# EURONEXT MARKET SERVICES LLC X-17A-5 (2024-03-28) — Broker-dealer annual report - Company: EURONEXT MARKET SERVICES LLC - Form: X-17A-5 - Filed: 2024-03-28 - Period: 2023-12-31 - Accession: 0001719196-24-000001 - CIK: 1719196 - File #: 8-70033 - Type: Broker-dealer - Material weakness: No - Auditor: Sanville and Company - Auditor location: Dallas, TX - Contact: Patrick Basilice - Phone: 646-779-1135 - Email: bmegenity@bdcaonline.com - Website: bdcaonline.com - Signed by: Allan Goldstein (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1719196/000171919624000001/emssfcs.pdf --- {0}------------------------------------------------ | UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
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12 | | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------|--------------------------------------------| | | ANNUAL REPORTS | | SEC FILE NUMBER | | | FORM X-17A-5 | | 8-70033 | | | PART Ill | | | | FACING PAGE
Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under te Securities Exchange Act of 1934 | | | | | FILING FOR THE PERIOD BEGINNING 1/1/2023 | MM/DD/VY | I | AND E~DING 12/31/2023
MM/DD/VY | | | A. REGISTRANT IDENTIFICATION I | | | | | | | | | NAME OF FIRM: EURONEXT MARKET SERVICES LLC | | | | | TYPE OF REGISTRANT (check all applicable boxes):
I
□ Major se,curity-based swap participant
~ Broker-dealer
□ Security-based swap dealer
D Check here if respondent is also an OTC derivatives dealer | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)
180 MAIDEN LANE, 15TH FLOOR | | | | | | (No. and Street) | | | | NEW YORK | NY | | 10038 | | (City) | (State) | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | Brian Megenity | (770) 263-6003 | | bmegenity@bdcaonline.com | | (Name) | (Area Code -Telephone Number) | | (Email Address) | | | B. ACCOUNTANT IDENTIFICATION! | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in ihis filing*
Sanville & Company LLC | | | | | | (Name - if individual, state last, first, and middle 'name) | | | | 325 N. St. Paul Street, Suite 3100 | Dallas | TX | 75201 | | (Address)
September 18, 2003 | (City) | (State)
169 | (Zip Code) | | (Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | | • Claims for exemption from the requirement that the annual reports be covered by 1he reports of an independent public | FOR OFFICIAL USE ONLY | | | accountant must be supported by a statement of facts and circumstances relied o~ as the basis of the exemption. See 17 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.** {1}------------------------------------------------ #### **OATH OR AFFIRMATION** | | 12/31 | 2~
partner, officer, director, or equivalent person, as the case may be, has any pro rie | | is true and correct. I further swe r (or affirm) that neither the company nor any
ry intere tin any account classified solely | |------|------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|--------|----------------------------------------------------------------------------------------------------------------------------------| | | as that of a customer. | | | | | | | | | | | | NY State
New York County - | | | | | | Sworn to before me on: | 'TAREK M ELBARl | | | 3 1,;_J 202 lf
,--~~~~~~~~~~!___ | NOT"RY PUBLIC-STATE OF NEW YORK | CEO | | | | Notary Public | No.01EL64'13650
OU8lified in New York County | | | | | | My Commi&sion Expires 02-01-2025 | | | | | This filing** contains (check all applicable boxes): | | | | | | ~ (a) Statement of financial condition. | | | | | | | ~ (b) Notes to consolidated statement of financial condition. | | | | D | | (c) Statement of income (loss) or, if there is other comprehensive income in th period(s) presented, a statement of | | | | | | comprehensive income (as defined in § 210.1-02 of Regulation S-X). | | | | | □ (d) Statement of cash flows. | | | | | D | | (e) Statement of changes in stockholders' or partners' or sole proprietor's equi | | | | D | | (f) Statement of changes in liabilities subordinated to claims of creditors. | | | | D | (g) Notes to consolidated financial statements. | | | | | D | | (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-l, s applicable. | | | | | | □ (i) Computation of tangible net worth under 17 CFR 240.18a-2. | | | | D | | (j) Computation for determination of customer reserve requirements pursuant o Exhibit A to 17 CFR 240.15c3-3. | | | | D | Exhibit A to 17 CFR 240.18a-4, as applicable. | | | (k) Computation for determination of security-based swap reserve requiremen s pursuant to Exhibit B to 17 CFR 240.15c3-3 or | | D | | (I) Computation for Determination of PAB Requirements under Exhibit A to§ 2 0.15c3-3. | | | | D | | (m) Information relating to possession or control requirements for customers nder 17 CFR 240.15c3-3. | | | | D | | (n) Information relating to possession or control requirements for security-bas d swap customers under 17 CFR | | | | | 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. | | | | | D | | | | (o) Reconciliations, including appropriate explanations, of the FOCUS Report wi h computation of net capital or tangible net | | | | | | worth under 17 CFR 240.15c3-l, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, asap licable, and the reserve requirements under 17 | | | | CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exis | | or a statement that no material differences | | | exist. | | | | | D | | (p) Summary of financial data for subsidiaries not consolidated in the statemen of financial condition. | | | | | | ~ (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-1 , or 17 CFR 240.18a-7, as applicable. | | | | D | | (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a- , 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 sta ement of financial condition. | | | | D | | | | (u) Independent public accountant's report based on an examination of the fin ncial report or financial statements under 17 | | | | CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. | | | | D | CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. | | | (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 | | !!!i | | (w) Independent public accountant's report based on a review of the exemptio report under 17 CFR 240.17a-5 or 17 | | | | | CFR 240.18a-7, as applicable. | | | | | D | | (x) Supplemental reports on applying agreed-upon procedures, in accordance | | ith 17 CFR 240.15c3-le or 17 CFR 240.17a-12, | | | as applicable. | | | | | D | | | | (y) Report describing any material inadequacies found to exist or 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). | ----+- | --------------- | {2}------------------------------------------------ EURONEXT MARKET SERVICE LLC Financial Statements For the Year Ended December 31, 2023 With Report of Independent Registered Public A counting Firm {3}------------------------------------------------ ![](_page_3_Picture_0.jpeg) ### **Report of Independent Registered Public Accounting Firm** To the Member and Those Charged With Governance of Euronext Market Services LLC #### **Opinion on the Financial Statement** We have audited the accompanying statement of financial condition of Euronext Market Services LLC (the Company) as of December 31, 2023, and the related notes (collectively, the financial s(atement). 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 *or* 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 U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. 1 We conducted our audit in accordance with the standards of the PCAOB. Th9se 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 t~ose risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures i~ the financial statement. Our audit also included evaluating the accounting principles used and significant estimat1 s 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. *s~* ✓ 6~ LLC This is the initial year we have served as the Company's auditor. Dallas, Texas March 28, 2024 > 325 North Saint Paul Street Suite 3100 Dallas, Texas 75201 214.738.1998 {4}------------------------------------------------ # **Euronext Market Services, LL** · **Statement of Financial Conditio December 31, 2023** | Assets | | |-------------------------------------------|---------------| | Cash and cash equivalents | \$2,944,599 | | Due from Parent -
Deferred tax benefit | 88,918 | | Accounts receivable | 401,971 | | Unbilled receivables | 226,748 | | Accrued tax receivables | 14,132 | | Prepaid expenses and other assets | 5,658 | | Total assets | \$ 3,682,026 | | Liabilites and member's equity | | | Liabilities | | | Due to related parties | 225,966
\$ | | Accounts payable | 575,219 | | Total liabilities | 801,185 | | Member's equity | 2,880,841 | | Total liabilities and member's equity | \$ 3,682,026 | | | | {5}------------------------------------------------ ## EURONEXT MARKET SERVICES J\_.LC NOTES TO FINANCIAL STA TEM~NTS FOR THE YEAR ENDED DECEMBER 31, 2023 #### NOTE 1 ~ NATURE OF OPERATIONS AND BASIS OF PRESENTATION ## Organization and Description of Business Euronext Market Services LLC (the "Company") is a wholly~owned subsidiary of Euronext US, Inc. (the "Parent"). The Company is a limited liability company and was formed under the laws of the state of Delaware in July 2017. On September 10, 2018, the Company became a broker~dealer and as such is registered with the Securities and Exchange Commission ( the "SEC') and a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investors Protection Corporation ("SIPC"). The Company was originally approved by FINRA to conduct business as an alternative trading system ("ATS") to trade U.S. cdrporate debt securities and U.S. Treasury securities, but the Company is not currently actively engaged as an ATS. In addition, the Company provides third party research services as afforded under SEC Section 28(e) safe harbor and section III(H) and (I) of its interpretative guidance issued July 24, 2006. See Note 7 for related party transactions. ## Basis of Presentation The accompanying financial statements have been prepared in accordance with accounting principles generally accepted in the United States of America ("US GAAP") and pursuant to Rule 17a~5 of the Securities and Exchange Commission Act of 1934. The classification and reporting of items appearing on the financial statements are consistent with that rule. The Company does not claim an exemption from Rule 15c3~ 3 in reliance upon footnote 74 of SEC Release No. 34~ 70073 dated July 30, 2013, and as discussed in Question 8 of the related FAQ released by SEC staff on April 4, 2014. The Company does not hold customer funds or securities and does not carry accounts of or for customers. #### NOTE 2 ~ SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES ## Use of Estimates Management uses estimates and assumptions in preparing these financial statements in accordance with US GAAP. 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. {6}------------------------------------------------ ## **EURONEXT MARKET SERVICES LLC NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2023** ### Cash and Cash Equivalents The Company considers all highly liquid investments with maturity of three months or less at the time of purchase to be cash equivalents. Cash and cash equivalents consist primarily of cash and money tnarket funds held at banks and other financial institutions. ## Revenue Recognition The Company accounts for revenue under the provisions of ASC 606, *Revenue from Contracts with Customers.* Under ASC 606, recognition of revenue occurs when a customer obtains control of promised services or qoods in an amount that reflects the consideration to which the entity expects t9 receive in exchange for those goods or services. In addition, the standard requires disclosure of the nature, amount, timing, and uncertainty of revenue and cash flows arising from customer contracts. In general, the Company applies the following steps when recognizing revenue from contracts with customers: (i) identify the contract, (ti) identify the performance obligations, (iii) determine the transaction price, (iv) allocate the transaction price to the performance obligations and (v) recognize revenue when a performance obligation is satisfied. The Company earns fees from its support and operational services provided to its customers in accordance with the related revenue sharing agreements. The Company has customer contracts that have a st~nd~ready obligation to perform services on an ongoing basis over the life of the contract, typically for periods up to one year, where the scope of these arrangemetits is broad and there are no significant gaps in performing the services. Thtrse contracts consist of a fixed monthly fee and a transaction based fee component. For these contracts, the Company recognizes the revenue over time for the availability of its monthly service bundle, which represents a stand~ready performance obligation. As the Company bills in arrears for the prior month's services, the fixed fee, and the variability in the transaction~based fee that does not align with the timing of the billings to the customer may result in the recognition of a contract asset. This can result in a requirement to estimate monthly transaction based fees each month during the contract term in order to determine the rate for revenue recognition. This variable consideration is constrained if there is an inability to reliably forecast this revenue. Additionally, the Company may occasionally recognize revenue adjustments in the current period for performance obligations partially or fully satisfied in the previous periods resulting from changes in estimates for the transaction price, including any changes to its assessment of whether an estimate of variable consideration is constrained. {7}------------------------------------------------ ## **EURONEXT MARKET SERVICES LLC NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2023** ### *Infonnation on Remaining Perfonnance Obligations* The Company does not disclose information about remaining performance obligations pertaining to contracts that have an o~iginal expected duration of one year or less. These performance obligations generally relate to the service fee income and are resolved monthly as services are p 1 rformed under the terms of the contracts. #### *Contract Balances* The timing of the revenue recognition may differ from the timing of payment by the customers. The Company records an unbilled receivable when revenue is recognized prior to invoicing and it has an urtconditional right to payment. Alternatively, when payment precedes the provision of the related services, the Company records deferred revenue until the perfoµnance obligations are satisfied. The Company records accounts receivables when services are billed to the customer. The Company had receivables related to revenues from contracts with customers of \$628,719 at December 31, 2023, consisting of \$226,748 of unbilled receivables, and \$401,971 of accounts receivable. The Company expects the entirety of these receivables to be collected in accordance with the invoice terms in 2024. ### *Contract Costs* Incremental costs of obtaining a contract are capinalized if they are expected to be recovered. Incremental contract costs that have an amortization period of one year or less are expensed as a practical expedient. There were no incremental contract costs during 2023. The Company does not incur any other contract costs with the exception of the services provided by the Affiliate. At December 31, 2023, the Company owes the Affiliate \$205,359. Please see Note 7 for further details. ### *Disaggregation of Revenue* The Company does not disaggregate revenue otht? than by service line, as it does not believe any further disaggregation provides meaningful information about its financial performance or position. #### Income Taxes The Company is a single member limited liability. company, which has elected to be taxed as a corporation for income tax reporting purposes. The Company is included in a consolidated federal, New York State and New York City group return of its Parent. {8}------------------------------------------------ ## **EURONEXT MARKET SERVICES LI\_C NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER ~l, 2023** Since the transactions reported in the Company's financial statements have income tax implications to the Parent, management believes that the Company's financial statements should reflect income tax expense and deferred income tax assets and liabilities attributable to the Company. Federal, state, and local income taxes are calculated as if the Company filed on a separate return basis and the amount of current tax or benefit calculated is either remitted to or received from the Parent. The Company accounts for income taxes pursuant to Financial Accounting Standards Board ("FASB") Accounting Standards Codification ("ASC") 740, *Income Taxes.* Deferred tax assets and liabilities are determined based on temporary differences between the bases of certain assets and liabilities for income tax and financial reporting purposes. The deferred tax as1 ets and liabilities are classified according to the financial statement classification of the assets and liabilities generating the differences. The Company maintains a valuation allowance with respect to deferred tax assets. The Company establishes a valuation allowance based upon the potential likelihood of realizing the deferred tax asset within the Parent's group return. Future realization of the deferred tax benefit depeI)-ds on the existence of sufficient group taxable income within the carry-forward period. Any change in the valuation allowance will be included in income in the year of the change in estimate. The Parent has evaluated the Company's tax positions and concluded that the Company has no uncertain tax positions that req9ire adjustment to or disclosures in the financial statements. I ### Financial Instruments - Credit Losses OnJanuary 1, 2020, the Company adoptedASU No. 2016-13, *Financial Instruments* - *Credit Losses (Topic 326): Measurement of Credit Lossts on Financial Instruments* ("ASU 2016-13"). The new guidance required an entity to measure all expected credit losses for financial assets measured at amortized cost based on historical experience, current conditions, and reasonable and supportable forecasts as opposed to delaying recognition until the loss was probable of occurring. The Company's assets within the scope of ASU 2016-13 include accounts receivable and unbilled receivables. For these financial instrume:p.ts within the guidance's scope, the expected credit losses were determined to [be immaterial considering the counterparty's credit quality, an insignificant history of credit losses, and/or the short-term nature of the credit exposure. {9}------------------------------------------------ ## EURONEXT MARKET SERVICES LLC NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2023 #### NOTE 3 - CONTINGENCIES ### Legal Matters From time to time, we may be involved in litigation relating to claims arising out of operations in the normal course of business. There were no pending or threatened lawsuits that could reasonably be expetted to have a material effect on the results of our operations. There are no proceedings in which any of our management, members or affiliates, is an adverse party or has a material interest aversft to our interest. #### NOTE4- CONCENTRATIONS OF CREDIT RISK The Company maintains its cash balances in one financial institution, which are not insured. At December 31, 2023 the Company's cash balance account had an uninsured balance of \$2,944,599. The Company Has not incurred any losses in its account. The Company provides its support and operational services to its customers through the Affiliate pursuant to the intercompany services agreement as discussed in Note 7. #### NOTES-NET CAPITAL REQUIREMENT The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-l), which requires t;he maintenance of minimum regulatory net capital, and requires that the rat~o of aggregate indebtedness to regulatory net capital, both as defined, shall not exceed 15 to 1. At December 31, 2023, the Company had net capital of \$2,143,414, which exceeded its requirement of \$53,412 by \$2,090,002. The ratio 1f aggregate indebtedness to net capital was .37 to 1. #### NOTE 6 - INCOME TAXES The Company elected to be taxed as a corporation for federal income tax purposes and is included in its Parent's consolidated federal income tax return. The Company also is included in its Parent's combined state and local income tax returns. The Company has elected to include its allocated amount of current and deferred taxes in its financial statements as if the ~ompany filed a separate federal income tax return. The current and deferred portions of the income tax expense included in the statement of operations as determined in accordance with F ASB ASC 7 40 are as follows: {10}------------------------------------------------ ## EURONEXT MARKET SERVICES LLC NOTES TO FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER ?I, 2023 | | Current | Deferred | Total | |-----------------|------------|----------|------------| | Federal | \$ 171,202 | \$5,667 | \$ 176,869 | | State and local | \$105,982 | \$3,sbs | \$109,490 | | Total | \$277,184 | \$9,175 | \$286,359 | Deferred tax expense represents the decrease in deferred tax assets during 2023 due to amortization of start/up costs that were caJ?italized for tax purposes and expensed for financial reporting purposes in prior years. T oral tax expense in the Statement of Operations is \$31,232 less than noted in the table above due to a 2022 tax adjustment that wasmade in 2023. 1 A reconciliation of the difference between the expected income tax expense or benefit computed at the U.S. statutory income tax rate and the Company's income tax expense is shown in the following table: | | Amount | % | |--------------------------------------------------------|-----------|-------| | Expected income tax expense at U.S. statutory tax rate | \$176,869 | 21.0% | | State and local income taxes, net of federal benefit | \$109,490 | 13.0% | | Total | \$286,359 | 34.0% | The Parent's group returns for calendar years 2020 through 2022 are subject to federal, state and local examination. The Parent's group return for the 2023 calendar year has not been filed yet. #### NOTE? ~ RELATED PARTY TRANSACTIONS The Company has an administrative services agreement with the Parent. Pursuant to the agreement, the Parent provides accountirig, administrative, office space, human resources and other services. The Parent allocated expenses of \$254,445 to the Company during the year ended December 3f, 2023. Additionally, Euronext Markets Americas llC, a subsidiary of the Parent, allocated compensation expenses related to one employee of \$56,764 to the Company as part of the administrative services agreement during the year ended December 31, 2023. The total expenses of \$310,780 are reflected in the Company's Statement of Operations, which consists of compensation of \$292,487, occupancy of \$6,293 and professional fees of \$12,000. Effective December 1, 2019, the Company entered into an intercompany services agreement with the Affiliate. Pursuant to the agreement, the Affiliate provides accounting, reconciliation, and retention services of soft dollar transactions uploaded and systemized through the affiliate's trade reconciliation technology. Expenses incurred under the agreement totaled \$823,448 consisted of a client service fee of \$249,692 and software maintenance of \$573,756. I {11}------------------------------------------------ ## EURONEXT MARKET SERVICES LC NOTES TO FINANCIAL STATEM S FOR THE YEAR ENDED DECEMBER 1, 2023 | Related party transactions: | | |-----------------------------------------------------------------------------------------------------------------------------|------------------------------------| | Parent ~ Euronext US Inc.
Affiliate 1 -
Euronext Markets Americas LLC.
Affiliate 2 -
Cornmcise Software Limited | | | | 2023 | | Purchase of services from related parties:
~ Parent (a)
~ Affiliate 1 (b)
~ Affiliate 2 ( C) | \$
254,445
56,764
821,436 | | | \$
1,132,645 | | Receivables due from related party:
~ Parent (d) | \$
88,918 | | Payables due to related parties: | | | ~ Parent (e)
~ Affiliate 1 (f) | \$
16,637
3,970 | | ~ Affiliate 2 (g) | 205,359 | | | \$
225,966 | | | | a) Consists of recharges for employee com pens tion, group supporting functions, and office space and other facility fees. I - b) Consists of recharges for employee compens tion. - c) Consists of recharges for client services fee d software maintenance. d) Consists of the receivable of the deferred t assets from the Parent. See Note 6 ~ Income Taxes for additional information. - e) Consists of the balance owed under the a strative services agreement and allocated for current income taxes. - f) Consists of the balance owed under the a strative services agreement. - g) Consists of the balance owed under the inte company services agreement. {12}------------------------------------------------ # **EURONEXT MARKET SERVICES C NOTES** TO **FINANCIAL STATEME S FOR THE YEAR ENDED DECEMBER 1, 2023** #### NOTES~ SUBSEQUENT EVENTS In preparing these financial statements, the Co any has evaluated events and transactions for potential recognition or disclosur through the date the financial statements were issued. {13}------------------------------------------------ ![](_page_13_Picture_0.jpeg) #### **Report of Independent Registered Public Accounting Firm** To the Member and Those Charged With Governance of Euronext Market Services LLC We have reviewed management's statements, included in the accompanying Exemption Report, in which Euronext Market Services LLC (the Company) stated that: - 1. The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3; - 2. The Company is filing an 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 busiriess activities exclusively to (1) receiving transaction-based compensation for providing technology or platform services; throughout the most recent fiscal year; and - 3. 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 17 C.F .R. § 240.15c2-4; (2) did not carry accounts of or for customers; and (3) did not carry proprietary accounts of broker-dealers (as defined in 17 C.F .R. § 240.15c3-3) throughout the most recent fiscal year without exception. The Company's management is responsible for its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United Stales) and, accordingly, included inquiries and other required procedures to obtain evidenbe that the Company limited its business activities exclusively to receiving transaction-based compensation for providing tech~ology or platform services and (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 17 C.F.R. § 240.15c2-4; (2) did not carry accounts of or for customers; and (3) did not carry proprietary accounts of ~roker-dealers (as defined in 17 C.F.R. § 240.15c3-3) throughout the most recent fiscal year without exception. 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 n\ade to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in 17 C.F .R. § 240.17a-5. s~ 6~LLC Dallas, Texas March 28, 2024 325 North Saint Paul Street Suite 3100 Dallas, Texas 75201 214.738.1998 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.