# ACCORD CAPITAL PARTNERS LLC X-17A-5/A (2024-06-25) — Broker-dealer annual report

- Company: ACCORD CAPITAL PARTNERS LLC
- Form: X-17A-5/A
- Filed: 2024-06-25
- Period: 2023-12-31
- Accession: 0001565138-24-000003
- CIK: 1565138
- File #: 8-69217
- Type: Broker-dealer
- Material weakness: No
- Auditor: Marcum
- Auditor location: San Francisco, CA
- Contact: Tricia Peterson
- Phone: 4156080242
- Email: tpeterson@accord-group.net
- Website: accord-group.net
- Signed by: Tricia Peterson (Managing Partner & Chief Operating Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1565138/000156513824000003/acp2023short.pdf

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UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

> ANNUAL REPORTS FORM X-17A-5 PART III

OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12

SEC FILE NUMBER 8-69217

| FACING PAGE<br>Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934                                                   |                                |                                            |                                                |            |  |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------|--------------------------------------------|------------------------------------------------|------------|--|
| AND ENDING 12/31/23<br>filing for the period beginning 01/01/23                                                                                                            |                                |                                            |                                                |            |  |
|                                                                                                                                                                            | MM/DD/YY                       |                                            |                                                | MM/DD/YY   |  |
| A. REGISTRANT IDENTIFICATION                                                                                                                                               |                                |                                            |                                                |            |  |
| NAME OF FIRM: Accord Capital Partners LLC                                                                                                                                  |                                |                                            |                                                |            |  |
|                                                                                                                                                                            |                                |                                            |                                                |            |  |
| TYPE OF REGISTRANT (check all applicable boxes):<br>  Major security-based swap participant<br>Broker-dealer<br>Check here if respondent is also an OTC derivatives dealer |                                |                                            |                                                |            |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                                                        |                                |                                            |                                                |            |  |
| 240 Stockton Street, 7th Floor                                                                                                                                             |                                |                                            |                                                |            |  |
|                                                                                                                                                                            | (No. and Street)               |                                            |                                                |            |  |
| San Francisco                                                                                                                                                              |                                | GA                                         |                                                | 94108      |  |
| (City)                                                                                                                                                                     |                                | (State)                                    |                                                | (Zip Code) |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                                                               |                                |                                            |                                                |            |  |
| Tricia Peterson                                                                                                                                                            |                                | 415-608-0242<br>tpeterson@accord-group.net |                                                |            |  |
| (Name)                                                                                                                                                                     | (Area Code - Telephone Number) |                                            | (Email Address)                                |            |  |
|                                                                                                                                                                            | B. ACCOUNTANT IDENTIFICATION   |                                            |                                                |            |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing"<br>Marcum                                                                                        |                                |                                            |                                                |            |  |
| (Name - if individual, state last, first, and middle name)                                                                                                                 |                                |                                            |                                                |            |  |
| 1 Montgomery St. Suite 1700 San Francisco                                                                                                                                  |                                |                                            | CA                                             | 9410       |  |
| (Address)                                                                                                                                                                  | (City)                         |                                            | (State)                                        | (Zip Code) |  |
| 10/16/2003                                                                                                                                                                 |                                | 688                                        |                                                |            |  |
| (Date of Registration with PCAOB)(if applicable)<br>(PCAOB Registration Number, it applicable)                                                                             |                                |                                            |                                                |            |  |
|                                                                                                                                                                            | FOR OFFICIAL USE ONLY          |                                            | suarad button ranarts of an indonomdant public |            |  |

Claims for exemption from the requirement that the annual reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(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 OMB control number.

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#### OATH OR AFFIRMATION

I. Tricia Peterson \_\_ swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of Accord Capital Partners LLC as of 12/31 , 2023 \_\_ is true and correct. I further swear (or affirm) that neither the company nor any

partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer.

See Attached Certificate

Tapin Put

Title: Managing Partner & Chief Operating Officer

Notary Public

#### This filing \*\* contains (check all applicable boxes):

- = (a) Statement of financial condition.
- [ (b) Notes to consolidated statement of financial condition.
- (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- (d) Statement of cash flows.
- = (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- [ (f) Statement of changes in liabilities subordinated to claims of creditors.
- (g) Notes to consolidated financial statements.
- (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.
- [ (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- □ (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- □ (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- [1) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- @ (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- [ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable.
- @ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- □ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- [ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- = (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- O (t) Independent public accountant's report based on an examination of the statement of financial condition.
- (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- [ (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- @ (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- | as applicable.
- [] (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).

[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 240.18c-7(d)(2), as applicable.

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| ACKNOWLEDGMENT                                                                                                                                                                                                                                                                                                                                                                                                                                            |  |  |  |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|--|
| A notary public or other officer completing this<br>certificate verifies only the identity of the individual<br>who signed the document to which this certificate is<br>attached, and not the truthfulness, accuracy, or<br>validity of that document.                                                                                                                                                                                                    |  |  |  |
| State of California<br>CONTRA COSTA<br>County of                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |  |
| PINAL KALPESH VAIDYA,NOTARY PUBLIC<br>before me,<br>(insert name and title of the officer)                                                                                                                                                                                                                                                                                                                                                                |  |  |  |
| PETERSON<br>PATRICIA<br>personally appeared<br>who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are<br>subscribed to the within instrument and acknowledged to me that he/she/they executed the same in<br>his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the<br>person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. |  |  |  |
| I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing<br>paragraph is true and correct.                                                                                                                                                                                                                                                                                                                         |  |  |  |
| PINAL KALPESH VAIDYA<br>Notary Public - California<br>Contra Costa County<br>WITNESS my hand and official seal.<br>Commission # 2462898<br>res Sep 12. 2027<br>(Seal)                                                                                                                                                                                                                                                                                     |  |  |  |
| Signature                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  |  |  |

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# **Accord Capital Partners LLC**

Statement of Financial Condition

December 31, 2023

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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_5_Picture_0.jpeg)

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

To the Member of **Accord Capital Partners LLC** 

#### *Opinion on the Financial Statement*

We have audited the accompanying statement of financial condition of Accord Capital Partners LLC ( the "Company") as of December 31, 2023, and the related notes ( collectively referred to as the "fmancial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31 , 2023 in conformity with accounting principles generally accepted in the United States of America.

#### *Basis for Opinion*

This financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on the Company'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 the Company 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. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audit, we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion.

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.

MarcumLLP

We have served as the Company's auditor since 2023.

San Francisco, California March 28, 2024

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

## ASSETS

| Assets                                |              |
|---------------------------------------|--------------|
| Cash and cash equivalents             | \$<br>43,421 |
| Accounts receivable                   | 2,032,187    |
| Prepaid expenses and other assets     | 860          |
| Total assets                          | \$ 2,076,468 |
| LIABILITIES AND MEMBER'S EQUITY       |              |
| Liabilities                           |              |
| Accounts payable                      | \$<br>27,222 |
| 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, 2023

## 1. Nature of Business and Summary of Significant 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 credit losses. Based on historical writeoffs, overall economic conditions, and an evaluation of the current aging status of its receivables, the Company has established an allowance for credit losses at a level considered to be adequate to cover anticipated lifetime 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. Recoveries are included in income as realized. As of December 31, 2023, management did not consider an allowance for credit losses necessary as all balances were considered collectible.

#### Cash

The Company maintains cash in a federally insurance banking institution. The Company may have cash in excess of federally insured limits but does not believe it is exposed to any significant credit risk.

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## ACCORD CAPITAL PARTNERS LLC Notes to Financial Statement December 31, 2023

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

#### Income taxes

The Company is a single-member 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, 2023, 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 March 28, 2024, the date the financial statements were 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, 2023, the Company had net capital of \$41,819, which was \$36,819 in excess of its required net capital of \$5,000. Assets totaling \$1,629,937 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 155.92% as of December 31, 2023.

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## ACCORD CAPITAL PARTNERS LLC Notes to Financial Statement December 31, 2023

## 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 \$50,000 for the year ended December 31, 2023 for the Company's share of operating expenses under the expense sharing agreement, which totaled \$600,000 for the year ended December 31, 2023.

#### 5. Concentrations

The Company had accounts receivable from two customers that accounted for approximately 100% of total accounts receivable as of December 31, 2023.


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