to Financial Statements {5}------------------------------------------------ # **Bardi Co., LLC Statement of Income (Loss) For the Year Ended December 31, 2019** | Revenues: | | |-------------------------------------------|---------------| | Commissions and Consulting Fees | \$
164,845 | | Interest Earned | 1,619 | | Realized Gains on Marketable Securities | 615 | | Unrealized gains on Marketable Securities | 1,245 | | Total revenue | 168,324 | | Expense: | | | Bad Debt | 1,351 | | Bank Charges | 505 | | Commissions | 56,4 16 | | Dues and Subscriptions | 320 | | Insurance | 1,948 | | Office Expense | 10,041 | | Professional Services | 4,765 | | Regulatory Fees | 3,567 | | Rent | 43,394 | | Travel and Entertainment | 24,309 | | Marketing | 2,102 | | Loss on Asset Disposal | 7,765 | | Utilities | 4,009 | | AU Others | ), 193 | | Total Expenses | 161,685 | | Income (Loss) from Operation | 6,639 | | Income Tax Benefit (Expense): | | | Current State Franchise Tax | (8002 | | Total Income Tax Expense | (8002 | | Net Income (Loss) | \$
5,839 | See Accompanying Notes to Financial Statements {6}------------------------------------------------ # **Bardi Co., LLC Statement of Changes** in **Members' Equity For the Year Ended December 31, 2019** | | Total | | |----------------------------|-------|--------| | Balance, December 31, 2018 | \$ | 38,030 | | Members Contributions | | 40,000 | | Net Income (loss) | | 5,839 | | Balance, December 31, 2019 | \$ | 83,870 | See Accompanying Notes to Financial Statements {7}------------------------------------------------ # **Bardi Co., LLC Statement of Cash Flows For the Year Ended December 31, 2019** | | 2019 | | |----------------------------------------------------|------|----------| | Operating activities | | | | Net income (loss) | \$ | 5,839 | | Bad debt | | (1,352) | | Loss on Assets Disposal | | 7,765 | | (Gain) loss on sale of securities | | (1,245) | | Adjustments to reconcile net income (loss) to | | | | net cash provided (used) by operating activities: | | | | Change in working capital components: | | | | Increase in Accounts Receivable | | (11.407) | | Increase in FINRA CRD | | (251) | | Increase in Credit Card Debt | | 1,437 | | Decrease in Accounts Payable | | (5,500) | | Decrease in Deferred Revenues | | (20,100) | | Net cash Provided (Used) by Operating Activities | | (24,814) | | Investing Activities | | | | Sale of Vehicle | | 14,000 | | Increase in Lease Deposit | | (250) | | Loan Repayment | | 4,000 | | Loan to Shareholders | | (10,000) | | Net Cash Provided (Used) by Investment Activities: | | 7,750 | | Financing Activities | | | | Capital Contribution | | 40 000 | | Net Cash provided (Used) by Financing Activities: | | 40,000 | | Net Increase (Decrease) in Cash and Equivalents | \$ | 22,936 | | Cash at 12/31/18 | \$ | 66,358 | | Cash at 12/31 /19 | \$ | 89,294 | | Supplementary Information: | | | | Cash Pa id for Interest | \$ | | | Cash Paid for [ncome Taxes | \$ | 800 | | | | | See Accompanying Notes to Financial Statements {8}------------------------------------------------ # **Note 1- Organization and Nature of Business** 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 Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). ## **Note 2 - Significant Accounting Policies** **Basis of Presentation** - The Company conducts the following types of business as a securities brokerdealer, which comprises several classes of services, including: - Private placements of securities - Investment banking **Use of Estimates** - The preparation of financial statements in conformity with 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. **Securities 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** - Investment 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 transaction may be significant 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. ### Significant accounting policy Revenue is measured based on a consideration specified in a contract with a customer, and excludes any sales incentives and amounts collected on behalf of third parties. The Company recognizes revenue when it satisfied a performance obligation by transferring control over a product or service to a customer. Taxes and regulatory fees assessed by a government authority or agency that are both imposed on and concurrent with a specified revenue-producing transaction, that are collected by the Company from a customer, are excluded from revenue. ## Nature of services The following is a description of activities - separated by reportable segments, per FINRA Form "Supplemental Statement of Income (SSOI)"; from which the Company generates its revenue. For more detailed information about reportable segments, see below {9}------------------------------------------------ Fees earned: This includes fees earned from affiliated entities; investment banking fees, M&A advisory; account supervision and investment advisory fees; administrative fees, revenue from research services; rebates from exchanges/ECN and A TS; l 2b-l fees; Mutual fund fees other than concessions or l 2b-l fees; execution service fees; clearing services; fees earned from customer bank sweep into FDIC insured products or from '40Act companies and networking fees from ' 40 Act companies. In 2019, the Company's four top clients accounted for approximately 76% of total revenues. **Income Taxes** -The Company, with consent of its Member, has elected to be a Califomfa Limited Liability Company. For tax purposes the Company is treated like a partnership, therefore in lieu of business 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 similar treatment, although there exists a provision for a gross receipts tax and a minimum Franchise Tax of \$800. The accounting principles 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. Management has considered its tax positions and believes that all of the positions taken by the Company in its Federal and State organization tax returns are more likely than not to be sustained upon examination. The Company is subject to examinations by U.S. Federal and State tax authorities from 20 I 6 to present, generally for three years after they are filed. ## **Note 3** - **Fair Value** FASB ASC 820 defines fair value, establishes a framework for measuring fair value, and establishes a fair value hierarchy, which prioritizes the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liabjlity in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transactfon 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 F ASB ASC 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 (unadjusted) in active markets for identical assets or liabilities the Company has the ability to access. - Level 2 inputs are inputs (other than quoted prices included within level 1) that are observable for the asset or liability, either directly or indirectly. - Level 3 are unobservable inputs for the asset 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 information 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, 2019: {10}------------------------------------------------ ## **Fair Value Measurements on a Recurring Basis As of December 31, 2019** | | Levell | Level2 | Level 3 | Total | |--------------|----------|--------|---------|----------| | Fixed Income | \$6,431 | | | \$6,431 | | Common Stock | \$13,533 | | | \$13,533 | | Total | \$19.964 | | | \$19,964 | ## **Note 4** - **Concentration of Risk** Amounts held in financial institutions occasionally are in excess of the Federal Deposit Insurance Corporation and Securities Investor Protection Corporation limits. The organization deposits its cash in high quality financial institutions, and management believes the organization is not exposed to significant credit risk on those amounts. ## **Note 5** - **Net Capital Requirement** The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule l5c3-l), 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 15c3-l 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, 2019, the Company had net capital of \$72,826, which was \$67,826 in excess of its required net capital of \$5,000. The Company's net capital ratio was 0.96. #### **Note 6- Operating Lease Commitments** During fiscal year 2019, the Company has leased three different office spaces in two separate locations. From January 1, 2019 through December 31, 2019 the Company leased two office spaces for approximately \$3,400 every month at respectively Metro 417 and Regus in downtown Los Angeles. On May 1, 2019, the Company entered into a new twelve-month non-cancellable operating lease for another office space Metro 417, commencing May 1, 2019 and expiring April 30, 2020. Management has reviewed ASC 842 Lease Accounting and does not believe that it is applicable to the Company because the two operating leases for office space expire respectively in four months, on April 30, 2020, and 11 months, on November 30, 2020. At December 31, 2019, future minimum lease payments under these agreements were as follows: For the Year Ending December 31, 2020: \$10,974 Rent expense for the year ended December 31 , 2019 was \$43,394. {11}------------------------------------------------ ## **Note 7** - **Exemption from the SEC Rule 15c3-3** Rule 15c3-3(k)(2)(i) provides an exemption from the SEC's so-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 all financial transactions with customers through one or more bank accounts designated as "Special Account for the Exclusive Benefit of Customers" of the Company. ### **Note 8 - Unearned Revenues** In 2019, the Company recorded deferred revenues for a total of \$68,647 as related to three clients who paid refundable retainer fees. The Company anticipates that such revenues will be recognized in full during fiscal year 2020. #### **Note 9** - **Loan to Shareholders** On July 7, 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. In July 2019, Chris Manfre paid interest of\$1,0l0 and principal of\$4,000. On July 19, 2019, the Company loaned to Bardi Quant L.P. \$10,000 with a five-year promissory note with an interest payable on the unpaid principle of 3.65% per annum. #### **Note 10** - **Subsequent Events** The management has reviewed the results of operations for the period from its year end December 31 , 2019 through January 29, 2020, the date the financial statements were available to be issued, and have determined that no adjustments are necessary to lhe amounts reported in the accompanying financial statements nor have any subsequent events occurred, the nature of which would require disclosure. In January 2020, the Company loaned \$20,000 to Bardi Quant L.P., \$30,000 to the Company officer Chris Manfre, and the officer Chris Manfre withdrew \$20,000 from his member's capital account. {12}------------------------------------------------ # **Bardi Co., LLC Schedule** I - **Computation of Net Capital Requirement December 31, 2019** ### **Computation of Net Capital unde r Rule 15c3-1 of the Securities and** Exchange Commission: | Total Members' equity from financial condition | \$
83,870 | |--------------------------------------------------|--------------| | Deduction and charges: | | | Non-allowable other assets | (5,833) | | Net capital before haircut charges | 78,037 | | Haircut on Investments | (5,211) | | Net Capital | 72,826 | | Aggregate Indebtedness: | | | Current liabilities | 70 215 | | Total Aggregate Indebtedness | 70 215 | | Computation of Basic Net Capital Requirement: | | | Net capital | 72,826 | | Minimum Net Capital Required | 5,000 | | Excess net capital | 67,826 | | Excess net capital at 120% | \$
66,826 | | Ratio: Aggregate Indebtedness to Net Capital | 0.96 | | Reconciliation with Companv's Computation: | | | Members' equity as reported in Company's Part II | | | Focus report (unaudited) | \$
83,870 | {13}------------------------------------------------ # **Bardi Co., LLC Schedule** II - **Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 December 31, 2019** A computation ofreserve requirement is not applicable to Bardi Co., LLC as the Company qualifies for exemption under Rule 15c3-3 (k) (2) (i). {14}------------------------------------------------ # **Bardi Co., LLC Schedule** III - **Information Relating to Possession or Control Requirements under Rule 15c3-3 December 31, 2019** lnfonnation relating to possession or control requirements is not appljcable to Bardi Co., LLC as the Company qualifies for exemption under Rule l Sc3-3 (k) (2) (i). {15}------------------------------------------------ **BRIAN W.** ANSON *Certified Public* AccountanJ 18401 Burbank Blvd., Suite 120, Tanana, 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) Bardj Co., LLC, identified rhe following provisions of 17 C.F.R. § l 5c3-3(k) under which Dardj Co., LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (k) (2) (i) (the '·exemption provisions") and (2) Sardi Co., LLC, stated that Bardi Co., LLC, met the identified exemption provisions throughout the most recent fiscal year without exception. Bardi Co., LLC's management is responsible for compliance with the exemption provisions 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 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, J 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 15c3-3 under the Securities Exchange Act of 1934. *~4'1* Brian W. Anson Certified Public Accountant Tarzana, California January 29, 2020 {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) January 31, 2020 ## Re: SEA Rule 17a-5(d) (4) Exemption Report Pursuant to the referenced rule, the following infom1ation is provided. Under its membership agreement with FINRA and pursuant to Rule l 5c3-3, the Company conducts business on a fully disclosed basis and does not execute or clear securities transactions for customers. Bardi Co. LLC met the Section 204, 15c3-3 (k) (2) (i) exemption for the year 2019. Sincerely, Christiano Manfre' Managing Director and FinOp 633 5th Street. Floor 28. Los Angeles, CA 90071 P: 323-977-9960 f : 877-774-1326 info@bardico.com Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.