# BARDI CO. LLC X-17A-5 (2021-02-26) — Broker-dealer annual report - Company: BARDI CO. LLC - Form: X-17A-5 - Filed: 2021-02-26 - Period: 2020-12-31 - Accession: 0001561729-21-000001 - CIK: 1561729 - File #: 8-69190 - Material weakness: No - Auditor: Brian Anson - Auditor location: Tarzana, CA - Contact: Chris Manfre - Phone: 3109939960 - Website: nationajnotary.org - Signed by: Chris Manfre (CEO & FINOP) Original filing: https://www.sec.gov/Archives/edgar/data/1561729/000156172921000001/audit2020.pdf --- {0}------------------------------------------------ UNITEDSTATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: August 31, 2020 Estimated average burden hours oer resoonse 12.00 SEC FILE NUMBER •-69190 # ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill FAClNG PAGE Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule l 7a-S Thereunder | REPORT FOR THE PERIOD BEGINNING01/01/2020 | | AND ENDING 12/31/2020 | | | |----------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------|-----------------------|---------------------------------|--| | | MM/DD/YY | | MMIDD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME or 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 1.D. NO. | | | | (No. and Street) | | | | | Los Angeles | CA | 90071 | | | | (City) | (State) | (Zip Code) | | | | NA.i\1£ AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Olrls Manfre
310-993-9960 | | | | | | | | | (Arca Code - 1 clephone Number) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained in this Report"
Brian W. Anson, CPA | (Name - ifi11d1vidual. srnlt l(m, fint. middle mim") | | | | | 18401 Burbank Blvd #120 | Tarzana | CA | 91356 | | | (Addreu) | (City) | (Staie) | (Zip Code) | | | CHECK ONE: | | | | | | lv'ICertified Public Accountant
B
Puhlic Accountant
Accountant not resident in United States or any of its possessions. | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | | | | | | | *=Ctaims for exemption from the requirement that the annual report be covered by the opinion of an independent public accoull/ant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240./7a-5(e)(2)* > Potential persons who are to respond to the ccneenon of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. SEC 141o (06--02) {1}------------------------------------------------ #### OATH OR AFFIRMATION | I, __ C_h_ri_,_M_a_a_f_,e | | . swear (or affirm) that. to the best of | |----------------------------------------------------------------------------------------------------------------------------------|-------|-------------------------------------------------------| | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
Sardi Co. LLC | | -�---------------------��---------------------· '' | | of December 31 | 20 20 | are true and correct. I funhcr 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: *CcD* */.ed�.�* Title *ax/ fi,vOf* #### SEE ATTACHED NOTARIAL CERTIFICATE Notary Public This report w contains (check all applicable boxes): 8 (a) Facing Page. ,... (b) Statement of Financial Condition. - ,.... (c) Statement of Income (Loss) . - .,. (d) Statement of Changes in Financial Condition. - *v* (c) 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 15c3-3. - "' (i) lnfonnation Relating to the Possession or Control Requirements Under Ruic 15c3-3. - 0 (i) A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3-1 and the Computation for Determination of the Reserve Requirements Under Exhibit A of Ruic 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 trearmem of certain portions of this filing, see section UO. J 7a-5(e)(3).* {2}------------------------------------------------ . ""}f's P"W a w a ww&Qa. a • CALIFORNIA JURAT WITH AFFIANT STATEMENT GOVERNMENT CODE§ 8202 ';;:l§!Je Attached Gocument (Notary to cross out lines 1-6 below) See Statement Below (Lines 1--6 to be completed only by document signer[sJ, *not* Notary) ,, ,, *Signature of Document Signer No. 1 Signature of Docum nt 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 \,Oj ffili2j:l\eJ l ffMlll�lm�1111111rna1ftlllblnillllllHIMllllftllWRlUHIHIHIIIIIIHIHlli .. IRENEu.sTRO � Moury Pub!lc • CtUfomta I I los.+.oplnCounty \_ ICommlulon *I* 2331652I *11f1* tomm. �lrts Aut: 15, 2024 MMIIIIHIIINIMlffl ...... l!UIHl"•1�1t1ltlQ ... IINllll"IMIIIIHINIIIIII Subscribed and sworn to (or affirmed) before me on this�' o� day of 1:Ebnl v1Y0:: . 20-2:l by *Date MonthU Year* (1,)\_ ----'�d!hl..Ln *,L-L.:�WL�* oLL£rLL't"---------- (an�-----------). *Nam.JJM-d Sign'll(,,}* proved to me on the basis of satisfact.ory E!Vidence to be the pers�h appeared before me. *Seal Place Notary S"eal Above --------'-------oPTIONAL-------------- Though this section* is· *optional, completing this information can deter alteration of the document or fraudulent rea/tachment of this form toen unintended document.* Description of Attached Document Trtle or Type of Document: Olt\h Oy rub1ro0:hon Document Date:.G1n�d ijr, \D. *Y/* Number of Pages: *L* Signer( Other Than Named Above:--------------- ©2014 National Notary Association• WWW.NationaJNotary.org • 1·800-US NOTARY {1·800·876·6827) Item #5910 {3}------------------------------------------------ BRIAN \V. ANSON *Cenlfied 1'11blic Accou1110111* 18455 Burbank Blvd .. Suite 404. Tarzana. CA 91356 • Tel. (818) 636-5660 • Fas (818) 881-2605 #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM 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 Bardi Co .. LLC as of December 3 1 . 2020. 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 ITI) opinion. the financial statements present fairly. in all material respects. the financial position of Sardi Co., LLC as of December 31. 2020. and the results of its operations and its cash nows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### Basis for Opinion These financial statements arc the responsibility or Bardi Co .. LLC "s management. My responsibility is to express an opinion on Sardi Co., LLC "s financial statements based on my audit. I am a public accounting finn registered with the Public Company Acccuruing Oversight Board (United States) (PCAOB) and am required to be independent with respect to Burdi Co., LLC in accordance with the U.S. federal securities Jaws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. l I conducted my audit in accordance with the standards of the PCAOB. Those standards require that I plan and pcrfonn the audit to obtain reasonable nssumnce 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 rny audit provides a reasonable basis for my opinion. #### Supplemental Information The information contained in Schedule I. II. and Ill (''Supplemental lnfonnation") has been subjected to audit procedures performed in conjunction with the audit ofthe Sardi Co .• LLC's financial smtcmerus. The Supplemental Information is the responsibility of the Bardi Co .. I.LC's management. M) audit procedures included detcnnining whether the Supplemental Information reconciles to the financial statements or the underly ing 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 Supplcmemal Information. including its form and content is presented in confonnity with 17 C.F.R. § 240.17a·5. In m) opinion, Schedules I. 11. and Ill arc fairly stated, in all material respects, in relation 10 the financial statements 111�cn as a whole. */fw�* st.fn W. Anson Certified Public Accountant I have served as Sardi Co .. LLC "s auditor since 2017. Tarzena, California January 19. 2021 {4}------------------------------------------------ #### Bardi Co., LLC Statement of Financial Conditions December 31, 2020 | Assets | | | 2020 | |------------------------------------------------|--------------|----|---------| | Cash | | \$ | 35,355 | | Marketable Securities, at Fair Value | | | 13,976 | | Loan to Shareholders | | | 32,000 | | Accounts Receivables | | | 2,800 | | FINRACRD | | | 118 | | Loan to Related Party | | | 140 000 | | Deposits | | | 935 | | | Total Assets | s | 225184 | | Liabilities and Members' Equity
Liabilities | | | | | Accounts Payables | | | | | Business Credit Card | | | 77 | | Deferred Revenues | | | 41,825 | | PPP Loan | | | 2,224 | | Loan Payable SBA | | | 106 800 | | Total Liabilities | | | 150,926 | | Members' Equity | | | | | Members' Equity | | | 74 258 | | Total Members' Equity | | | 74 258 | | Total Liabilities and Members' Equity | | \$ | 225 184 | See Accompanying Notes to Financial Statements {5}------------------------------------------------ ## Bardi Co., LLC Statement of Income (Loss) For the Year Ended December 31, 2020 | Revenues: | | | |--------------------------------------------------------------|----|---------| | Commissions and Consulting Fees | \$ | 125,579 | | Interest Earned | | 781 | | Realized Gains on Marketable Securities | | 897 | | Unrealized Losses on Marketable Securities | | (2,925) | | Total revenue | | 124,332 | | Expense: | | | | Bank Charges | | 171 | | Commissions & Fees | | 43,425 | | Insurance | | 1,508 | | Office Expense | | 8,977 | | Legal & Professional Services | | 10,750 | | Regulatory Fees | | 3,040 | | Rent and Utilities | | 27,183 | | Travel and Entertainment | | 1,919 | | Marketing | | 1,146 | | All Others | | 631 | | Total Expenses | | 98,749 | | Income (Loss) from Operation | | 25 583 | | Income Tax Benefit (Expense):
Current State Franchise Tax | | 800 | | Total Income Tax Expense | | | | | | 800 | | Net Income (Loss) | s | 24,783 | See Accompanying Notes to Financial Statements {6}------------------------------------------------ #### **Bardi** Co., **LLC Statement of Changes in Members' Equity For the Year Ended December 31, 2020** | | Total | | |------------------------------------------|--------------------|--| | Balance, December 31, 2019 | S
83,870 | | | Members Withdrawals
Net Income (Loss) | (34,394)
24 783 | | | Balance, December 31, 2020 | s
74,258 | | {7}------------------------------------------------ #### Bardi Co., LLC Statement of Cash Flows For the Year Ended December 31, 2020 | 24, 783 | |-----------| | | | | | 2,925 | | | | | | | | 3,062 | | 10,194 | | 265 | | 4,515 | | (1,491) | | (26,822) | | 17,431 | | | | (16,000) | | (130,000) | | (146,000) | | | | 2,224 | | 106,800 | | (34,394) | | 74,630 | | (53,939) | | 89 294 | | 35 355 | | | | | | 800 | | | See Accompanying Notes to Financial Statements {8}------------------------------------------------ #### Bardi Co., LLC Notes to Financial Statements December 31, 2020 #### Note t - 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 broker-dealer, which comprises several classes of services, including: - Private placements of securities; - Investment banking; - Exempt Reporting Advisor. 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 mark to market. 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. Revenue Recognition - Investment banking fees are contingent on, and are recognized upon, the successful completion of a project. Investment banking fees arc generated from services related to a limited number of transactions. ## 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 beha1f of third parties. The Company recognizes revenue when it satisfied a performance obligation by transferring control over a product or service to a customer. {9}------------------------------------------------ ## Sardi ce., LLC Notes to Financial Statements December 31, 2020 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 FIN RA Form "Supplemental Statement of Income (SSOI)"; from which the Company generates its revenue. For more detailed information about reportable segments, see below 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; I 2b-1 fees; Mutual fund fees other than concessions or 12b-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 2020, the Company's three top clients accounted for 54% of total revenues. 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 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 2017 to present, generally for three years after they are filed. # Note 3 - Fair Value F ASB 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 liability in an orderly transaction between market participants at the measurement date. A fair value measurement {10}------------------------------------------------ ### Bardi Co., LLC Notes to Financial Statements December 31, 2020 assumes that the transaction to sell the asset or transfer the liability occurs in the principal market for the asset or liability or, in the absence of a principal market, the most advantageous market. Valuation techniques that are consistent with the market, income or cost approach, as specified by 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 I) 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, 2020: ## Fair Value Measurements on a Recurring Basis As of December 31, 2020 | | Level 1 | Level 2 | Level 3 | Total | |--------------|----------|---------|---------|----------| | Fixed Income | \$4,564 | | | \$4564 | | Common Stock | \$9 412 | | | \$9 412 | | Total | \$13,976 | | | \$13.976 | 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 S - Net Capital Requirement The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule l 5c3-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 l 5c3-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 {11}------------------------------------------------ #### Hardi Co., LLC Notes to Financial Statements December 31, 2020 3 1, 2020, the Company had net capital of \$59, 182, which was \$54, 182 in excess of its required net capital of \$5,000. The Company's net capital ratio was 2.55. #### Note 6- Operating Lease Commitments During fiscal year 2020, the Company has leased three different office spaces in two separate locations. From January I, 2020 through December 31, 2020 the Company leased two office spaces for approximately \$1,750 every month at Metro 417 while maintaining a virtual address at Regus in downtown Los Angeles for \$135 a month. Management has reviewed ASC 842 Lease Accounting and does not believe that it is applicable to the Company because of the two office spaces at Metro 417, one office space is on a monthto-month basis and the other expire respectively on February 28, 2020. At December 31, 2020, future minimum lease payments under these agreements were as follows: For the Year Ending December 31, 2021: \$2,872 Rent expense for the year ended December 3 1, 2020 was \$27, l 83. #### Note 7 - Exemption from the SEC Rule 15c3-3 Rule l 5c3-3(k)(2)(i) provides an exemption from the SEC's so-called "customer protection rule" for finns 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 2020, the Company recorded deferred revenues for a total of \$41,825 as related to three clients. The Company anticipates that such revenues will be recognized in full during fiscal year 2021. #### Note 9 - Loan to Shareholders On January 31, 2020, the Company loaned to Chris Manfre, shareholder and CEO, \$20,000 with a one-year promissory note with an interest payable on the unpaid principal of 1.60% per annum. The previous \$12,000 outstanding five-year promissory note was renegotiated into a new oneyear promissory note for a combined amount of \$32,000 with the same expiration date and interest rate. On January I, 2020, Chris Manfre paid interest of\$394 on the outstanding {12}------------------------------------------------ ### Bardi Co., LLC Notes to Financial Statements December 31, 2020 promissory note. On January 2 1, 2020, the Company loaned to Sardi Quant L.P. \$20,000 with a one-year promissory note with an interest payable on the unpaid principle of 0.5% per annum. Similarly, on July 14, 2020, the Company loaned to Bardi Quant L.P. \$110,000 with a one-year promissory note with an interest payable on the unpaid principle of 0.5% per annum. On July 14, 2020, Bardi Quant L.P. paid interest of\$365 on the outstanding promissory note of\$10,000 that was executed on July 14, 2019. #### Note 10 - Paycheck Protection Program On July 27, 2020, the Company was granted a loan in the aggregate amount of \$2,224 pursuant to the Paycheck Protection Program (PPP Loan) under the recently enacted Coronavirus Aid, Relief, and Economic Security Act ("CARES Act") administered by the U.S. Small annum and is subject to the terms and conditions applicable to loans administered by the U.S. Small Business Administration under the CARES Act. Subject to certain conditions. the PPP Loan may be forgiven in whole or in part by applying for forgiveness pursuant to the CARES Act and the PPP Loan. There can be no assurance that the Company will be granted forgiveness of the PPP Loan in whole or in part. Note 11 - SBA Loan On June 26, 2020, the Company took a 30-year SBA loan in the net aggregate amount of \$ I 06,800 for an interest rate of 3. 75%. #### Note 12 - Subsequent Events The management has reviewed the results of operations for the period from its year end December 3 1, 2020 through January 19, 2021, 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 events occurred, the nature of which would require disclosure. · {13}------------------------------------------------ #### Bardi Co., LLC Schedule I - Computation of Net Capital Requirement December 31, 2020 | Computation of Net Capital Under Rule IScJ-1 of the Securities and | | |--------------------------------------------------------------------|------------------| | Exchange Commission: | | | Total Members' Equity from Financial Condition | s
74,258 | | Deduction and Charges: | | | Non-allowable other assets | -----
(1,053) | | Net Capital Before Haircut Charges | 73,206 | | Haircut on Investments | (14,024) | | Net Capital | 59,182 | | Aggregate Indebtedness: | | | Current Liabilities | 41,902 | | Long Tenn Liabilities | 109,024 | | Total Aggregate Indebtedness | 150,926 | | Computation of Basic Net Capital Requirement: | | | Net Capital | 59,182 | | Minimum Net Capital Required | 5 000 | | Excess Net Capital | 54 182 | | Excess Net Capital at 120% | s
53 182 | | Ratio: Aggregate Indebtedness to Net Capital | 2.55 | | -------
Reconciliation with Company's Computation: | | | | | ' 74,258 Members' Equity as Reported in Company's Part II Focus Report (Unaudited) {14}------------------------------------------------ ## Bardi Co., LLC Schedule II - Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 December 31, 2020 A computation of reserve requirement is not applicable to Sardi Co., LLC as the Company qualifies for exemption under Rule I 5c3-3 (k) (2) (i). {15}------------------------------------------------ #### " • Bardi ce., LLC Schedule III - Information Relating to Possession or Control Requirements under Rule 15c3-3 December 31, 2020 Information relating to possession or control requirements is not applicable to Bardi Co .• LLC as the Company qualifies for exemption under Rule J Sc3-3 (k) (2) (i). {16}------------------------------------------------ - - ------------------- BRIAN W. ANSON *Certified fuh/ic ,Acco,mtalll* 18455 Burbank Bhd .• Suitc-404. Tarzana, CA 91356 • Tel. (818} 636-5660 • Fax (818) 881-2605 #### 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 accompany ing Exemption Report in which (I) Bardi Co .. LLC. identified the following provisions of 17 C.F.R. § I 5c3-3(k) under which Bardi Co .. LLC claimed an exemption from 17 C.F.R. §240. l Sc3-3: (k) (2) (i) (the .. exemption provisions") and (2) Bardi Co., LLC. stated that Bardi Co., LLC, met the identified exemption provisions throughout the most recent fiscal year w ithout exception. Burdi 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 re, iew 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 Ruic I 5c3-3 under the Securities Exchange Act of 1934. ' Br�!:1 Certified Public Accountant Tarzana. California January 19. 2021 {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) January 19, 2021 Re: SEA Rule 17a-5(d) (4) Exemption Report Pursuant to the referenced rule, the following information is provided. Under its membership agreement with FINRA and pursuant to Rule 15c3-3, 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, l 5c3-3 (k) (2) (i) exemption for the year 2020. Sincerely, Christiano Manfre' Managing Director and FinOp 633 5t.1, SIT\.-ct. Floor 26 Los Angeles. C'A '10071 I': 32:\-•}77-W60 I·: *t. 17.* 774-1 }26 inf.Ya h.11J11:o.cl1m Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.