# VIENNA CAPITAL PARTNERS LLC X-17A-5 (2026-04-07) — Broker-dealer annual report - Company: VIENNA CAPITAL PARTNERS LLC - Form: X-17A-5 - Filed: 2026-04-07 - Period: 2024-12-31 - Accession: 0001834059-26-000004 - CIK: 1834059 - File #: 8-70631 - Type: Broker-dealer - Material weakness: No - Auditor: LMHS, P.C. - Auditor location: Norwell, MA - Contact: Vincent DeFilippo - Phone: 8563192784 - Signed by: Ernest Kappotis (Consultant) Original filing: https://www.sec.gov/Archives/edgar/data/1834059/000183405926000004/annual24.pdf --- {0}------------------------------------------------ UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, o.c. 20549 > ANNUAL REPORTS FORM X-17A-S | 0MB Number: 323S.0123 | | |---------------------------|--| | Expires; Nov, 30, 2026 | | | Estimated ave,age burden | | | hQul'\$ per rti?(IR5e: 12 | | # PART Ill | hQul'\$ per rti?(IR5e: 12 | | |---------------------------|--| | SEC Fil£ NUMBER | | | 8-70631 | | | | | FACtNG **PAGE** tnfonnatlon Required Pursuantto Rules 17a-S, 17a-12, and 18a-7 under the Securities Exchanee Act of 1934 | | FILING FOR THE PERIOD BEGINNING 01/01/2024 | AND ENDING | 1213112024 | |-------------------|--------------------------------------------------------------|------------|-----------------------------------------| | MM/00/YV | | | MM/DD/VY | | | A. REGISTRANT IDENTIFICATION | | | | | NAME oF FIRM: Vienna Capital Partners, LLC | | | | | TYPE OF REGISTRANT (check all applicable boxes): | | | | Ii] Broker-dealer | D Security-based swap dealer | | D Major security-based swap participant | | | 0 Check here if respondent is also an OTC derivatives dealer | | | ADORESS OF PRINCIPAL PLACE OF BUSINESS: {Do not use a P.O. box no.) ## 40 Wall Street 17th Floor | New York | NY | 10005 | |----------------------------------------------|-------------------------------------------------------------|---------------------------------------| | (City) | (State) | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | Richard Onesto | 34 7 853-6534 | rich@finopsolutior | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | 8. ACCOUNTANT IDENTIFICATION | | | | (NatM - If lndtvldu l, \$tlte ta,t, first, and middle name} | | | 80 Washington Street | Norwell | MA
02061 | | (Address} | (City) | {State)
{Zip Code) | | | | | | 02/24/2009 | | 3373 | | (Date of Re iur11tlon with PCAOB If a Ucable | | PCAOB Re lstraUon Number If a llcable | | | | | | | FOR OFFIOAL USE ONLY | | CFR 240.17...S( )(1)(11), ff applicable. s>.rsont who,,. to rHpond to th• colt.ctlon of lnfomtatlon contained In thh form ar• not requl,.d to respond unless the form dlspl1V11 cur,.ntlywllcl OMii conttol number. {1}------------------------------------------------ #### OATH **OR AFFIRMATION** | I, Vincent DeFilippo | swear (or affirm) that, to the best of my knowledge and belief, the | |-------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------| | financial report pertaining to the firm of Vienna Capital Partners, LLC | as of | | 2~
12/31 | 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 i terest i any account classified solely | | as that of a customer. | | | ROSEMARYO A
,_---,,,--t~OTARY PUBLIC. STATE o::
es stra ·on o.
)
Oualtl\ed in | 'tW YORK
Signature:
0 64 2~27
ew O'}; Co- .inty | | Commission Expires | err~r •,. 2025
Title:
CEO | | | | ## This **filing .. contains (check an applicable boxes):** - (a) Statement of financial condition. - D (b) Notes to consolidated sta.tement of financial condition. - ii (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 5-X). - ii (d) Statement of cash flows. - (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - D (f) Statement of changes in liabilities subordinated to claims of creditors. - ii (c) Notes to consolidated financial statements. - ii (h) Computat.ion of net capital under 17 CFR 240.15c3-l or 17 CFR 240.lSa-l, as applicable. - D (i) Computation of tangible net worth under 17 CFR 240.lSa-2. - ii U) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.1Sc3-3. - D (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. - D (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3, - ii (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.1Sc3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - ii (o) Reconciliations, including appropriate e)(planatlons, of the FOCUS Report with 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, as applicable, and the reserve requirements under 17 CFR 240.1Sc3-3 or 17 CfR 240.lSa-4, as applicable, if material differences exist, or a statement that no material differences e>eist. - D (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - iii (q) Oath or affirmation in accordance with 17 CFR 240.17a-S, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - 0 (r) Compliance report In accordance with 17 CFR 240.17a-S or 17 CFR 240.18a-7, as applicable. - iii (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240,lSa-7, as applicable. - D (t) Independent public accountant's report based on an examination of the statement of financial condition. - ii (u) Independent public accountant's report based on an examination of the financlal report or financial statements under 17 CFR 240.17a-S, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a•S or 17 CFR 240.18a-7, as applicable. - ii (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.lSa-7, as applicable. - D (x) Supplemental reports on applying agreed•upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-U, as applicable. - D (y) Rerrt describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a sti~ment that no material inadequacies exist, under 17 CFR 240,17a-12{k), D (z)Other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_ - - 0 To request confidential treatment of certain portions of this filing, see 17 CFR 240.17o-5{e){3) or 17 CFR 240.18o-7(d)(2), as applicable. {2}------------------------------------------------ FINANCIAL STATEMENTS AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM DECEMBER 31 , 2024 (CONFIDENTIAL PURSUANT TO RULE 17a-5(e)(3)) {3}------------------------------------------------ | CONTENTS | |-------------------------------------------------------------------------------------------------| | Page(s} Report of Independent Registered Public Accounting Firm

1 | | Financial Statements | | Statement of Financial Condition 2 | | Statement of Earnings 3 | | Statement of Changes in Member's Equity 4 | | Statement of Cash Flows 5 | | Notes to Financial Statements 6-9 | | Supplementary Information | | Computation of Net Capital Under Rule 15c3-1 of the Securities and
Exchange Commission | | And Reconciliation with Company's Net Capital Computation 10 | | Computation for Determination of Reserve Requirements and Information
Relating to Possession | | or Control Requirements Under Rule 15c3-3 of the Securities and Exchange
Commission 11 | | | | Report of Independent Registered Public Accounting Firm on Rule 15c3-3 Exemption | | |----------------------------------------------------------------------------------|--| | Report 12 | | | Rule 15c3-3 Exemption Report 13 | | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) *Report of Independent Registered Public Accounting Firm* To The Member Vienna Capital Partners, LLC cw York, ew York #### *Opinion on the Fi11a11cial Statements* We have audited the accompanying tatement of financial condition of Vienna Capital Partners. LLC as of December 31 , 2024, and the related statements of operation , changes in member's equity, and cash flows for the year then ended and the related notes (collectively referred to as the 'financial statements"). Tn our opinion, the financial statements present fairly, in all material respects, the financial position of Vienna Capital Partners, LLC as of December 31 , 2024, and the results of its operations and its cash flows for the years then ended in conformity with accouming principles generally accepted in the United State of America. #### *Basis for Opinion* These financial tatements are the responsibility of the entity's management. Our re ponsibility is to express an opinion on these 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 Vienna Capital Partners, LLC in accordance with the U.S. federal securiti es law 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 tatement are free of material misstatement, whether due lo error or fraud. Our audit included perfonning procedure to as e s the ri ks of material misstatement of the financial statements, whether due to error or fraud and perfonning procedures that respond lo those risks. Such procedures included examining, on a le t basis, evidence regarding the amount and disclo ures in the financial statements. Our audit also included evaluating the accounting principle used and significant e timates 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 opinjon. #### *Supplemental Information* The supplemental information appearing on pages IO and 11 has been subjected to audit procedures performed in conjunction with the audit of Vienna Capital Partners, LLC's financial statements. The supplemental information is the responsibility of Vienna Capital Partners, LLC 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 completcne - and accuracy of the info1111ation pre ented in the upplemental information. In forming our opinion on the upplemental information, we evaluated whether the supplemental information, including its form and content is presented in conformity with C.F.R. §240.17a-5. 1n our opinion, the supplemental information is fairly tared, in all material respects, in relation to the financial statements a a whole. *LM* H-S, *?.* C\_ LMHS, P.C. We have served as Vienna Capital Partners, LLC's auditor since 2023. orwell, Mas achu ctt April 11, 2025 ![](_page_4_Picture_14.jpeg) ![](_page_4_Picture_16.jpeg) {5}------------------------------------------------ ## **STATEMENT OF FINANCIAL CONDITION** #### **December 31, 2024** #### **ASSETS** | Cash
Investments -
U.S. Treasuries
Investments -
Mutual Funds
Advances to Reps
Prepaid Expense | \$
26,801
134,215
28,085
1,500
111 | |------------------------------------------------------------------------------------------------------------------|---------------------------------------------------| | Total assets | \$
190,712 | | LIABILITIES AND MEMBER'S EQUITY | | | Liabilities
Accounts payable and accrued expenses | \$
5,614 | | Total liabilities | 5,614 | | Member's equity | 185,098 | | Total liabilities and member's equity | \$
190,712 | {6}------------------------------------------------ ## **STATEMENT OF OPERATIONS** ## **Year Ended December 31, 2024 Revenues** Private Placement Fees \$ 374,850 Loss on Securities (82,058) Interest and Dividends 22,784 Total revenue 315,576 **Expenses** Commissions 162,750 Bank Charges and Fees 670 Advisory Fees 3,693 Regulatory Fees 23,050 Data and Technolgy 45,530 Legal and Professional Fees 110,739 Research Fees 2,500 SIPC Fees 562 Occupancy Cost 96,413 Total expenses 445,907 Net Loss \$ {130,330} {7}------------------------------------------------ ## **STATEMENT OF CHANGES IN MEMBER'S EQUITY** #### **Year Ended December 31 , 2024** | Member's equity, beginning of year | \$ 1,437,161 | |------------------------------------|---------------| | Contributions | 164,300 | | Distributions to member | (1 ,286,032) | | Net Loss | (130,330) | | Member's equity, end of year | \$
185,099 | {8}------------------------------------------------ ## **STATEMENT OF CASH FLOWS** #### **Year Ended December 31, 2024 Cash flows provided by operating activities** Net Loss Changes in operating assets and liabilities: Increase in Advances to Reps Increase in Prepaid Expenses Increase in Accounts payable and accrued expenses Net cash used in operating activities Cash Flows from investing activities U.S. Treasuries Non Marketable Securities Investments in Mutual Funds Net cash provided by investing activities Cash flows from financing activities Contributions by member Distributions to member Net cash used in financing activities Net increase in cash Cash, beginning of year Cash, end of year \$ (130,330) {1 ,500) (111) 3,229 1,618 (128,712) 1,138,671 158,828 (28,085) 1,269,414 164,300 (1 ,286,031) (1 ,121 ,731) 18,971 7,831 \$ 26,802 {9}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** #### **1. Nature of business and summary of significant accounting policies** #### Nature of Business Vienna Capital Partners, LLC (the "Company"), a Delaware Limited Liability Corporation established on November 6th , 2020, is a broker-dealer, registered with the Financial Industry Regulatory Authority ("FINRA"), and licensed by the Securities and Exchange Commission ("SEC"). The Company is wholly owned by Tomasa Antonia Holdings ("the Parent"). The company received FINRA approval pn November 3"\ 2022 The Company, as a broker-dealer, does not carry margin accounts, promptly transmits all customer funds and delivers all securities received in connection with the Company's activities as a broker-dealer, and does not otherwise hold funds or securities for, or owe money or securities to, customers. The Company provides investment banking and consulting services. #### Government and Other Regulation The Company's business is subject to significant regulation by governmental agencies and self-regulatory organizations. Such regulation includes, among other things, periodic examinations by these regulatory bodies to determine whether the Company is conducting and reporting its operations in accordance with the applicable requirements of these organizations. #### Basis of Presentation The financial statements have been prepared in conformity with accounting principles generally accepted in the United States of America ("GAAP") as detailed in the Financial Accounting Standards Board's Accounting Standards Codification ("ASC"). #### Revenue Recognition The Company recognizes revenue in accordance with ASC-606 Revenue from Contracts with Customers. Revenue recognition guidance requires that an entity recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. The guidance requires an entity to follow a five-step model to (a) identify the contracts with the customer, (b) identify the performance obligations in the contract, (c) determining the transaction price, (d) allocate the transaction price to the performance obligations in the contract, and (e) recognize revenue when (or as) the entity satisfies a performance obligation. For the year ended December 31 , 2024 there were revenues of \$374,850 related to business activity all of which was from private placement services recognized at a point in time. Performance Obligations - Revenue from contracts with customers is recognized when, or as, the Company satisfies its performance obligations by transferring goods or services to customers. A good or service is transferred to a customer when, or as, the customer obtains control of that good or service. A performance obligation may be satisfied over time or at a point in time. Revenue from a performance obligation satisfied at a point in time is recognized at the point in time that the company determines the customer has obtained control over the promised good or service. The amount of revenue recognized reflects the consideration of which the Company expects to be entitled in exchange for the promised goods or services. Revenue from providing private placement services is recognized when earned, which generally occurs as services are performed. {10}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** #### **1. Nature of business and summary of significant accounting policies (continued)** #### Cash and Cash Equivalents For the purposes of reporting the statement of cash flows , the Company considers all cash accounts, which are not subject to withdrawal restrictions or penalties, and all highly liquid debt instruments purchased with a maturity of three months or less to be cash equivalents. Cash balances in excess of FDIC and similar insurance coverage are subject to the usual banking risks associated with funds in excess of those limits. At December 31 , 2024 the Company had no uninsured cash balances. #### Accounts Receivable The Company recognizes revenue from services and other fees in the period they are earned and are reasonably assured as collectible. Accounts Receivable are reviewed periodically. The Company has not made provisions for bad debt expense or any amount of allowance for uncollectable accounts at year-end since it has determined that there is no need for any write-offs. #### Income Taxes The Company does not record a provision for income taxes because the members report their share of the Company's income or loss on their income tax returns. The financial statements reflect the Company's transactions without adjustment, if any, required for income tax purposes. The Company files an income tax return in the U.S. federal jurisdiction and may file income tax returns in various. U.S. states and foreign jurisdictions. Generally, the Company is subject to income tax examinations by major taxing authorities for the last three years. #### Use of Estimates The preparation of financial statements in conformity with GAAP requires the Company's management to make estimates and assumptions that affect the reported amounts of 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. #### Lease Policies The Company follows the guidance of Accounting Standards Update (ASU) 2016-02, Leases (ASC Topic 842) and subsequent amendments. ASC 842 affect all companies that enter into lease arrangements, with certain exclusions under limited scope limitations. Under ASU 2016-02, an entity recognizes right-of-use assets and lease obligations on its balance sheet for all leases with a lease term of more than 12 months. Short-term rentals under year-to-year leases or remaining lease terms of 12 months or less are exempt from being capitalized. As of December 31 , 2024, the Company did not hold any leases with a term greater than 12 months. {11}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** #### **2. Net capital requirement** The Company is a member of FINRA and is subject to the SE C's Uniform Net Capital Rule 15c3-1. The Company has elected to compute its net capital requirement pursuant to SEC Rule 15c3-1 , which requires minimum net capital of the greater of \$100,000 or 6.67% of aggregate indebtedness and a ratio of aggregate indebtedness to net capital not exceeding 15 to 1. At December 31 , 2024, the Company's net capital was \$181,398 which was \$81 ,398 in excess of its minimum requirement of \$100,000. #### **3. Concentrations of credit risk** In the normal course of business, the Company maintains its cash balances in a financial institution which is insured by the Federal Insurance Corporation ("FDIC"). The Company is subject to credit risk to the extent any financial institution with which it conducts business is unable to fulfill contractual obligations on its behalf. The Company's account balances that are non-interest-bearing accounts are subject to the Dodd-Frank Walk Street Reform and Consumer Protection Act (the "Act"). The Company's interest-bearing cash balances may exceed the FDIC coverage of \$250,000. As of December 31 , 2024, the Company did not have balances in excess of insured limits. The Company has not experienced any losses in such accounts and believes it is not subject to any significant credit risk on cash. {12}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** #### **4. Commitments and contingencies** The Company may be exposed to various asserted and unasserted potential claims encountered in the normal course of business. In the opinion of management, the resolution of any such matters will not have a material effect on the Company's financial position or results of operations. There were no commitments or contingencies at December 31 st, 2024. #### **5. Subsequentevents** The Company has evaluated subsequent events through the date of the Independent Registered Public Accounting Firm Report, whereupon the financial statements were issued and determined there are no items to disclose. #### **6. Fair Value** FASS ASC 820 defines fair value, establishes a framework for measuring fair value, and establishes a fair value hierarchy which prioritized the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transaction to sell the asset or liability or, in the absence of a principal market, the most advantageous market for the asset of liability. Valuation techniques that are consistent with the market, income or cost approach, as specified by FASB ASC 820 are used to measure fair value. The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels: Level 1 inputs are quoted prices (unadjusted) in active markets for identical assets or liabilities the Company has the ability to access. Level 2 inputs are inputs (other than quoted prices included within Level 1) that are observable for the asset or liability, either directly or indirectly. Level 3 are unobservable inputs for the asset or liability and rely on management's own assumptions about the assumptions that market participants would use in pricing the asset or liability. (The unobservable inputs should be developed based on the best information available in the circumstances and may include the Company's own data.) As of December 31 , 2024, the Company holds six which are classified as level 1 securities. #### **7. Segment Reporting** The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services, Private Placement Services. The company has identified Vincent DeFilippo as the chief operating decision maker ("CODM"), who uses net income to evaluate the results of the business, predominantly in the forecasting process, to manage the Company. Additionally, the CODM uses 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 pay dividends. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies. All revenue segments and significant expenses for the year ended December 31 , 2024 is disclosed on the Statement of Operations. {13}------------------------------------------------ ## **COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION** | Year Ended December 31, 2024 | | |-----------------------------------------------------------------|-------------------------------| | Net capital, member's equity | \$
185,098 | | Less nonallowable assets
Prepaid Expense
Advances to Reps | (111)
{1 ,500)
(1 ,611) | | Net Capital before haircuts on securities positions | \$
183,487 | | Haircuts on securities | (2,089) | | Net Capital | 181 ,398 | | Minimum net capital required (under SEC Rule 15c3-1) | 100,000 | | Excess net capital | \$
81 ,398 | | Aggregate indebtedness | 5,614 | | Percentage of aggregate indebtedness to net capital | 3.09% | There are no material differences between the proceeding computation and the Company's corresponding unaudited Part II of Form X-17A-5 as of December 31 , 2024. {14}------------------------------------------------ **NOTES TO FINANCIAL STATEMENTS** ## **COMPUTATION FOR DETERMTNATTON OF RESERVE REQUIREMENTS** #### **December 31, 2024** #### **ST A TEMENT PURSUANT TO EXEMPTION FROM THE COMPUT A TTON FOR DETERMINATION OF RESERVE REQUIREMENTS PURSUANT TO RULE 15c3-3** The Company operates pw-suant to Footnote 74 of the SEC Release o. 34-70073 adopting amendments to 17 C.F.R. § 240. l 7a-5 -Accordingly, the "Computation for Determination of Reserve Requirements"and "Information Relating to the Posse sion or Control Requirements" under such rule have not been prepared. #### **INFORMATION FOR POSSESSION OR CONTROL REQUIREMENTS UNDER RULE l 5c3-3** The Company is exempt from the provision of SEC rule 15c3-3 pursuant to Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240. l 7a-5 and for the year ended December 31 , 2024 the Company was in compliance with the conditions of exemption. {15}------------------------------------------------ ![](_page_15_Picture_0.jpeg) *Report of independent Registered Public Accounting Firm* To The Member Vienna Capital Partners, LLC cw York, ew York We have reviewed management' statements, included in the accompanying SEC Rule I 5c3-3 Exemption Report in which Vienna Capital Partners, LLC stated that Vienna Capital Partners, LLC's business activitie are limited to private placement of securities capital advisory: assisting issuers to plan for and structure capital market transactions, merger and acquisition services: advising both public and private companie in merger and acquisition initiatives including is uing fairness opinions, wholesaling: sourcing investment for and provide marketing support for thirdparty broker-dealers, and 144A resales: purchasing unregistered securities from an issuer in a primary offering that is a private placement and simultaneously reselling the same securities the firm pw·chases from the issuer in resale transactions, and that it has not held customer funds or securitie and that Vienna Capital Partners, LLC is classified as "non-covered" pursuant to Footnote 74 to SEC Release 34-70073, dated July 30, 2013 and as discussed in Q&A 8 of the related FAQ issued by SEC state on April 4, 2014. Vienna Capital Pa1tners, LLC also stated that it had maintained compliance with the above declaration throughout the most recent fi cal year ended without exception. Vienna Capital Partners, LLC management is responsible for compliance and is not subject to the provision set forth in Rule l 5c3-3 under the Securities and Exchange Act of 1934 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 Vienna Capital Partners, LLC's declaration concerning the provisions set forth in Rule l 5c3-3 under the Securities and Exchange Act of 1934. A review is sub tantially le in cope than an examination, the objective of which i the expression of an opinion on management' statements. Accordingly, we do not expres such an opinion. Based on our review, we are not aware of any material modifications that sbould be made to management' statements referred to above for them to be fairly stated, in all material respects, in all material respects, based on the provisions set forth in Footnote 74 to SEC Release 34-70073. *LMH-S, ?J.C.* LMHS P.C. We have served as Vienna Capital Partners, LLC's auditor since 2023. orwell Massachusetts April 11 2025 ![](_page_15_Picture_11.jpeg) {16}------------------------------------------------ ## April 11, 2025 Vienna Capital **Partners,** LLC Vienna capital Partners, LLC (the "Company") is a registered broker.