# SI SECURITIES, LLC X-17A-5 (2024-03-28) — Broker-dealer annual report - Company: SI SECURITIES, LLC - Form: X-17A-5 - Filed: 2024-03-28 - Period: 2023-12-31 - Accession: 0002013816-24-000010 - CIK: 1603038 - File #: 8-69440 - Type: Broker-dealer - Material weakness: No - Auditor: Mazars USA LLP - Auditor location: Woodbury, NY - Contact: Chris Meyers - Phone: 212-668-8700 - Email: cmeyers@acisecure.com - Website: acisecure.com - Signed by: Daniel Fishman (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1603038/000201381624000010/sipublicaudit.pdf --- {0}------------------------------------------------ # UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 sec file number 8-69440 # ANNUAL REPORTS FORM X-17A-5 PART III | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | | FACING PAGE | | | | | | | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------|------------------------------------------------------------|--|---------|-----------------------|--|--|--| | 1/1/2023 _____________________________________________________________________________________________________________________________________________________________________
FILING FOR THE PERIOD BEGINNING
AND ENDING | | | | | 12/31/2023 | | | | | | MM/DD/YY | | | | MM/DD/YY | | | | | | | A. REGISTRANT IDENTIFICATION | | | | | | | | NAME OF FIRM: SI Securities LLC | | | | | | | | | | TYPE OF REGISTRANT (check all applicable boxes):
l Broker-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.)
99 High Street, 17th Floor | | | | | | | | | | | | (No. and Street) | | | | | | | | Boston | | MA | | | 02210 | | | | | (City) | | (State) | | | (Zip Code) | | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | | | | Chris Meyers | 212-668-8700 | | | | cmeyers@acisecure.com | | | | | (Name) | (Area Code - Telephone Number) | | | | (Email Address) | | | | | B. Accountant IDENTIFICATION | | | | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
Mazars USA LLP | | | | | | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | | | | 60 Crossways Park Drive West, Suite 301 Woodbury | | | | NY | 11797 | | | | | (Address) | | (City) | | (State) | (Zip Code) | | | | | 10/08/2003 | | | | 339 | | | | | | (PCAOB Registration Number, if applicable)
(Date of Registration with PCAOB)(if applicable) | | | | | | | | | | * Claims for exemption from the requirement that the annual reports of an independent public | | FOR OFFICIAL USE ONLY | | | | | | | 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)(1)(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 OMB control number. {1}------------------------------------------------ # OATH OR AFFIRMATION State of Florida. County of Osceola ı, Dan Fishman aka Daniel Fishman financial report pertaining to the firm of Sl Securities LLC report ending 12/31/2023 as a comments of as a consideration as of March 27 , 2024 , 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. via online notarization and who produced Canada Passport as ID Notary Public - State of Florida | Signature: | | |------------|--| | Title: | | | CFO | | Notary Public --- This notarization was an online notarization along with multi-factor authentication and using audio/video recording. # 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). ROSELY DIAZ Commission # HH 78838 Comm. Expires Jan 7, 2025 - □ (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. - □ (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. - □ (I) 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 capible net worth under 17 CFR 240.15c3-1, 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. - - | - □ (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)(2), as applicable. {2}------------------------------------------------ # SI Securities, LLC (A Wholly Owned Subsidiary of Pluto Holdings, LLC) Statement of Financial Condition As of December 31, 2023 {3}------------------------------------------------ ## Contents | Report of Independent Registered Public Accounting Firm | | |---------------------------------------------------------|-------| | Statement of Financial Condition | | | Notes to Financial Statement | 3 - 5 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) Mazars USA LLP 60 Crossways Park Drive West Suite 301 Woodbury. New York 11797 Tel: 516.488.1200 www.mazars.us # Report of Independent Registered Public Accounting Firm To the Board of directors of the Member of SI Securities, LLC ## Opinion on the Financial Statement We have audited the accompanying statement of financial condition of SI Securities, LLC (the "Company") ( a wholly owned subsidiary of Pluto Holdings, LLC), as of December 31, 2023, and the related notes (collectively referred to as the "financial statement"). In our opinion, the statement of financial condition 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 of 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. 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 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 2020. Woodbury, NY March 27, 2024 {5}------------------------------------------------ ### Statement of Financial Condition December 31, 2023 | ASSETS | | | |---------------------------------------------------------------------------------------------------------------------------------------------|---|--------------------------------| | Cash and cash equivalents
Investments in privately held companies, at fair value (cost \$2,343,469)
Prepaid expenses and other assets | ક | 1,132,961
827,474
17,897 | | TOTAL ASSETS | | 1,978,332 | | LIABILITIES AND MEMBER'S EQUITY | | | | LIABILITIES: | | | | Accounts payable and accrued expenses | S | 158,152 | | Due to affiliates | | 81,569 | | TOTAL LIABILITIES | | 239,721 | | MEMBER'S EQUITY | | 1,738,611 | | TOTAL LIABILITIES AND MEMBER'S EQUITY | | 1,978,332 | | | | | See Notes to Accompanying Financial Statement. {6}------------------------------------------------ Notes to Financial Statement December 31, 2023 ## 1. Organization and Nature of Business St Securities, LLC (the "Company") was organized as a Imited lability company on February 26, 2013 under York. Effective October 7, 2014, the Company ecisiered with the Securities and Exchange Comment of the Financial housty Requator Authority Requatory Authority. Inc. ("FINR"). The Commervis wholy ovned by Pluto Holdings, LLC (the "Merche"), a subsidian of Circle LLC. The Company primarily rees for raising capital for small businesses. As of May 5, 2023, the platform was closed. The Company ceased revenue generating operations and is reliant on meet its financial obligations Since the Company is a limited lability company, the Mallies of the Company, whelter arising in ontract, tot or other arising in ontract, tot or otherwise, unless the Mercher has signed a specific guarantee. ## 2. Summary of Significant Accounting Policies #### a) Basis of Accounting The financial statement is prepared using in acordance with accounting principles generaly accepted in the United States of Anneica. Revenue is recognized when earned, while expenses and losses are recognized when incurred. #### b) Cash and Cash Equivalents The Company considers all highly in these months or less when purchased to be cash equivalents. Cash and cash eximalined in checking and money market accounts held at financial institutions. There are no cash equivalents at December 31, 2023. The Company's cash and cash equivalents are financial institution and at times nay exceed federally insured limits. The Company has plants in a high quality institution in order to minimize risk relating to exceeding in 2023, the amount in excess of federally insured linits is approximately \$881,000 Through September 30, 2023, the Company maintained a sed solely for the benefit of its oustomers. As of December 31, 2023, this account was closed and there were no amounts due to customers. #### c) Revenue From Contracts with Customers #### Performance Obligations Revenue from contracts with customers is resolities its performance chigations by transfering promised goods or services to customers. A good or service is transfered to a customer when or as , the customance obligation may be satisfied over time or at a point in time or at a point in line. Revenue from a performance obligation salisfied a a point in line that the Company delemines the customer obtains control over the promised god or service. The amount of revenue recognized reflects the consideration to which the Company expects to be entitled in exchange for those promised goods or services The following provides detailed information on the recognition of the Company's revenue from contracts with customers hvestment banking fees for services in private placed at the line time transaction is completed as this is when the customer has obtained ontrol over the promised good or service. If contractual arrangenents provided when earned. In sme instances, as compensation in lieu of cash, the Compensation in lieu of cash, the Company nay receive conventble notes, equity or warrants in the company they are assisting in raising investments in privately held companies that are reseived in lieu of cash are deemed illiquid securities without a publiced is recognized when the transation is completed as this is when the customer has obtained control over the promised good or service. Experse rimbursent revenues are agreed upon and recompany for expenses it incurs to complete a successful transation. In the event a successful transaction closes, and the Client has aged to reimbrany to these expenses, the Company earns the expense at the close of the transaction The Company has not incurred costs to obtain customer contracts #### Accounts Receivable The accurts receivable balance in the statement of finals in estrent banking fees from customers in connection with prirate placement sen ices. The acounts receivable balance as of January 1, 2023 was \$4,477. The accounts receivable balance as of December 31, 2023 was \$0. #### Allowance Policy Management provides for probable unounts through a charge to bad debt expense and a redit to bad debt reserve bestablily status of accounts, under the current expected credit loss model. The allowance for doubtful accounts at December 31, 2023 was \$0. 3 {7}------------------------------------------------ Notes to Financial Statement December 31, 2023 #### Significant Customer For the year ended December 31, 2023, 70% of gross revenues was derived from 5 customers. #### d) Income Taxe In December 2019, the Financial Accuning Standards Update ('ASU') 2019-12, hoome Tanes (Topic 740) to simplify the accounting for income ares by emoving cetain excections to the general principes in the anorments also introve consistent and simplify GAP for the other areas of Topic 740 v claifing and amenting existing quidance. The Company is a dised the quidance in ASU 2019-12 and therefor has not reflected federal, state, or cly (ares for the year ented December 31, 2023 The Company has adopted the tar provisions of Accome Taxes which presorition thresholds that must be met before a lax position is recognize in the financial statements and provins, classification, and interest and peralies. Under this guidance, an entity nay only recognize or online to recognize as postions that meet a "nore likely han not" these on 2023, maragement has defernined that the Company had no uncertain tax positions that would require financial statement recognition. This deternination will always be subject to ongines may reguire. The Parent remains subject to U.S. federal, state, and boa income lax audits for the tax years 2020 though 2021. There are no delilies recognized in the accompanying statement of financial contine as anounts are deemet to be immaterial and are not expected to have any future tax consequence. #### e) Use of Estimates The preparation of financial statements in contines generally accepted in the United States of America requires nanagement to make estimates and assumplions that affect the reported and labilities and the discosure of onlingent asses and librities as of the inancial statements and the reported ancurity of revenue and expenses during the reporting period. Actual results could differ from those estimates. #### f) Investments in privately held companies Investments in pirately held company has less than a 20% interest and does not have the ability o exercise significant influence. The can in any and of these investments are \$827,474, with the difference from in the statement of operations during the year ended December 31, 2023. The initial value is determined by using the private placement transaction initialy takes place, which is when the investment in privately hel companies. Management evaluates subsequent share issuances and other any fair value adjustments are necessary ### 3. Indemnifications and uncertainties In the normal course of its business the series cetain service providers against specified potential boses in connection with their acting as a agent of, or providing serices to, the Company. The maximum of future payments that the Company could be required to make under these indentifications canot be estinated Hovever, the Company believes that it is unle material payments under these arrangements and has not recorded any contingent lability in the financial statements for these indemnifications. The Company provides representations and variety with a variety of commercial transactions and occasions and occasional internifies then against losses caused by the breach of those rearesertations and valso novide stard intennifications to some cunteraries to rotect then in the event additional takes are oved or payments are witheld, due ether to a catintation of certain tax. These internifications generally are stardard contractual tems and are entered into in the normal course of business. The navinents that the Company could be required to nake under these indemnifications cannot be estimated. However, he Company believes that it is unlike naterial payments under these arrangements and has not recorded any on the financial statements for these indemnifications. #### 4. Contingencies In the ordinary course of business, the Company (a a co-defenciant in a putative class action lawsuit under the Securities Act of 1933 with a caim for camot be reasonably estimated at this ine and (b) is the ulimate cultinate cultimate cultimate coucome of the forecultory inquires cannot be realited with certainly, in the opinion of management, the outcome of these material adverse effect on the Company's financial condition. #### 5. Fair Value Measurements The Company records its financial asses and liabilities at fair value provides a franswork for measuring fair value that carific of fair value and expants disclosures regarding fair value is defined as the price that would be received to sell an asset or paid to transfer a lability (an exit price) in an order) transaction belveen market parting date. The accunting stardatishes a three-tier hierary, witch proritizes the inputs use in the valuation nelbodogies in measuring fair value. Level 1 - Quoted prices in active markets for identical assets or liabilities Level 2 - Inputs other that are observate, either directly or intrestly, such as quoted prices in market hat are not adver of ather inputs that are observable or can be corroborated by observable market data for substantially the full term of the assets or liabilities. Level 3 - Unchservable inqut that are supported by ittle or no market activity and that are significant to the asses and labilities. A financial instrument's level within th value hierarchy is based on the lowest level within the fair value hierarchy of any input that is significant to the fair value measurement. {8}------------------------------------------------ #### Notes to Financial Statement December 31, 2023 ## 5. Fair Value Measurements (Continued) The following table represents the Company's for those assets and liabilities measured at fair value on a recurring basis at December 31, 2023 | | | Level | Level 2 | | Level 3 | Total | |-----------------------------------------------|---|-------|---------|----|---------|---------| | Securities Owned: | | | | | | | | Convertible & Crowd Notes | | | | မာ | 107.603 | 107.603 | | Equity Investments | | | | | 719.871 | 719.871 | | Total Investments in Privately Held Companies | ങ | - | - | | 827.474 | 827.474 | Level 3 investments are valued based on incificant to the overall fair yalle measurement. Fair yalle is a market based on assumptions of prices and inputs considered for the perspective of a market as of the measurent date, rather than an entity-specific measure. Therefore, even viner observable inputs are not readiy avaliable, the Company's own as and to relect those that market participants would use in pricing the asset or liability at the measurenent date The aralability of valuation lections can vary from investment to investment and are affected by a wide variety of factors, including the the the investment is new and not established in the markets, and dher characteristics particular to the ransaction. To the extent hat valuation is based on models or inputs that are less closervale in the naties, the fair value requires more judgement. Because of the interent uncertainly of valuation, those estinated values may be materially higher or loves that would have been used had a ready market for the innestments exsted. According the cercised by the Company in deternining far value is greatest for in evel 3. In some cases, the inputs used to measure fair value might be categorized within different levels of the fair vale hierachy. In such cases, the fair vale measurement in its entirely in the fair value hieradly based on the lovest to the fair value measurement. The following table summarizes the valuation to the Company's investments that are categorized within Level 3 of the fair vale hierary as of December 31, 2023: | Assets (at fair value) | Fair value at
December 31, 2023 | Valuation Techniques | Unobservable inputs | |---------------------------|------------------------------------|-----------------------------|---------------------| | Convertible & Crowd Notes | 107,603 | Most recent financing round | N/A | | Convertible & Crowd Notes | | Forfeiture rate analysis | N/A | | Equity Investments | 719,871 | Most recent financing round | N/A | | Equity Investments | ಳಿ | Forfeiture rate analysis | N/A | The following table represents additional information and and undeservable inpuls may be used to determine the fair ralle of positions | Balance, January 1, 2023 | S | 915,103 | |-----------------------------------------------|---|-----------| | Receipts of equity investments as fee revenue | | 72.037 | | Return of capital on investment | | (379) | | Unrealized loss on investments | | (159.666) | | Realized gain (loss) on investments | | 379 | | Balance, December 31. 2023 | | 827.474 | ## 6. Related Party Transactions The Company receives working capital advances from is affiliates and has a expense sharing arrangement with its affiliates whereby the Company incurs a morthy alocation of rent, wages and overhead costs from these affiliates was delemined based upon the square needed by the Company to operate and the ulilization of employee personnel to effectively manage the activities of the Company. ## 7. Net Capital Requirement The Company is subject to the Securities and Exchange (15:3-1), which requires the maintenance of minimum net capital and that the ration of aggregate indebtedness to net capital, both as defined and 1500% in the first year of operations, and 1500% in every vear thereating the spages from moment to mornent. At December 31, 2023, the Company of \$83,240, which was \$64,240 in excess of its required net capital of \$250,000. The Company's aggregate indebtedness to net capital ratio was 26.84% at December 31, 2023. ### 8. Exemption from the Customer Protection Rule The Company claimed an exemplion to SEA Rule 15:3-3 under this exemption, the Company naintained a bank accunt for the exclusive benefit of customers" which was not subject to liens for the purposes assets forn liabilies of the Company. In order to maintain the exemplion, the Company was required to promply remit all customer funds that were received by noon escrow agent or other designated control location. The Company relied on Footrote 74 of the SEC Reease No. 34-7007 and ment to 17 C.F.R. 240.17-5 because the Company cased revealing operations as of May 5, 2023, and the Company (1) did not directly receive, hold, or otherwise over unders (2) did not cary accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) from May 6, 2023 through December 31, 2023 without exception. #### 9. Subsequent Events The Company has evaluated events and transactions that on any 1, 2024 and March 27, 2024, which is the the Financial Statement were available to be issued, for possible disclosure and recognition in the Financial Statement. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.