# NPM SECURITIES, LLC X-17A-5 (2025-03-03) — Broker-dealer annual report - Company: NPM SECURITIES, LLC - Form: X-17A-5 - Filed: 2025-03-03 - Period: 2024-12-31 - Accession: 0001580825-25-000001 - CIK: 1580825 - File #: 8-69312 - Type: Broker-dealer - Material weakness: No - Auditor: Citron Cooperman & Company, LLP - Auditor location: Florham Park, NJ - Contact: Christopher Setaro - Phone: 646.968.7064 - Email: lati.afonja@npm.com - Website: npm.com - Signed by: Christopher Setaro (Chief Compliance Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1580825/000158082525000001/npms_audited_public.pdf --- {0}------------------------------------------------ #### FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION NPM Securities, LLC Year Ended December 31, 2024 With Report of Independent Registered Public Accounting Firm (Confidential Pursuant to Rule 17a-5(e)(3)) (SEC I.D. No.8-69312) {1}------------------------------------------------ ## Financial Statements and Supplemental Information Year Ended December 31, 2024 ## Contents | Facing Page and Oath or Affirmation | | |----------------------------------------------------------------------------------------|--| | Report of Independent Registered Public Accounting Firm | | | Financial Statements | | | Statement of Financial Condition | | | Statement of Operations | | | Statement of Changes in Member's Equity | | | Statement of Cash Flows | | | Notes to Financial Statements | | | Supplemental Information | | | Schedule I - Computation of Net Capital Pursuant to | | | Uniform Net Capital Rule 15c3-1 | | | Schedule 11 - Computation for Determination of Reserve Requirements Pursuant to | | | SEC Rule 15c3-3 | | | Schedule III - Information Relating to Possession or Control of Securities Pursuant to | | | SEC Rule 15c3-3 | | {2}------------------------------------------------ 5+\$4`1431` 150\$4&1`+`9"+ `-)\*\$11\$-+` 7;XBCNA[RO` ` ` **@ !%@ @;0(+4@ - @ ?3.4+8@2=@ @ @ 89/0&:+)@&>+4',+@(<5\*+1@ -2<68@3+4@7+83218+@ @** #### **- --** | | #@@\$"@ | |--|---------| - **"& +!("+("\$('+' +(\$+\*+-+++(#+'+("'%+)+ '+ + +** %'&,!`.0`4#`/0%.`!&,,%,!`**---** ,`,&,!`**-** -- -- #### ,\*`S`&0)` 3/+"."--33 4:/`.`0!%240,4`=B?=I`;LM`;UULE=;?;K?W` `2?=\WDY\_<;X?>`X];U`>?;L?V` `\*;HTW`X?=\WEZ\_<;X?>`X];U`U;WZE=FU;OZ` m 73.@m73U3m84mU3ZRQL23O\m8Zm)AZQm)Mm &m23V9c)\9c3Zm23)B3Vm 022`.`/0%,&/(`/'`.`62&,22`T`PTY`\X?`;`/ .``EQ`ZBGX`@ELEQA`
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8\hm | \$\)\3m | (8RmQ23m | | | 3 | 3 | | | | | )\3mQ4m#368Z\V)]8QLme8]7m! 94m)RRC:.)+C3m | ! m#368Z\U)\8QOm`J+3Vm84m)RRC8.)+D3m | | | | | | | | | | | | | | | | k C)8JZm4QXm3g3JR\8QMm4VQJm]73mU3Sa8V3J3M\m\7)\m\73m)OL\_)DmU3RQV\Zm+3m.Qc3U32m+hm\73mV3RQV\ZmQ4m)Lm8L23R3O23M^mR\_+A8. )..Q\_M\)M^mJ\_Z\m+3mZ\_RRQY^32m+im)mZ\)]3J3M\mQ4m4)/\Zm)L2m/8V0\_JZ^)O/3ZmV3E832mQNm)Zm\73m,)Z8ZmQ4m\73m3g3JR^;QL m \$33m #m )l%3F88m4m)RRD80)+G3 "3U[QO[mf7Qm\*U3m]QmU3[RQO2m]Qm]73m.QDC31[m5QUKm\*U3mOQ]mU3Tb\*\* 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. {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) ### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member and Management NPM Securities, LLC #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of NPM Securities, LLC as of December 31, 2024, and the related statements of operations, 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 our opinion, the financial statements present fairly, in all material respects, the financial position of NPM Securities, LLC as of December 31, 2024, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** These financial statements are the responsibility of NPM Securities, LLC's management. Our responsibility is to express an opinion on NPM Securities, LLC's financial statements 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 NPM Securities, 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 statements are 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 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. 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 statements. We believe that our audit provides a reasonable basis for our opinion. {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) #### **Auditor's Report on Supplemental Information** The supplemental information contained in Schedules I, II and III has been subjected to audit procedures performed in conjunction with the audit of NPM Securities, LLC's financial statements. The supplemental information is the responsibility of NPM Securities, LLC's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a–5. In our opinion, the supplemental information contained in Schedules I, II and III is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as NPM Securities, LLC's auditor since 2021. Florham Park, New Jersey March 3, 2025 {6}------------------------------------------------ ## Statement of Financial Condition December 31, 2024 | Assets | | | |-------------------------------------------|---|-----------| | Cash | ಕ | 4,938,786 | | Cash segregated under federal regulations | | 633,083 | | Interest receivable | | 63,616 | | Accounts receivable, net | | 865,723 | | Prepaid and other assets | | 60,141 | | Total assets | S | 6,561,349 | | Liabilities and member's equity | | | | Liabilities: | | | | Accounts payable | S | 337,022 | | Due to Parent | | 20,000 | | Due to customer | | 633,083 | | Total liabilities | | 990,105 | | Member's equity | | 5,571,244 | | Total liabilities and member's equity | | 6,561,349 | | | | | {7}------------------------------------------------ ## Statement of Operations Year Ended December 31, 2024 | Revenues | | |---------------------------------------------|-----------------| | Transaction fees | 13,592,128
A | | Interest | 2,452,277 | | Total revenues | 16,044,405 | | Expenses | | | Expense Sharing costs | 6,916,503 | | Computer operations and data communications | 27,327 | | Professional services | 111,300 | | Regulatory fees | 89,560 | | General and administrative expenses | 250,063 | | Total expenses | 7,394,753 | | Interest income | (175,989) | | Net income | ಕೊ
8,825,641 | | | | {8}------------------------------------------------ ## Statement of Changes in Member's Equity Year Ended December 31, 2024 Balance at December 31, 2023 Distribution Net income Balance at December 31, 2024 | S | 4,245,603 | |---|-------------| | | (7,500,000) | | | 8,825,641 | | | 5,571,244 | {9}------------------------------------------------ ## Statement of Cash Flows ### Year Ended December 31, 2024 | Operating activities | | | |-------------------------------------------------------------------------|---|-------------| | Net income | S | 8,825,641 | | Changes in operating assets and liabilities: | | | | Accounts receivable, net | | (171,455) | | Interest receivable | | (14,721) | | Due to Parent | | 15,381 | | Prepaid and other assets | | (10,252) | | Accounts payable | | 265,932 | | Due to customer | | 612,379 | | Net cash provided by operating activities | | 9,522,905 | | Financing activities | | | | Distribution | | (7,500,000) | | Net cash used in financing activities | | (7,500,000) | | Net increase in cash and cash segregated under federal regulations | | 2,022,905 | | Cash and cash segregated under federal regulations at beginning of year | | 3,548,964 | | Cash and cash segregated under federal regulations at end of year | S | 5,571,869 | | Supplemental Disclosure: | | | | Interest income received during the year ended December 31, 2024 | S | 2,628,266 | | Cash | S | 4,938,786 | | Cash segregated under federal regulations | | 633,083 | | Total Cash and cash segregated under federal regulations at end of year | | 5,571,869 | | | | | {10}------------------------------------------------ ### Notes to Financial Statements Year Ended December 31, 2024 ### 1. Organization and Description of the Business NPM Securities, LLC ("NPMS" or the "Company") was formed under laws of the State of Delaware on May 1, 2013. The Company is registered as an introducing broker-dealer and alternative trading system ("ATS") with the Securities and Exchange Commission ("SEC"). The Company is a member of Financial Industry Regulatory Authority ("FINRA") and Securities Investor Protection Corporation ('SIPC''). The Company is subject to regulation by the SEC, FINRA, and state securities regulators. NPMS is a wholly owned subsidiary of Nasdaq Private Market, LLC formerly Copeland Markets LLC ("NPM" or the "Parent"). The ATS facilitates primary and secondary transactions in private unregistered securities (i.e., securities not listed on registered securities exchange and not registered under Section 12 of the Securities Exchange Act of 1934) ("Exchange Act") whether domiciled in the U.S. or outside of the U.S. ("Private Company Product Line"). The ATS will utilize various price discovery and execution mechanisms, such as structured liquidity programs (liquidity programs in which issuers connect purchasers of equity securities with their existing stockholders and/or optionees that are identified or approved by the issuers) in the form of company buy backs, third-party tender offers, or auctions; one-off secondary transactions; primaries and subscriptions with respect to its provided, however, that the Company will not serve as an underwriter to any issuer. The Company is not a member of any securities depositories or clearing corporations, and does not maintain brokerage accounts or maintain custody of any securities. The Company may receive securities, but will promptly transmit them to the issuer or its transfer agent. The issuer, its transfer agent, or other corporate record keeper will provide the buyer with a stock certificate in either physical or book entry form. The Company manages and operates its business as one reportable segment. ### 2. Summary of Significant Accounting Policies ### Basis of Presentation The financial statements are prepared in accordance with accounting principles generally accepted in the United States ("U.S. GAAP"), as codified in the Accounting Standards Codification and set forth by the Financial Accounting Standards Board ("FASB"). {11}------------------------------------------------ ### Notes to Financial Statements (continued) Year Ended December 31, 2024 #### Use of Estimates The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts and the disclosure of contingent amounts in the financial statements and accompanying notes. Actual results could differ from those estimates and assumptions. #### Allowance for Credit Losses For financial assets measured at amortized cost (e.g., cash and receivables), the Company has concluded that there are de minimis expected credit losses based on the nature and contractual life or expected life of the financial assets and de minimis historic and expected losses. #### Cash The Company considers short-term investments with initial maturities of three months or less from the date of purchase to be cash equivalents. The Company held no cash equivalents at December 31, 2024. The Company's cash is held by one financial institution which, at times, may exceed federally insured limits. At December 31, 2024, the Company had cash of \$4,938,786. #### Cash Segregated Under Federal Regulations Pursuant to the exemptive provisions of sub-paragraph (k)(2)(i) of SEC Rule 15c3-3, the Company is permitted to hold customer funds received in connection with privately negotiated securities transactions in anticipation of settlement. At December 31, 2024, the Company held \$633,083 of customer funds in a special account for the exclusive benefit of customers of NPM Securities, LLC. #### Revenues Substantially all the Company's revenues are considered to be revenues from contracts with customers. The Company does not have obligations for warranties, returns or refunds to customers. For the contracts with the Company's customers, the Company's performance obligations are short-term in nature and there is no significant variable consideration. The Company does not provide disclosures about transaction price allocated to unsatisfied performance obligations if contract durations are less than one year. The Company's primary business is facilitating transactions for private equity assets, providing both buyers and sellers access to liquidity through a controlled marketplace. Transaction fees {12}------------------------------------------------ ## Notes to Financial Statements (continued) Year Ended December 31, 2024 ### Revenues (continued) comprises Platform, Trading & Other Revenue. Trading Revenue is typically recognized on the settlement date of the transaction, which is when the performance obligation is complete. Platform Revenue (Tender Offer and Buyback) is recognized pro-rata over the period from program launch to settlement. ### Segment Reporting Effective January 1, 2024 the Company adopted the provisions of ASU No.2023-07 Segment Reporting (Topic 280) Improvements to Reportable Segment Disclosures ("ASU 2023-07"). ASU 2023-07 improves reportable segment disclosure requirements primarily through enhanced disclosures about significant segment expenses. The Company is required to provide all annual disclosures about reportable segment profit or loss and assets as required by ASU 2023-07 for interim periods. In accordance with ASU 2023-07, the Company is required to disclose significant segment expenses that are regularly provided to the Chief Operating Decision Maker ("CODM") and included within each reported measure of segment profit or loss, an amount for other segment items including a description of the composition. Additionally, ASU 2023-07 requires the Company to disclose the title and position of the CODM along with an explanation of how the CODM uses reported measures of segment profit or loss in assessing segment performance and deciding how to allocate resources. ASU 2023-07 also requires the Company to clarify if the CODM uses more than one measure of a segment's profit or loss in assessing segment performance and deciding how to allocate resources. ### Income Taxes The Company is a single-member limited liability company and is not subject to federal and state and local income taxes. The Company's operating results are included in the federal, state and local income tax returns filed by the Parent, a U.S. partnership pursuant to U.S. Income Tax Regulations Sec. 301.7701-3(b)(1)(ii). ### 3. Related-Party Transactions The Parent agrees to provide the Company with support services, including, but not limited to, direct financial and business management support, compliance and reporting support, information technology support, legal services, occupancy and human resource services. Included in Expense {13}------------------------------------------------ ### Notes to Financial Statements (continued) Year Ended December 31, 2024 #### 3. Related-Party Transactions (continued) Sharing costs on the Statement of Operations are the expense related to these support services, which were \$6,916,503 for the year ended December 31, 2024. At December 31, 2024, \$20,000 was recorded as Due to Parent on the Statement of Financial Condition. It is the intent and ability of management to settle all intercompany balances between the Parent and the Company on a net basis. The Company records all transactions to and from the Parent subject to the expense sharing arrangement. #### 4. Income Taxes The Company's operating results will be included in the federal and state income tax returns filed by the Parent, Nasdaq Private Market, LLC, a U.S. partnership pursuant to U.S. Income Tax Regulations Sec. 301.7701-3(b)(1)(ii). #### 5. Revenues The following table presents the Company's total revenues for the year ended December 31, 2024: | Total Revenue | \$16,044,405 | |------------------|--------------| | Interest | 2.452.277 | | Other revenue | 432,232 | | Trading revenue | 5.924,635 | | Platform revenue | \$ 7,235,261 | | Revenue | | #### 6. Segment Reporting The Company is registered as an introducing broker-dealer and ATS with the SEC. The Company has identified its Chief Executive Officer as the Chief Operating Decision Maker ("CODM"), who uses net income to evaluate the results of the business, predominately in the forecasting process, to manage the Company. Additionally, the CODM uses the excess net capital, which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or make capital distributions. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using the information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as described in the summary of significant accounting policies (see Note 2). {14}------------------------------------------------ ### Notes to Financial Statements (continued) Year Ended December 31, 2024 #### 6. Segment Reporting (continued) The following table presents the segment revenue and significant expenses for the year ended December 31, 2024 | Revenue | | 16,044,405 | |---------------------------------------------|---|------------| | Less: | | | | Expense Sharing costs | | 6,916,503 | | Computer operations and data communications | | 27,327 | | Professional services | | 111,300 | | Regulatory fees | | 89,560 | | General and administrative expenses | | 250,063 | | Total expenses | | 7,394,753 | | Interest income | | (175,989) | | Net income | S | 8,825,641 | The operating segment's asset for the year ended December 31, 2024 is \$6,561,349 #### 7. Regulatory Requirements The Company is a registered broker-dealer with the SEC and, accordingly, is subject to the SEC's Uniform Net Capital Rule ("SEC Rule 15c3-1"). The Company calculates its excess net capital under the alternative basic method. At December 31, 2024, the Company had net capital of \$4,645,380, which was \$4,395,380 in excess of its required net capital of \$250,000. The Company is exempt from the provisions of Rule 15c3-3 pursuant to the exemptive provisions under sub-paragraph (k)(2)(i). The Company does not hold customer funds or safekeep customer securities. The Company is permitted to receive customer funds in connection with privately negotiated securities transactions in anticipation of settlement. The Company maintains a "Special Account for the Exclusive Benefit of Customers of NPM Securities, LLC" for such customer funds received. Member distributions are subject to certain notification and other requirements of SEC Rule 15c3-1 and other regulatory bodies. {15}------------------------------------------------ ## Notes to Financial Statements (continued) Year Ended December 31, 2024 ### 8. Commitments and Contingent Liabilities ### General Litigation and Regulatory Matters The Company may be subject to claims as well as reviews by self-regulatory agencies arising out of the conduct of its business. Management is not aware of any unasserted claims or assessments that would have a material adverse effect on the financial position and the results of operations of the Company. ### Risks and Uncertainties Cash is held by one financial institution. In the event that the financial institution is unable to fulfill its obligations, the Company would be subject to credit risk. The balances are insured by the Federal Deposit Insurance Corporation up to \$250,000. Bankruptcy or insolvency may cause the Company's rights with respect to the cash held to be delayed or limited. ### 9. Fair Value of Financial Instruments The Company's financial assets and financial liabilities are recorded at fair value or at amounts that approximate fair value. The carrying amounts reported on the Statement of Financial Condition for cash, cash segregated, accounts receivable, interest receivable and prepaid and other assets approximate fair value due to the short term nature of these assets. The Company's liabilities, which include accounts payable, due to parent and due to customer are reported at their contractual amounts, which approximate fair value. ### 10. Subsequent Events The Company has performed an evaluation of events that have occurred subsequent to December 31, 2024, and through March 3, 2025, the date of the filing of this report. There have been no material subsequent events that occurred during such period that would require disclosure in this report or would be required to be recognized in the financial statements as of December 31, 2024. {16}------------------------------------------------ Supplemental Information {17}------------------------------------------------ # Schedule I NPM Securities, LLC Computation of Net Capital Pursuant to Uniform Net Capital Rule 15c3-1 December 31, 2024 ಕಿತ 5,571,244 Member's equity 925,864 Total non-allowable assets 4,645,380 Net capital Less minimum capital required 250,000 ക 4,395,380 Net capital in excess of minimum requirement No material differences exist between the above computation of net capital and the computation of net capital included in the Company's corresponding unaudited Form X-17A-5, filing as of December 31, 2024. {18}------------------------------------------------ Schedule II ## NPM Securities, LLC ### Computation for Determination of Reserve Requirements ## Pursuant to SEC Rule 15c3-3 ### December 31, 2024 The Company is exempt from SEC Rule 15c3-3 pursuant to sub-paragraph (k)(2)(i). The Company does not hold customer funds or safekeep customer securities. The Company is permitted to hold the customer funds received in connection with privately negotiated securities transactions in anticipation of settlement. The Company maintains "Special Account for the Exclusive Benefit of Customers of NPM Securities LLC" for such customer funds received. {19}------------------------------------------------ #### Schedule III ## NPM Securities, LLC ### Information Relating to Possession or Control of Securities ### Pursuant to SEC Rule 15c3-3 ## December 31, 2024 The Company is exempt from the possession or control requirements under paragraph (k)(2)(i) of Rule 15c3-3 of the Securities Exchange Act of 1934. {20}------------------------------------------------ ![](_page_20_Picture_0.jpeg) #### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member and the Management NPM Securities, LLC We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) NPM Securities, LLC identified the following provisions of 17 C.F.R. §15c3-3(k) under which NPM Securities, LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (k(2)(i)) (the "exemption provisions") and (2) NPM Securities, LLC stated that NPM Securities, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. NPM Securities, LLC's management is responsible for compliance with the exemption provisions and its statements. Our 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 NPM Securities, LLC's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are aware of two material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k(2)(i)) of Rule 15c3-3 under the Securities Exchange Act of 1934. The two material modifications relate to the following omitted exceptions: (a) The account title "NPM Securities, LLC FBO Exclusive Benefit of End Customer " appeared to be inconsistent with the provisions of 17 C.F.R. § 240.15c3-3(k)(2)(i) which explicitly requires that the name of the account be "Special Account for the Exclusive Benefit of Customers in the name of the Company"; (b) As a result of an operational process where customer funds were withdrawn from the "Special Account for the Exclusive Benefit of Customers of NPM Securities LLC" and into a money market mutual fund subjecting the customer funds to potential market losses and outside of FDIC insurance protections. Florham Park, New Jersey March 3, 2025 {21}------------------------------------------------ ![](_page_21_Picture_1.jpeg) 3 East 28th Street 7th Floor New York, NY 10016 / USA www.nasdaqprivatemarket.com #### **NPM Securities, LLC's Exemption Report** NPM Securities, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following: - (1) The Company claimed an exemption from 17 C.F.R. § 240.15c3-3 under the following provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(i); and - (2) The Company believed it met the identified exemption provisions in 17 C.F.R. § 240.15c3-3(k) throughout the most recent fiscal year without exception1 . I, Latifat Afonja, affirm that, to my best knowledge and belief, this Exemption Report is true and correct. ![](_page_21_Picture_9.jpeg) Latifat Afonja Principal Financial Officer NPM Securities, LLC \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ **3/3/2025** Date 1 The staff of the U.S. Securities and Exchange Commission (the "Staff") completed an examination of the Company on February 25, 2025. The Staff found that the Company did not avail itself from the exemptive provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(i) as a result of an operational process where customer funds were withdrawn from the "Special Account for the Exclusive Benefit of Customers of NPM Securities LLC" and into a money market mutual fund subjecting the customer funds to potential market losses and outside of FDIC insurance protections. Additionally, the Staff found that account title, "NPM Securities, LLC FBO Exclusive Benefit of End Customer", appeared to be inconsistent with the provisions of 17 C.F.R. § 240.15c3-3(k)(2)(i) which explicitly requires that the name of the account be "Special Account for the Exclusive Benefit of Customers of NPM Securities LLC". Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.