# BRIGHTTOWER SECURITIES LLC X-17A-5 (2023-09-15) — Broker-dealer annual report - Company: BRIGHTTOWER SECURITIES LLC - Form: X-17A-5 - Filed: 2023-09-15 - Period: 2023-06-30 - Accession: 0001905658-23-000004 - CIK: 1905658 - File #: 8-70864 - Type: Broker-dealer - Material weakness: No - Auditor: Withum Smith & Brown, PC - Auditor location: New York, NY - Contact: Rafael Beck - Phone: 212-897-1690 - Signed by: Rafael Beck (FinOp & CFO) Original filing: https://www.sec.gov/Archives/edgar/data/1905658/000190565823000004/BrightT23s.pdf --- {0}------------------------------------------------ #### **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** # **ANNUAL REPORTS FORM X-17A-5 PART Ill** | 0MB APPROVAL | | |--------------------------|--| | 0MB Number: 3235-0123 | | | Expires: Oct. 31, 2023 | | | Estimated average burden | | | hours per response: 12 | | SEC FILE NUMER 8- 70864 **FACING PAGE** **Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934** | A. REGISTRANT IDENTIFICATION | | | | | | | | |---------------------------------|----------------|------------------|----------|--|--|--|--| | | MM/DD/YY | | MM/DD/YY | | | | | | FILING FOR THE PERIOD BEGINNING | _0_7_/0_1_/_22 | __
AND ENDING | 06/30/23 | | | | | | | | | | | | | | # NAME OF FIRM: BrightTower Securities, LLC TYPE OF REGISTRANT (check all applicable boxes): ~ Broker-dealer D Security-based swap dealer D Major security-based swap participant 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.) # 110 East 25th Street, 11th Floor | | {No. and Street) | | | | |----------------------------------------------------------------------------------------------------|------------------------------------------------------------|-------------------------------------------|------------------------------|--| | New York | NY | | 10010 | | | (City) | (State) | | (Zip Code) | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | Rafael Beck | (212) 897-1690 | | rbeck@integ rated .solutions | | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
WithumSmith+Brown, PC | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | 1411 Broadway, 9th Floor | New York | NY | 10018 | | | (Address) | (City) | (State) | (Zip Code) | | | 10/08/2003 | | 100 | | | | (Date of Registration with PCAOB)(if applicable) | | (PCAOB Registration Number, ifapplicable) | | | #### **FOR OFFICIAL USE ONLY** \* Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(l)(ii), if applicable. **Persons who are to respond to the collection of information contained in this form are not require d to respond unless the form displays a currently valid 0MB control number.** {1}------------------------------------------------ #### OATH OR AFFIRMATION I, Rafael Beck , swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to BRIGHTIOWER SECURITIES LLC as of 06/30/23 , 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. FINOP and CFO Title | ,,,,.~;;.-;;··,
BONNIE BREIINER | |------------------------------------------------------------------------------------| | {?~\\ Notary
Public · State or Florida
\"J.·~~-ll
Commission ti HH 360096 | | ··1or ~·' My Comm. Expim Mar 21, 2027 | | ~-·Bonded through National Notary Assn. | ~~ Public / Notary {2}------------------------------------------------ #### **This filing\*\* contains (check all applicable boxes):** - **[El** (a) Statement of financial condition. - **[El** (b) Notes to unconsolidated or consolidated statement of financial condition, as applicable. - **D** (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** (d) Statement of cash flows. - **D** (e) Statement of changes in stockholders' or partners' or members' or sole proprietor's equity, as applicable. - **D** (f) Statement of changes in liabilities subordinated to claims of creditors. - **D** (g) Notes to unconsolidated or consolidated financial statements,, as applicable. - **D** (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-l, as applicable. - **D** (i) Computation of tangible net worth under 17 CFR 240.18a-2. - **D** (j) 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. - **D** (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 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - **D** (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. - **D** (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - 0 (q) Oath or affirmation in accordance wit h 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - **D** (r) Compliance report in accordance with 17 CFR 240.l 7a-5 or 17 CFR 240.18a-7, as applicable. - **D** (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - **[El** (t) Independent public accountant's report based on an examination of the statement of financial condition. - D (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 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-5 or 17 CFR 240.18a-7, as applicable. - **D** (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.l 7a-S or 17 CFR 240.18a-7, as applicable. - **D** (x) Supplemental reports on applying agreed-upon procedures, in accordance with 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.l 7a-12(k). (z) Other:-------------------------------------- - **D** *\*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5{e}{3} or 17 CFR 240.18a-* *7(d){2}, as applicable.* {3}------------------------------------------------ Statement of Financial Condition June 30, 2023 (With Report of Independent Registered Public Accounting Firm) {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) ## **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of BrightTower Securities, LLC: #### **Opinion on the Financ1ial Statement** We have audited the accompanying statement of financial condition of BrightTower Securities, LLC (the "Company") as of June 30, 2023, and the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of June 30, 2023, in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** This financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on this financial statement based on our audit. We are a public accounting firm reg.istered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion. We have served as the Company's auditor since 2022. New York, New York September 7, 2023 {5}------------------------------------------------ ### **Statement of Financial Condition June 30, 2023** | Assets | | |---------------------------------------|--------------| | Cash | \$
24,912 | | Other assets | 1,355 | | Total assets | \$
26,267 | | | | | Member's equity | \$
26,267 | | Total liabilities and Member's equity | \$
26,267 | The accompanying notes are an integral part of these financial statements. {6}------------------------------------------------ ## **Notes to Statement of Financial Condition June 30, 2023** #### **1. Organization and Business** BrightTower Securities, LLC (the "Company"), is a limited liability company formed under the laws of the State of New York and a wholly owned subsidiary of BrightTower LLC (the "Parent" , or the "Member"). On January 12, 2023, the Company became a broker-dealer registered with the United States Securities and Exchange Commission ("SEC") under the Securities and Exchange Act of 1934, as amended ("Exchange Act"), and a member of the Financial Industry Regulatory Authority ("FINRA"). The Company provides unique strategic counseling and investment banking services to companies in the technology industry. The liability of the Member is limited to the capital held by the Company. #### **2. Summary of Significant Accounting Policies** #### **Basis of Presentation** These financial statements were prepared in conformity with accounting principles generally accepted in the United States of America ("U.S. GAAP") which requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the amounts of revenues and expenses during the reporting period. Actual results could differ from these estimates. #### **Revenue Recognition** The Company recognizes revenues in accordance with ASU 2014-09, Revenue from Contracts with Customers (Topic 606) ("ASU 20 14-09"). ASU 2014-09, and related amendments, provide comprehensive guidance for recognizing revenue from contracts with customers. Revenue is recognized when the entity transfers promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled to in exchange for those goods or services. The guidance includes a five-step framework that requires an entity to: (i) identify the contract(s) with a customer, (ii) identify the performance obligations in the contract, (iii) determine the transaction price, (iv) allocated the transaction price to the performance obligations in the contract, and (v) recognize revenue when the entity satisfies a performance obligation. The Company earns revenue by way of advisory fees from investment banking, which include retainers and success fees. The Company may also earn finder's fees. Revenue from services provided are recognized at the time there is persuasive evidence that the Company's services have been substantially completed pursuant to the terms of an engagement letter, the fee is determinable, and collection of the related receivable is reasonably assured. Unearned retainer fees are included in deferred income on the statement of financial condition, have already been received and are expected to be recognized as revenue in a future period. As of July 1, 2022, and June 30, 2023, there were no accounts receivable, contract assets or contract liabilities. #### **Other Assets** A deposit with Central Registration Depository ("CRD") is included in other assets on the statement of financial condition. FINRA operates the CRD and uses the funds deposited to process registrations and other regulatory assessments of the Company. {7}------------------------------------------------ ### **Notes to Statement of Financial Condition June 30, 2023** #### **2. Summary of Significant Accounting Policies (continued)** #### **Income Taxes** The Company is a "disregarded entity" for income tax purposes, as it is wholly owned by its sole member, the Parent. The operations of the Company are included on the Parent's tax return, and items of taxable income or loss flow through to the members of the Parent. Accordingly, no provision or liability for income taxes is included in the accompanying financial statements. Management is responsible for evaluating the Company's uncertain tax positions in accordance with the Financial Accounting Standards Board ("FASB") Accounting Standards Codification 740, Income Taxes. The Company has evaluated its tax positions taken for all open tax years and has not identified any uncertain tax positions which would require disclosure in the financial statements as of June 30, 2023. The Company is subject to examination by the taxing authorities for all the years since inception. #### **3. Transactions with Related Parties** The Company maintains an expense sharing agreement with the Parent. Pursuant to the agreement, the Parent funds some of the Company's expenses and provides administration, office space, office equipment, employee services, employee travel, legal, professional, and other services. The Parent incurs these costs and provides these services at no cost to the Company. The results of operations may have been materially different if the Company had operated as an independent company. The Company maintains a separate schedule of the expenses that are funded by the Parent and as such, these expenses have not been recorded in the books of the Company. #### **4. Economic Dependency** The Company may require from time-to-time support from the Parent; however, management believes it has sufficient cash to support operations for at least one year from the date of the issuance of these financial statements. The Parent has pledged to continue to support the Company in the future. #### **5. Regulatory Requirements** As a registered broker-dealer, the Company is subject to the Uniform Net Capital Rule l 5c3-l under the Securities Exchange Act of 1934 (the "Rule") in addition to the rules of FINRA and other principal exchanges on which it is licensed to transact business. The Company is following the basic method which requires the maintenance of minimum net capital at an amount equal to the greater of \$5,000 or 6-2/3% (12-1/2% during the first 12 months of operations) of aggregate indebtedness and requires that the ratio of aggregate indebtedness to net capital, both as defined, not to exceed 15 to 1 (8 to 1 during the first 12 months of operations). On June 30, 2023, the Company had net capital of approximately \$25,000 which exceeded its minimum requirement by approximately \$20,000. The Company's aggregate indebtedness to net capital ratio was .0 to 1. The Company does not handle customers' cash or securities, and therefore, it is not impacted by SEC Rule 15c3-3. {8}------------------------------------------------ ## **Notes to Statement of Financial Condition June 30, 2023** #### **6. Concentrations** All cash deposits are held in an account by one financial institution and is subject to credit risk to the extend these balances are in excess of federally insured limits. At June 30, 2023, the cash balances held by the Company are within federally insured limits. #### **7. Subsequent Events** Management of the Company has evaluated events or transactions that may have occurred from June 30, 2023, and determined that there are no material events that would require disclosure in the Company's financial statements except for the following. On August 22, 2023, the Company received a capital contribution in the amount of \$30,000 from the Parent. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.