# ACCORD CAPITAL PARTNERS LLC X-17A-5 (2023-03-01) — Broker-dealer annual report

- Company: ACCORD CAPITAL PARTNERS LLC
- Form: X-17A-5
- Filed: 2023-03-01
- Period: 2022-12-31
- Accession: 0001565138-23-000001
- CIK: 1565138
- File #: 8-69217
- Type: Broker-dealer
- Material weakness: No
- Auditor: Armanino LLP
- Auditor location: San Francisco, CA
- Contact: Bryan Hunt
- Phone: 415-412-6486
- Email: bhunt@accord-group.net
- Website: accord-group.net
- Signed by: Bryan Hunt (CFO)

Original filing: https://www.sec.gov/Archives/edgar/data/1565138/000156513823000001/accord22pub2.pdf

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# PUBLIC **UNITED STATES**

**SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 

0MB APPROVAL 0MB Number: 3235-0123 Expires: Oct. 31, 2023 Estimated average burden hours per response: 12

## **ANNUAL REPORTS FORM X-17A-5 PART** Ill

| SEC FILE NUMBER |  |
|-----------------|--|

8-69217

**FACING PAGE** 

**Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934** 

| FILING FOR THE PERIOD BEGINNING 01/01/22                                                                                                                                                                                                         | ----------                                                 | AND ENDING                              | 12/31/22        | -----------                                  |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|-----------------------------------------|-----------------|----------------------------------------------|
|                                                                                                                                                                                                                                                  | MM/DD/VY                                                   |                                         |                 | MM/DD/VY                                     |
|                                                                                                                                                                                                                                                  | A. REGISTRANT IDENTIFICATION                               |                                         |                 |                                              |
| NAME OF FIRM: Accord Capital Partners LLC                                                                                                                                                                                                        |                                                            |                                         |                 |                                              |
| TYPE OF REGISTRANT (check all applicable boxes):<br>IKl Broker-dealer<br>□ Check here if respondent is also an OTC derivatives dealer                                                                                                            | □ Security-based swap dealer                               | □ Major security-based swap participant |                 |                                              |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                                                                                                                              |                                                            |                                         |                 |                                              |
| 240 Stockton Street, 7th Floor                                                                                                                                                                                                                   |                                                            |                                         |                 |                                              |
|                                                                                                                                                                                                                                                  | (No. and Street)                                           |                                         |                 |                                              |
| San Francisco                                                                                                                                                                                                                                    | CA                                                         |                                         |                 | 94108                                        |
| (City)                                                                                                                                                                                                                                           | (State)                                                    |                                         |                 | (Zip Code)                                   |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                                                                                                     |                                                            |                                         |                 |                                              |
| Bryan Hunt                                                                                                                                                                                                                                       | (415) 412-6486                                             | bhunt@accord-group.net                  |                 |                                              |
| (Name)                                                                                                                                                                                                                                           | (Area Code - Telephone Number)                             |                                         | (Email Address) |                                              |
|                                                                                                                                                                                                                                                  | B. ACCOUNTANT IDENTIFICATION                               |                                         |                 |                                              |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*<br>Armanino LLP                                                                                                                                                        |                                                            |                                         |                 |                                              |
|                                                                                                                                                                                                                                                  | (Name - if individual, state last, first, and middle name) |                                         |                 |                                              |
| 12657 Alcosta Blvd. Suite 500                                                                                                                                                                                                                    | San Ramon                                                  | CA                                      |                 | 94583                                        |
| (Address)                                                                                                                                                                                                                                        | (City)                                                     | (State)                                 |                 | (Zip Code)                                   |
| 10/20/2003                                                                                                                                                                                                                                       |                                                            | 32                                      |                 |                                              |
| rte<br>of Regist,atlo, with PCAOB)(lf applicable)                                                                                                                                                                                                |                                                            |                                         |                 | (PCAOB Reglstratlo, N,mbe,, If applicable) I |
| * Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public<br>accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 | FOR OFFICIAL USE ONLY                                      |                                         |                 |                                              |

CFR 240.17a-S(e)(l)(ii), if applicable. **Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** 

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#### **OATH OR AFFIRMATION**

| I,     | Bryan Hunt                                                                                                                                                                                                                                                                                    | , swear (or aH\irm) that, to the best of my knowledge and belief, the                                                                                                                                           |  |  |  |
|--------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|--|
|        | financial report pertai ing to the firm of                                                                                                                                                                                                                                                    | , as of<br>Accord Capital Partners LLC                                                                                                                                                                          |  |  |  |
|        | December 31<br>,                                                                                                                                                                                                                                                                              | 2~,<br>is true and correct. I fu'rther swear (or affirm) that neither the company nor any                                                                                                                       |  |  |  |
|        | as tha .cafo111~111t , r-~cer_~~tfhls·ce~ate veti!le~ only<br>Identity of th~ lndlwld1 al whO slpdit~e document to ~hlch .th_lJ tertlflcate•.<br>Is attached, and not. t e truthfulness, acgira~, or·_validlty o_ f that document.<br>~ ·<br>· ··<br>· ·• ·<br>· "''                          | 5~<br>pa'!'tner officer, director, or equivalent persq.r, as the case may be, ha1s any proprietary interest in any account classified solely<br>~/_~<br>.the<br>\<br>5.<br>· · •.•<br>· ·<br>Ignature:          |  |  |  |
|        | County of<br>•.<br>I<br><br>. ,<br>Subscribed and swor!' ~ -(or affirl'_t\ed) before me on this ~r-!:J<br>, 2ola., by<br>·<br>of                                                                                                                                                              | -----,~=--1---1-~<br>--~--------<br>----=--,11----------<br>-.-1<br>t'J~ 1 I<br>c_ FCJ<br>Tit e:<br>day<br>BJlldan HvW:                                                                                         |  |  |  |
|        | u                                                                                                                                                                                                                                                                                             | 1••••••• •• •••·<br>I                                                                                                                                                                                           |  |  |  |
|        | Notary Public                                                                                                                                                                                                                                                                                 | :<br>'' ~. Not~~liu~ii~~~~~~:rnia<br>i<br>ed toa:~ t:,~,: ~:i.s<br>~                                                                                                                                            |  |  |  |
|        | This fij;\nrli;* contai<br>~' (a) ~tat~~;;:e~n;;:t-;o;TT;;;-::;j;;,:,~;,;::;;:;;:.,-r.,::-"1'--------                                                                                                                                                                                         | !<br>i "<br>San Francl,co County<br>~<br>:<br>,<br><br>,<br>-<br>Comm1ss1on I/ 2380962<br>"•,,•c _,► My Comni, Expires 'lov 13 , 2025<br>(Seal)<br>;-                                                           |  |  |  |
|        | ~ (b) Notes to consolid ted statement of financial condition.                                                                                                                                                                                                                                 |                                                                                                                                                                                                                 |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (c) Statement of incd\me (loss) or, if there is other comprehensive inc6me in the period(s) presented, a statement of<br>I                                                                                      |  |  |  |
|        | comprehensive inco f e (as defined in§ 210.1-02 of Regulation S-X).                                                                                                                                                                                                                           |                                                                                                                                                                                                                 |  |  |  |
| D      | (d) Statement of cas~ flows.                                                                                                                                                                                                                                                                  |                                                                                                                                                                                                                 |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (e) Statement of cha~ges in stockholders' or partners' or sole proprietor's equity.                                                                                                                             |  |  |  |
| D      | (f) Statement of cha ~ges in liabilities subordinated to claims of creditbrs.                                                                                                                                                                                                                 |                                                                                                                                                                                                                 |  |  |  |
| D      | (g) Notes to consolid~ted financial statements.                                                                                                                                                                                                                                               | \                                                                                                                                                                                                               |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.<br>I                                                                                                                 |  |  |  |
| D      | (i) Computation of ta I gible net worth under 17 CFR 240.18a-2.                                                                                                                                                                                                                               |                                                                                                                                                                                                                 |  |  |  |
| 0<br>D | (j) Computation for drermination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.<br>(k) Computation for ~:termination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or<br>Exhibit A to 17 CFR Zf0.18a-4, as applicable. |                                                                                                                                                                                                                 |  |  |  |
| D      | (I) Computation for ~etermination of PAB Requirements under Exhibiit A to§ 240.15c3-3.                                                                                                                                                                                                        |                                                                                                                                                                                                                 |  |  |  |
| D      | ing to possession or control requirements for customers under 17 CFR 240.15c3-3.                                                                                                                                                                                                              |                                                                                                                                                                                                                 |  |  |  |
| D      | (m) Information rela 1<br>(n) Information relati g to possession or control requirements for security-based swap customers under 17 CFR<br>I                                                                                                                                                  |                                                                                                                                                                                                                 |  |  |  |
| D      | 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable.                                                                                                                                                                                                                                          | (o) Reconciliations, in1 luding appropriate explanations, of the FOCUS Report with computation of net capital or tangible net                                                                                   |  |  |  |
|        | CFR 240.15c3-3 or 17 FR 240.18a-4, as applicable, if material differe~                                                                                                                                                                                                                        | worth under 17 CFR -40.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17<br>ces exist, or a statement that no material differences                            |  |  |  |
|        | exist.                                                                                                                                                                                                                                                                                        | 1                                                                                                                                                                                                               |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (p) Summary of finan · ial data for subsidiaries not consolidated in the statement of financial condition.                                                                                                      |  |  |  |
| IXI    | (q) Oath or affirmatiom in accordance with 17 CFR 240.17a-5, 17 CFR 2f 0.17a-12, or 17 CFR 240.18a-7, as applicable.                                                                                                                                                                          |                                                                                                                                                                                                                 |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (r) Compliance report n accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.                                                                                                                    |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (s) Exemption report i i accordance with 17 CFR 240.17a-5 or 17 CFR 2f 0.18a-7, as applicable.                                                                                                                  |  |  |  |
|        |                                                                                                                                                                                                                                                                                               | ~ (t) Independent publi1 accountant's report based on an examination of the statement of financial condition.                                                                                                   |  |  |  |
|        | D (u) Independent publiI<br>CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. \                                                                                                                                                                                           | , accountant's report based on an examination of the financial report or financial statements under 17                                                                                                          |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (v) Independent publi accountant's report based on an examination of certain statements in the compliance report under 17<br>I                                                                                  |  |  |  |
|        | CFR 240.17a-5 or 17 CfR 240.18a-7, as applicable.                                                                                                                                                                                                                                             |                                                                                                                                                                                                                 |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (w) Independent publ \t accountant's report based on a review of thee emption report under 17 CFR 240.17a-5 or 17                                                                                               |  |  |  |
|        | CFR 240.18a-7, as appl1<br>icable.                                                                                                                                                                                                                                                            |                                                                                                                                                                                                                 |  |  |  |
| D      | as applicable.                                                                                                                                                                                                                                                                                | (x) Supplemental repo ts on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12,                                                                                        |  |  |  |
| D      |                                                                                                                                                                                                                                                                                               | (y) Report describing a y material inadequacies found to exist or foun to have existed since the date of the previous audit, or<br>a statement that no m terial inadequacies exist, under 17 CFR 240.17a 12(k). |  |  |  |
| D      | (z) Other:                                                                                                                                                                                                                                                                                    | ----+-----------------+------------------                                                                                                                                                                       |  |  |  |

<sup>\*\*</sup>To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3} or 17 CFR 240.18a-7{d)(2}, as applicable.

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## **Accord Capital Partners LLC**

Statement of Financial Condition

December 31, 2022

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#### TABLE OF CONTENTS

|                                                         | Page No. |
|---------------------------------------------------------|----------|
| Report of Independent Registered Public Accounting Firm | 1        |
| Statement of Financial Condition                        | 2        |
| Notes to Financial Statement                            | 3-5      |

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![](_page_4_Picture_0.jpeg)

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Accord Capital Partners LLC San Francisco, California

#### **Opinion on the Financial Statement**

We have audited the accompanying statement of financial condition of Accord Capital Partners LLC as of December 31, 2022 and the related notes ( collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of Accord Capital Partners LLC as of December 31, 2022 in conformity with accounting principles generally accepted in the United States of America.

#### **Basis for Opinion**

This financial statement is the responsibility of Accord Capital Partners LLC's management. Our responsibility is to express an opinion on Accord Capital Partners LLC's financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to Accord Capital Partners 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.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion.

ArmaninoLLP San Francisco, California

We have served as Accord Capital Partner LLC's auditor since 2013. February 27, 2023

![](_page_4_Picture_11.jpeg)

Global Network Limited

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### ACCORD CAPITAL PARTNERS LLC Statement of Financial Condition December 31, 2022

#### ASSETS

| Assets                                |              |
|---------------------------------------|--------------|
| Cash and cash equivalents             | 43,421<br>\$ |
| Accounts receivable                   | 2,032,187    |
| Prepaid expenses and other assets     | 860          |
| Total assets                          | \$ 2,076,468 |
| LIABILITIES AND MEMBER'S EQUITY       |              |
| Liabilities                           |              |
| Accounts payable                      | 27,222<br>\$ |
| Total liabilities                     | 27,222       |
| Member's equity                       | 2,049,246    |
| Total liabilities and member's equity | \$ 2,076,468 |

The accompanying notes are an integral part of these financial statements.

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#### ACCORD CAPITAL PARTNERS LLC Notes to Financial Statement December 31, 2022

#### 1. Nature of Business and Summary of Accounting Policies

#### Nature of business

Accord Capital Partners LLC (the "Company") is a Delaware limited liability company formed on October 31, 2012. The Company was a single member limited liability company wholly owned by Milagro Group LLC ("Milagro"). On May 13, 2014, Accord Group Holdings LLC ("AGH") acquired Milagro's 100% interest in the Company. The Company is registered with the Securities and Exchange Commission as a fully disclosed broker-dealer and is a member of the Financial Industry Regulatory Authority ("FINRA"). The Company provides private placement and advisory services.

The Company receives support from AGH, an affiliated company, for such items as personnel salaries and benefits, accounting and information technology services, office equipment, and other miscellaneous overhead expenses (see Note 4). The financial results of the Company may have been significantly different absent this relationship with the affiliated company.

#### Accounts receivable

Accounts receivable consist of consulting and advisory fees receivable as well as sales commissions receivable and reimbursements for out-of-pocket expenses receivable from clients. The Company uses the allowance method to account for uncollectible accounts. Based on historical write-offs, overall economic conditions, and an evaluation of the current aging status of its receivables, the Company has established an allowance for doubtful accounts at a level considered to be adequate to cover anticipated credit losses on outstanding client receivables. Accounts are monitored by management on an ongoing basis and are written off by the Company when it has been determined that all available collection avenues have been exhausted. Bad debt recoveries are included in income as realized. As of December 31, 2022, management did not consider an allowance for doubtful accounts necessary as all balances were considered collectible.

#### Cash and cash equivalents

The Company classifies highly liquid investments with original maturities of three months or less as cash and cash equivalents. Cash and cash equivalents are held in major financial institutions. Periodically, such deposits may be in excess of federally insured limits.

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#### ACCORD CAPITAL PARTNERS LLC Notes to Financial Statement December 31, 2022

#### 1. Nature of Business and Summary of Accounting Policies (continued)

#### Income taxes

The Company is a limited liability company for federal and state income tax purposes. Under laws pertaining to income taxation of limited liability companies, no federal income tax is paid by the Company. The income or loss of the Company is taxed to the member in its respective return.

The Company evaluates its tax positions taken or expected to be taken in the course of preparing tax returns to determine whether the tax positions are "more-likely-than-not" of being sustained by the applicable tax authority. Tax positions not deemed to meet the "more-likely-than-not" threshold are recorded as an expense in the applicable year. As of December 31, 2022, the Company does not have any significant uncertain tax positions for which a reserve would be necessary.

#### 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.

#### Subsequent events

The Company has evaluated subsequent events through February 27, 2023, the date the financial statements were available to be issued. No subsequent events have occurred that would have a material impact on the presentation of the Company's financial statements.

#### 2. Net Capital Requirements

Pursuant to the net capital provisions of the U.S. Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule 15c3-l), the Company is required to maintain minimum net capital of the greater of \$5,000 or the ratio of aggregate indebtedness to net capital, as defined. The ratio of aggregate indebtedness ( as defined) to net capital shall not exceed 15 to 1. The rule of the "applicable" exchange also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1. Net capital and the related ratio of aggregate indebtedness to net capital may fluctuate on a daily basis.

As of December 31, 2022, the Company had net capital of \$16,199, which was \$11,199 in excess of its required net capital of \$5,000. Assets totaling \$2,033,047 were excluded from the calculation of the Company's net capital as they are classified as non-allowable assets. The Company's ratio of aggregate indebtedness to net capital was 168.05% as of December 31, 2022.

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#### ACCORD CAPITAL PARTNERS LLC Notes to Financial Statement December 31, 2022

#### 3. Exemption from Rule 15c3-3

The Company does not claim an exemption from Rule 15c3-3 of the U.S. Securities and Exchange Commission act of 1934, in reliance on footnote 7 4 to SEC Release 34-70073. The Company does not hold funds or securities for customers and it promptly transmits all funds and delivers all securities in connection with its activities as a broker or dealer.

#### 4. Expense Sharing Agreement

The Company receives support from an affiliated company for such items as personnel salaries and benefits, accounting and information technology services, office equipment and other miscellaneous overhead expenses. The Company is charged a monthly fee that is dependent upon the level of personnel support required by the Company; monthly fees were \$150,000 for the year ended December 31, 2022 for the Company's share of operating expenses under the expense sharing agreement, which totaled \$1.8 million for the year ended December 31, 2022.

#### 5. Concentrations

The Company had accounts receivable from one customer that accounted for approximately 100% of total accounts receivable as of December 31, 2022.


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