# VERITAS INDEPENDENT PARTNERS, LLC X-17A-5 (2022-03-31) — Broker-dealer annual report

- Company: VERITAS INDEPENDENT PARTNERS, LLC
- Form: X-17A-5
- Filed: 2022-03-31
- Period: 2021-12-31
- Accession: 0001588116-22-000003
- CIK: 1588116
- File #: 8-69363
- Type: Broker-dealer
- Material weakness: No
- Auditor: AJSH and Co. LLP
- Auditor location: New Delhi, K7
- Contact: Debra Shannon
- Phone: 5013586131
- Email: debra@veritasmail.com
- Website: veritasmail.com
- Signed by: Debra Shannon (Managing Member)

Original filing: https://www.sec.gov/Archives/edgar/data/1588116/000158811622000003/Veritas2021Audit.pdf

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OMB APPROVAL UNITED STATES OMB Number: 3235-0123 SECURITIES AND EXCHANGE COMMISSION Expires: Oct. 31, 2023 Washington, D.C. 20549 Estimated average burden hours per response: ANNUAL REPORTS SEC FILE NUMBER FORM X-17A-5 8-69363 PART III FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 AND ENDING 12/31/21 FILING FOR THE PERIOD BEGINNING 01/01/21 MM/DD/YY MM/DD/YY A. REGISTRANT IDENTIFICATION NAME OF FIRM: Veritas Independent Partners LLC TYPE OF REGISTRANT (check all applicable boxes): Broker-dealer | Security-based swap dealer Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) 2201 Washington Ave, Suite 2 (No. and Street) 72032 Conway Arkansas (City) (State) (Zip Code) PERSON TO CONTACT WITH REGARD TO THIS FILING Debra Shannon 501-358-6131 debra@veritasmail.com (Area Code - Telephone Number) (Name) (Email Address) B. ACCOUNTANT IDENTIFICATION INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\* AJSH and Co. LLP (Name – if individual, state last, first, and middle name) C7/227, Sector 7, Rohini 110085 New Delhi Delhi (Address) (City) (State) (Zip Code) 02/10/2009 3223 (Date of Registration with PCAOB)(if applicable) (PCAOB Registration Number, if applicable) FOR OFFICIAL USE ONLY \* 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

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.

CFR 240.17a-5(e)(1)(ii), if applicable.

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#### OATH OR AFFIRMATION

| Debra Shannon                                                               | swear (or affirm) that, to the best of my knowledge and belief, the                                                                 |
|-----------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| financial report pertaining to the firm of Veritas Independent Partners LLC | , as of                                                                                                                             |
| December 31                                                                 | 2 021 , 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.                                                      | Signatyre:                                                                                                                          |
|                                                                             | Title:<br>Managing Member                                                                                                           |
| 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.
- 0 (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 240.18a-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.
- [ (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:
- \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e/(3) or 17 CFR 240.180-7(d)(2), as applicable.

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#### REPORTS PURSUANT TO RULES 17a-5(d)

#### YEAR ENDED DECEMBER 31, 2021

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# Report of the Independent Registered Public Accounting Firm

To the Members of Veritas Independent Partners, LLC

## Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Veritas Independent Partners, LLC (the "Company") as of December 31, 2021 and the related statements of Neritas Indenement Partners,
member's equity and cash flows for the vear then order, or operations, member's equity and cash flows for the year the related statements of operations, changes in
as the "financial statements"). In our opinion the financial states (collectively as the "financial statements"). In our opinion, the related notes (collectively referred to
respects, the financial position, the financial statements present fairly, in all respects, the financial position of the Company as of December 31, 2021, and material
operations and its cash flows for the Company as of December 31, 2021, operations and its cash flows for the year then ended, in conformity with accounting of its
accepted in the United States of America, in conformity with accounting principles accepted in the United States of America.

#### Basis for Opinion

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board ("PCAOB") and are required with the ublic Company Accounting Oversight Board (United States)
federal securities laws and federal securities

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 when the finance and require that
are free of material misstatement, whether due to error of financi are free of material mis start to othil Pasonable so error or final. Our audit included procedures to assess the risks of material mistatement of the financial statements, whether discussion
error or fraud, and performing procedures that misstatements, whether d error or fraud, and performing procedures that respond to the financial statements, whether due to
examining, on a test basis, evidence regarding the amounts and discless inc examining, on a test basis, evidence regarding the amounts and disclosures included 
examining, on a test basis, evidence regarding the amounts and disclosures in the financ Our audit also included evaluating the accounting principles used and significant estimates statements.
management, as well as evaluating the accounting principles used and s management, as well as evaluating the accounting principles used and significant estimates made by
our audit provide a reasonable the overall presentation of the financial our audit provide a reasonable basis for our opinion.

## Supplementary Information

The supplementary information contained in Schedule I - Computation of Net Capital pursuant to Uniform Net Capital Rule 15c3-1 of Securities and Exchange Commission has been subjected to audit to
procedures performed in conjunction with the audit of Commission procedures performed in conjunction with the audit of Company's financial to supplemental information is the responsibility of the Company's minareement. The
included determining whether the supplemental information research. Our audit procedures included determining whether the supplements information reconciles to the financial statements
the underlying accounting and other records, as annicable and neconciles to th the underlying and other records, as applicable and performing procedures or 
completeness and accuracy as applicable and performing procedures to test the complete of the submiting and 'other 'records, 'as 'applicable and performing procedure
 completeness and accuracy of the information presented in the supplemental informa

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In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented with the supplemental
opinion, the supplemental information in fairly status in conformity with 17 CFR § 240.17a-5. opinion, the supplemental information is fairly stated in comornity with I 7 CFR 9 240.1/a-5. In our 
statements as a wholo statements as a whole.

AJSH & Co LLP

We have served as the Company's Auditor since 2018

New Delhi, India March 29, 2022

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#### STATEMENT OF FINANCIAL CONDITION

#### DECEMBER 31, 2021

## ASSETS

| Total assets                            | \$<br>233,480 |
|-----------------------------------------|---------------|
| Undeposited funds                       | 3,150         |
| Prepaid expenses                        | 1,098         |
| Central registration depository account | 268           |
| Commissions receivable                  | 124,682       |
| Cash                                    | \$<br>104,282 |

#### LIABILITIES AND MEMBER'S EQUITY

## LIABILITIES:

| Accounts payable and accrued expenses         | \$<br>103,735 |
|-----------------------------------------------|---------------|
| Related party payables                        | 17,974        |
| Total liabilities                             | 121,709       |
| COMMITMENTS AND CONTINGENCIES (Notes 5 and 6) | -             |
| MEMBER'S EQUITY (Note 2)                      | 111,771       |
| Total liabilities and member's equity         | \$<br>233,480 |

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#### STATEMENT OF INCOME

#### FOR THE YEAR ENDED DECEMBER 31, 2021

| REVENUES:             |                 |
|-----------------------|-----------------|
| Commissions           | \$<br>2,372,270 |
| Insurance income      | 14,426          |
| Reimbursed expenses   | 62,628          |
| Other income          | 32,225          |
| Total revenues        | 2,481,549       |
| EXPENSES:             |                 |
| Commission            | 2,011,234       |
| Professional services | 45,958          |
| Personnel             | 153,995         |
| General operating     | 80,649          |
| Insurance             | 26,131          |
| Regulatory            | 36,435          |
| Marketing             | 818             |
| Other                 | 1,839           |
| Total expenses        | 2,357,059       |
| NET INCOME            | \$<br>124,490   |

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## STATEMENT OF CASH FLOWS

#### FOR THE YEAR ENDED DECEMBER 31, 2021

| CASH FLOWS FROM (TO) OPERATING ACTIVITIES:                                           |               |
|--------------------------------------------------------------------------------------|---------------|
| Net income                                                                           | \$<br>124,490 |
| Adjustments to reconcile net income to net cash provided by<br>operating activities: |               |
| Decrease in accounts receivable - personnel                                          | 100           |
| Decrease in central registration depository account                                  | 1,326         |
| Decrease in prepaid expenses                                                         | 601           |
| Decrease in commissions receivable                                                   | 81,374        |
| Decrease in right of use asset                                                       | 3,593         |
| (Increase) in undeposited funds                                                      | (3,150)       |
| Increase in accounts payable and accrued expenses                                    | 6,327         |
| (Decrease) in Lease liability - roua                                                 | (3,593)       |
| (Decrease) in related party payables                                                 | (3,998)       |
| Net cash provided by operating activities                                            | 207,070       |
| CASH FLOWS FROM FINANCING ACTIVITIES:                                                |               |
| PPP loan                                                                             | (18,733)      |
| Capital distribution                                                                 | (109,930)     |
| Net cash provided by financing activities                                            | (128,663)     |
| NET INCREASE IN CASH                                                                 | 78,407        |
| CASH, at beginning of year                                                           | 25,875        |
| CASH, at end of year                                                                 | \$<br>104,282 |

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## STATEMENT OF CHANGES IN MEMBER'S EQUITY

#### FOR THE YEAR ENDED DECEMBER 31, 2021

| BALANCES, December 31, 2020 | \$<br>97,211         |
|-----------------------------|----------------------|
| Distributions<br>Net income | (109,930)<br>124,490 |
| BALANCES, December 31, 2021 | \$<br>111,771        |

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## NOTES TO FINANCIAL STATEMENTS

## December 31, 2021

## NOTE 1- ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

#### Organization and Business

Veritas Independent Partners, LLC (the "Company") is an Arkansas limited liability company formed on September 9, 2013. The Company is affiliated with Cardinal Investment Group ("Cardinal"), a registered branch office of the Company and Tartan Properties through common ownership. The Company is registered with the Securities and Exchange Commission (SEC), and licensed by the Financial Industry Regulatory Authority, Inc. (FINRA). The Company operates as a securities broker-dealer for mutual funds, variable annuities, and investment advisory services.

## 15c3-3 Exemption

The Company carries no customer funds or securities and therefore is exempt from the reserve and possession or control requirements under Rule 15c3-3(k)(2)(i) of the Securities Exchange Act of 1934. The Company identified the provisions of Footnote 74 under which the Company is not required to claim an exemption from 17 C.F.R 240.15c3-3.

#### Revenue Recognition

The Company's main source of revenue is mutual funds, variable annuities and investment advisory services. This revenue and the related commission expense are recognized on an accrual basis.

## Cash and Cash Equivalents

For purposes of the statement of cash flows, the Company considers investments with a maturity of three months or less to be cash equivalents.

## Income Taxes

The Company is not a taxable entity and thus the financial statements do not include a provision for income taxes. The Company's members are taxed on their respective share of the Company's earnings.

The Company is required to determine whether a tax position is more likely than not to be sustained upon examination by the applicable taxing authority, including resolution of any tax related appeals or litigation processes, based on the technical merits of the position. The Company files an income tax return in the U.S. federal jurisdiction, and may file income tax returns in various U.S. states. The Company is not subject to income tax return examinations by major taxing authorities for years before 2018. The tax benefit recognized is measured as the largest amount of benefit that has a greater than fifty percent likelihood of being realized upon ultimate settlement. De-recognition of a tax benefit previously recognized results in the Company recording a tax liability that reduces net assets. However, the Company's conclusions regarding this policy may be subject to review and adjustment at a later date based on factors including, but not limited to, on-going analyses of and changes to tax laws, regulations and interpretations thereof. The Company recognizes interest accrued related to unrecognized tax benefits and penalties related unrecognized tax benefits in income taxes payable, if assessed. No interest expense or penalties have been recognized as of and for the year ended December 31, 2021.

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## NOTES TO FINANCIAL STATEMENTS (*continued*)

## NOTE 1- ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES(cont'd)

## Estimates

Management uses estimates and assumptions in preparing these financial statements in accordance with accounting principles generally accepted in the United States of America. Those estimates and assumptions affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabilities, and the reported revenues and expenses. Actual results could vary from the estimates that were used.

## Leases

The Company's accounting and reporting of its leases complies with FASB ASC 842, Lease. See Note 3.

## NOTE 2 – NET CAPITAL REQUIREMENTS

Pursuant to the net capital provisions of Rule 15c3-1 of the Securities Exchange Act of 1934, the Company is required to maintain a minimum net capital, as defined under such provisions. At December 31, 2021, the Company had net capital and net capital requirements of \$107,014 and \$8,114, respectively. The Company's net capital ratio (aggregate indebtedness to net capital) was 1.14 to 1. According to Rule 15c3-1, the Company's net capital ratio shall not exceed 15 to 1.

## NOTE 3 – RECENTLY ISSUED ACCOUNTING PRONOUNCEMENTS

Effective December 1, 2020, the Company adopted the new FASB accounting standard ASC 842, Leases, which governs the accounting and reporting of leases by lessees. ASC 842 generally applies to leases that have a lease term greater than 12 months at lease commencement, or that include an option to purchase the underlying asset the Company is reasonably certain to exercise. ASC 842's principal changes are: 1) recognizing leases on the Statement of Financial Condition by recording a Right-of-use asset and a Lease liability; 2) changes in lease expense recognition during the lease term based on its classification as an Operating lease or Finance lease; 3) expanded disclosures of lease agreements, cost and other matters. See Note 4.

## NOTE 4 – LEASES

The Company is a lessee in a non-cancelable operating lease for office space subject to ASC 842, Leases. The lease agreement does not include a termination or renewal option for either party, or restrictive financial or other covenants. The non-cancelable operating lease is set to expire on May 1, 2022.

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## NOTES TO FINANCIAL STATEMENTS (*continued*)

## NOTE 5 – RELATED PARTY TRANSACTIONS AND COMMITMENTS

The Company is affiliated with Cardinal Investment Group ("Cardinal"), a registered branch office of the Company and Tartan Properties through common ownership.

The Company has an expense sharing agreement ("ESA") with Cardinal. Under the agreement, the Company pays an allocation of Cardinal's utilities.

The Company entered into a lease agreement with Tartan Properties which will expire May 1, 2022.

At December 31, 2021 there were related party payables of \$17,974 that are commissions due to the members of the Firm. The Firm has recorded \$87,080 as payroll expense and \$330,275 as commission expense paid to members for 2021.

## NOTE 6 – FINANCIAL INSTRUMENTS, OFF-BALANCE SHEET RISK AND CONTINGENCIES

The Company's financial instruments, including cash and cash equivalents, accounts receivable and other assets and accounts payable are carried at amounts that approximate fair value due to the short–term nature of those instruments.

## NOTE 7 - PAYCHECK PROTECTION PROGRAM LOAN

During the 12 months ended December 31, 2020 the Company borrowed \$18,650 under the Paycheck Protection Program (PPP) established by the Coronavirus Aid, Relief, and Economic Security Act sponsored by the United State and administered by the Small Business Administration (the "SBA").

The loan is subject to a note dated April 13, 2020 to the extent proceeds of the loan are used for eligible expenditures such as payroll and other expenses described in the CRAES Act. The loan bears interest at a rate of 1% and is payable in monthly installments of principal and interest over 24 months beginning 6 months for the date of the note. The loan can repaid at any time with no prepayment penalty. The Company has utilized the entirety of the proceeds of this loan amount for qualifying expenses, and as such, full loan forgiveness, including interest, was granted on April 8, 2021.

## NOTE 8 – SUBSEQUENT EVENTS

The Company has performed an evaluation of subsequent events through the date the financial statements were issued. The evaluation did not result in any subsequent events that required disclosures and/or adjustments.

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## SUPPLEMENTARY INFORMATION

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## SCHEDULE I

## VERITAS INDEPENDENT PARTNERS, LLC

## UNDER RULE 15c3-1 OF THE SECURITIES EXCHANGE ACT OF 1934 COMPUTATION OF NET CAPITAL

## DECEMBER 31, 2021

| CREDIT:                                                                                                  |               |
|----------------------------------------------------------------------------------------------------------|---------------|
| Stockholders' equity                                                                                     | \$<br>111,771 |
|                                                                                                          | -             |
| Total credits                                                                                            | 111,771       |
| DEBITS:                                                                                                  |               |
| Nonallowable assets:                                                                                     |               |
| Commissions - nonallowable                                                                               | 241           |
| Central registration depository account                                                                  | 268           |
| Prepaid expenses                                                                                         | 1,098         |
| Undeposited funds                                                                                        | 3,150         |
| Total debits                                                                                             | 4,757         |
| NET CAPITAL                                                                                              | 107,014       |
| Minimum requirement of 6-2/3% of aggregate indebtedness of<br>\$121,709 or \$5,000, whichever is greater | 8,114         |
| Excess net capital                                                                                       | \$<br>98,900  |
| AGGREGATE INDEBTEDNESS:<br>Accounts payable, accrued expenses & related party payables                   | \$ 121,709    |
| RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL                                                           | 1.14 to 1     |

NOTE: There are no material differences between the above computation of net capital and the corresponding computation as submitted by the Company with the unaudited Form X-17A-5 as of December 31, 2021.

See Independent Auditor's Report.

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A-94/8, Wazirpur Industrial Area, Main Ring Road, Delhi-110052 +91 11 45596689 Web : www.ajsh.in E-mail : info@ajsh.in

## Report of Independent Registered Public Accounting Firm

To the Board of Directors of Veritas Independent Partners, LLC

We have reviewed management's statements, included in the accompanying Veritas Independent Partners, LLC's Exemption Report, in which (1) Veritas Independent Partners, LLC does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3 and (2) Veritas Interendent Partners, LC stated that it is filing the Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F R. § 240.17a-5 because Veritas Independent Partners, LLC limits its business activities exclusively to Mutual fund retailer (Application way); Broker selling veriable ife insurance or annuities; Investment advisory services; and Municipal securities retailer -- 529 plans only and Veritas Independent Partners, LLC 1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, 2) did not carry accounts of, or for, customers; ond Mast ower, carry PAB accounts {as defined in Rule 15c3-3 throughout the most recent fiscal year, 2021, without exception. The Company'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 the Company'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 not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all meterial respects, based on the provisions set forth in SEC Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5.

AJSH & Co LLP

New Delhi, India March 29, 2022

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## EXEMPTION REPORT REQUIREMENT FOR BROKER/DEALERS UNDER RULE 17a-5 OF THE SECURITIES EXCHANGE ACT OF 1934

#### DECEMBER 31, 2021

Veritas Independent Partners, 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 does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and

(2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34- 70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to: (1) effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company: and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception.

I, Debra Shannon, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Signature Signature

Managing Member Title

See Independent Auditor's Report.


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