FOCUS Report Metric Financial Inc.

X-17A-5 [Paper] - FOCUS Report

Published: 2014-03-20 19:36:46
Submitted: 2014-02-28
Period Ending In: 2013-12-31
scanned.pdf Scanned paper document


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                                                                                    FORM X17A-5                                                                                                                                     SEOFUE                  NUMBER
                                                                                                                PART                                                                                                                      46684

                                                                                                                WING PAGE
                             information Required of Brokers                                                         and Dealers                        Pursuant                           to    Section               17    ol     the

                                               Securities                   Fxchange                Act of             19             and Rule 17a                                          hereunder


Li   POR                      1111         PFR1OD                BEGINNING                    1/01/2013                                                             AND                   ND1ii             12/31/2013
                                                                                                                     MM      Dl                                                                                              NM            55



                                                                                   REGISTR                 NT          IDENTIFI                                 TION


NAMF           OF BROKIR                    1FI             FR           NEWBURY                     PIRET SE CURITIES                                                        INC                                           OFFICIAL USE                         ONLY


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                                                                              ACCOUNTANT                                  IDENTIFICATION


INDIPF\DFNI                      PUBLIC             ACCOUNIANC hose                                  opinion           is    contained                 in this            RepolD


MILLER                 WACHMAN                              LLP
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                                                                                                                                          posscsions


                                                                                            FOR       OFFCAL                        USE ONLY




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                                                                 Potential  persons who are to respond     to the collection of

                                                                 information  contained inthisform are not reqwredto respond
     SEC       1410         06 02                                unless the form displays  currendy valid 0M8 control number


                                                                                     OATH          OR AFFIRMATION

                                                                                                                                                                                                                            of
       MARGUERITE                                       IRET                                                                                               swear      or affirm             that       to    the   best



                                                                                                                     and                           schedules        pertaining         to   the     firm of
                            and    belief         the    accompanying               financial      statement                    supporting
my knowledge
  NEWBURY                     PIRET SECURITIES                                       INC                                                                                                                                        as



of_DECEMBER                             31                                                             2Oj3__                    are   true      and   correct          further        swear       or        affirm       that



                                        nor any partner                    proprietor      principal       officer         or    director     has any       proprietary          interest         in    any account
neither      the    company

classified                   as    that      of         customer           except    as   follows
                solely




      1w-i
                          KATHRYN                       MOLONEY

                     COMMON WEALTH                OF MASSACHUSETTS
                                                                                                                                                         Signature
                              My Commission Expires
                                  June 23 2017


                                                                                                                                                           Title




       69kJ                         1/C

                          otary         Public



This   report             contains           check        all
                                                                 applicable         boxes
             Facing         Page
1X1          Statement            of Financial                Condition

XI           Statement            of    Income           Loss
I1           Statement            of                      in    Financial       Condition
                                        Changes
1X1          Statement            of    Changes           in    Stockholders              Equity    or Partners                 or Sole     Proprietors         Capital

             Statement            of                      in Liabilities            Subordinated           to    Claims         of Creditors
                                        Changes
XI           Computation                of Net          Capital
                                                                             of Reserve                                    Pursuant         to    Rule    15c3-3
             Computation                for       Determination                                 Requirements

             Information                                 to    the    Possession          or   Control      Requirements               Under Rule            15c3-3
                                       Relating
                                                                                                                of the     Computation             of Net     Capital     Under Rule                   5c3-1       and    the
                   Reconciliation                 including           appropriate         explanation

                                        for       Determination              of the Reserve          Requirements                  Under Exhibit               of Rule        15c3-3
             Computation
                                                                                               unaudited          Statements           of Financial         Condition         with                          to   methods         of
                   Reconciliation                 between            the   audited     and                                                                                              respect


             consolidation

XI           An     Oath      or    Affirmation

                   copy      of   the     SIPC          Supplemental           Report
                                                                                                   found        to exist    or    found     to    have    existed     since      the   date    of      the   previous audit
                   report    describing             any material             inadequacies



For conditions                of confidential                   treatment       of certain portions                of   this     filing       see section 240.1           7a-5e


                  Piret Securities             Inc
Newbury

Subsidiary   of   Newbury   Piret      Company   Inc


       Annual Audited               Report

       Form       X-1 7A-5          Part III



             December 31 2013


                  Piret Securities                  Inc
Newbury
                 of    Newbury       Piret       Company      Inc
  Subsidiary




Index     to    Financial Statements
December         31     2013




                                                                                              1-2
                      Auditors       Report
 Independent


 Statement of Financial Condition


 Statement of Income



  Statement of Changes in Stockholders                       Equity



  Statement of Cash Flows

                                                                                              7-10
  Notes    to   Financial Statements




                             Information
  Supplementary


                                                               Under Rule    5c3-1   of the
  Schedule             Computation           of Net Capital

                                                               Computation   of Basic Net
   Securities         and    Exchange Commission
                                                           of Aggregate   Indebtedness
   Capital Requirement                  Computation
                                                                                              11-12
   Reconciliation of Net               Capital



                        Information Relating          to   Requirements
  Schedule       II
                                                                                               13
          Broker-Dealers         Under Rule          5c3-3
   for



                                                                                               14
  Schedule       ifi        Report   on Material Inadequacies


                MILLER               WACHMAN                             LLP
                CERTIFIED              PUBLIC            ACCOUNTANTS




                                                                          Independent Auditors Report



To      the     Board         of Directors              and Stockholder

Newbury            Piret        Securities              Inc

Waltham            Massachusetts




Report on Financial                             Statements


We      have       audited           the     accompanying                     statement         of    financial          condition            of   Newbury                Piret        Securities             Inc           wholly
owned                                 of Newbury
                subsidiary                                         Piret            Company                Inc     as    of    December               31 2013                 and       the       related       statements           of
operations              changes            in        stockholders             equity      and    cash        flows       for       the year then               ended          that     are        filed                     to    rule
                                                                                                                                                                                                           pursuant
17a-5       under the Securities                        Exchange              Act of 1934             and the       related          notes      to     the     financial             statements


Managements                     Responsibifity                     for the Financial                 Statements


Management                 is
                                 responsible              for the preparation                    and       fair                               of these            financial            statements             in   accordance
                                                                                                                   presentation
with       accounting                principles                                                       in    the     United            States         of
                                                           generally                accepted                                                                 America                 this         includes         the     design
implementation                   and maintenance                         of   internal        control       relevant          to    the preparation                   and      fair        presentation            of    financial

statements             that     are    free          from material            misstatement                 whether due              to   fraud or error


Auditors               Responsibility


Our responsibility                    is    to       express        an    opinion        on these           financial          statements            based           on our audit                     We      conducted           our
audit      in    accordance                with       auditing           standards                                                           United                           of   America
                                                                                          generally          accepted              in the                      States                                     Those         standards

require         that    we      plan        and perform the audit                        to   obtain        reasonable              assurance           about         whether               the     financial         statements
are     free    of material            misstatement


An      audit      involves            performing                  procedures            to    obtain        audit       evidence             about          the      amounts                and      disclosures           in    the
financial         statements                 The        procedures             selected                          on the auditors                                                               the assessment
                                                                                                depend                                         judgment                  including                                           of the
risks      of    material         misstatement                     of    the fmancial                                    whether            due      to      fraud                             In                     those       risk
                                                                                                 statements                                                              or error                     making
assessments              the auditor                  considers          internal        control       relevant          to   the entitys preparation                              and       fair                            of the
                                                                                                                                                                                                      presentation
financial         statements               in    order     to      design       audit procedures                  that    are                                in    the
                                                                                                                                    appropriate                           circumstances                       but not for the

puqiose          of expressing                  an     opinion          on    the    effectiveness           of    the                      internal         control
                                                                                                                          entitys                                              Accordingly                    we express           no
such       opinion              An     audit           also        includes          evaluating            the     appropriateness                     of      accounting                   policies          used        and     the

reasonableness                  of     significant              accounting               estimates          made by management                                  as    well           as      evaluating            the     overall

presentation             of the       financial           statements


We      believe         that     the audit             evidence           we have        obtained           is   sufficient          and appropriate                     to    provide                basis     for      our audit

opinion


Opinion

In   our       opinion           the       financial          statements             referred         to    above                                         in    all   material
                                                                                                                         present            fairly                                                              the      financial
                                                                                                                                                                                             respects
position         of Newbury                 Piret                             Inc as of December
                                                        Securities                                                      31 2013 and                  the     results          of     its
                                                                                                                                                                                             operations            and    its    cash
flows      for    the                            ended
                         year then                            in   accordance             with       accounting           principles generally                        accepted               in    the United            States      of
America




                                                                                                           Page



                                member          of         International             world-wide        oraganization          of
                                                                                                                                   accounting        firms     and    business             advisers


Newbury       Piret       Securities          Inc

WalthamMassachusetts




Other Matter

                                                                                                                                                                                       whole          The
                          conducted                  the                      of    forming           an   opinion      on the fmancial              statements             as
Our audit was                                 for            purpose
                                                                                                                     for                     of   additional          analysis         and     is    not
information         contained            in   Schedules                 II    and   III    are   presented                  purposes
                                                                                                                                                                                                       the
                             the        fmancial                              but   is    supplementary               information            required       by Rule               7a-5       under
required      part      of                               statements
                                                                                                                                        of                        and was derived                    from
                                    Act of         1934          Such        information         is    the    responsibility                 management
Securities        Exchange
                                                                                                                                                     the    fmancial             statements           The
                                         the underlying            accounting            and     other records             used    to   prepare
and    relates     directly        to

                                                                                                                   the auditing                            applied          in the     audit        of the
information         in    Schedules                 II    and    III   has     been      subjected           to                         procedures

                                                                                                                                              and    reconciling             such      information
fmancial      statements            and       certain       additional             procedures including                    comparing
                                                                                                                                  the   financial        statements         or    to   the    fmancial
             to   the    underlying           accounting          and other records used                      to    prepare
directly
                                                                                                      in   accordance          with      auditing        standards          generally         accepted
statements         themselves and other additional                             procedures
                                                                                          the    information           in   Schedules               II    and   III    is   fairly     stated        in all
in   the   United        States     of America              In   our     opinion
                                                         the basic      financial         statements          as      whole
material     respects         in   relation     to




Holliston         Massachusetts

February          25 2014




                                                                                                  Page


Newbury          Piret       Securities Inc

    subsidiary of               Newbury             Piret         Company Inc

Statement of Financial Condition
December 31 2013




                                                                   Assets

                                                                                                                               3427
Cash
                                                                                                                               11424
Marketable       securities
                                                                                                                                 514
Interest   receivable       from     parent    company
                                                                                                                                 504
Prepaid expenses                                                                                                               9102
Note   receivable       from    parent    company
                                                                                                                               11.873
Due    from   parent company
                                                                                                                               36844
Total Assets




                                                Liabilities    and Stockholders            Equity




Liabilities
                                                                                                                                3195
  Accounts                     and   accrued     expenses
                 payable
                                                                                                                                3195
      Total liabilities



 Stockholders         Equity

      Common        stock    $1 par value

       Authorized        80000       shares
                                                                                                                                2723
                                             2723   shares
       Issued and       outstanding
                                                                                                                               20637
      Additional     paid-in       capital
                                                                                                                               10289
      Retained     Earnings
                                                                                                                               33649
           Total Stockholders             Equity

                                                                                                                                36844
 Total Liabilities          and Stockholders            Equity




                                                                                                            ofthesefInancial   statements
                                                              auditors    report   are   an integral part
      The accompanying          notes    and   independent

                                                                         Page


Newbury       Piret     Securities Inc

   subsidiary of           Newbury             Piret        Company Inc

Statement of Operations
Year Ended December 31 2013




Revenues
                                                                                                                     19302
   Fee   income
                                                                                                                         484
   investment     income
                                                                                                                     19.786



 Expenses
                                                                                                                       3443
   Compensation and         benefits
                                                                                                                      12963
   General and     administrative
                                                                                                                         814
   Occupancy
                                                                                                                      17220


                                                                                                                       2566
 Net Income




                                   and                 auditors    report   are   an integral part   of these financial statements
   The accompanying        notes         independent

                                                                  Page


Newbury      Piret Securities Inc

   subsidiary of       Newbury             Piret        Company Inc

Statement of Changes           in   Stockholder               Equity

Year Ended    December 31           2013




                                                              Common          Additional

                                                                               Paid-Tn           Retained

                                                                                                                    Total
                                                               Stock           Capital           Eaming




                                                              $2723              20637               7723            31083
BalanceatBegiiiniflgOfYear

                                                                                                     2566              2566
Net Income


                                                              $2723              20637              10289            33649
BalanceatEndofYear




                                                                        are   an integral part   ofthesefinancial   statements
   The accompanying   notes   and independent      auditors    report

                                                              Page


                Piret Securities                 Inc
Newbury
   subsidiary of              Newbury             Piret           Company Inc

Statement of Cash Flows
Year Ended December 31 2013




                                          Activities
Cash Flows from Operating
                                                                                                                               2566
  Net    Income


               in   operating    assets   and   liabilities
   Change
                                                                                                                                284
        Interest    receivable
                                                                                                                                   82
        Prepaid expenses
                                                                                                                              1273
        Due    from parent company
                                                                                                                              326O1
                      payable and
        Accounts                        accrued        expenses
                                                                                                                              2.1 691
              Cash used by                      activities
                                 operating




                                          Activities
Cash Flows from Investing
   Purchase     of marketable         securities


   Collection       of note receivable          parent    company

        Cash provided         by   investing     activities



                                                                                                                               2161
Net Decrease         in   Cash
                                                                                                                                5588
Cash    at   Beginning      of Year

                                                                                                                                3427
 Cash   at   End    of Year




                                                              auditors             are   an integral part   of these financial statements
   The accompanying          notes   and independent                      report

                                                                         Page


Newbury            Piret             Securities Inc

       subsidiary of                  Newbury                 Piret                Company Inc

Notes      to    Financial Statements

December 31 2013




Note            Nature of Business


                                                                                                                                                   with     the    Securities        and
Newbury         Piret    Securities           Inc     the     Company                is             broker-dealer              registered

                                                                         member                of                                                    Regulatory           Authority
Exchange         Commission                  SEC       and      is                                    the     Financial           Industry

                                                                                                services           and    does not hold funds or securities for
FINRA            The Company provides                        financial       advisory

the   accounts     of    its    customers

                                                                                                                                                     Inc     and    serves        as the
The                     is       wholly           owned      subsidiary        of   Newbury                  Piret       and    Company
        Company
                                                                                                                   dealer      license       is    held
                                                             associated with the broker
Company through which                        activities




                                                              Accounting             Policies
Note            Summary               of Significant



Basis of Accoujng



                                                                                     statements in accordance                            with accounting                 principles
                                             to               its    financial
The Companys              policy        is        prepare
                                                                                                                                basis     of accounting               The       accrual
                                 in the      United        States    of America under                       the    accrual
generally       accepted
                                                                                                                  rather       than when           received        and    records
                                                               in the                          is   earned
basis    of accounting               records revenue                        period       it




                in the                  in   which         incurred rather          than        when         paid
expenses                 period



Use of Estimates


                                                                       in                              with accounting                 principles           generally          accepted
The                          of financial            statements               conformity
        preparation
                                                                                                             make        estimates           and    assumptions            that    affect
in the    United        States        of America requires                management                    to

                                                                                                                   of contingent              assets       and    liabilities      at   the
                                       of assets and                               and        disclosure
the     reported    amounts                                    liabilities

                                                                                                                     of revenues               and                        during        the
                    financial           statements            and     the     reported              amounts                                            expenses
date     of the
                               Actual        results       could     differ    from       those estimates
reporting       period




Note            Related         Party



                                                                                                                                                                                          an
                                                                                              On December                      2012      the    Company entered                   into
 The Company                                       space with               parent
                                       office                         its
                         shares
                                                                                                                                              the Company for                   services
                   with        its    parent       company           whereby         the        parent            company pays
 agreement
                                                                                                                                for    its    share       of allocated            indirect
 performed          In       addition          the    Company          pays        the        parent         company
                                                                                                                                                                          to
 overhead        costs         Such      costs       are    recorded         and     paid           throughout            the    year and            are    subject             periodic

                                                                                                                                      earned                       for services          and
                                with the agreement during 2013 the Company                                                                         $18480
 review     In accordance

                        allocated  costs in accordance with the agreement
 paid $5124         for




                                                                                     Page


                       Piret Securities                           Inc
Newbury
       subsidiary of                      Newbury                  Piret                  Company Inc

Notes         to   Financial Statements
December 31 2013




Note            Related           Party         continued


                                                                        consists          of     $10020           unsecured           promissory             note dated            May 13
Note     receivable          from        parent        company
                                                                                                                                                                                             of
                                                                        and    accrues         interest          of   5% annually            The outstanding                    balance
2010 The note                is   payable on demand
                                                                                                            on   the   note was        $484
the    note as of December                      31 2013 was $9102                         Interest



                                                                                  with no                               terms and          no   interest          is    being charged
Due     from                                         is     receivable                            repayment
                   parent         company
The balance            at    December 31 2013 was $11873



Note               Net Capital ReQuirements


                                                                                                                      Commissions Uniform                         Net     Capital         Rule
The                                               to      the    Securities          and       Exchange
        Company              is     subject
                                                                                                                                                                           that     the ratio
                                                                         maintenance                 of minimum net capital and                            requires
SEC       Rule         5c3-1 which                requires        the

                                                                               both       as   defined           shall    not     exceed        15    to           At December               31
of aggregate indebtedness                         to      net    capital
                                                                                            of $11428                                  which was $6428                        in   excess        of
                                                                               rule l5c3-1
2013      the      Company had                  net capital        pursuant to
                                                                                         of                                            indebtedness               to    net     capital     was
its                    net   capital        of    $5000           The Companys     ratio    aggregated
       required

0.27     to




Note                Fair Value Measurements



                       Standards Codification Topic                                 820    Fair      Value Measurements                      and      Disclosures               ASC 820
Accounting
                                                                                                 That        framework provides                       fair    value hierarchy that
                        framework               for    measuring           fair     value
establishes
                                                                                           used        to    measure          fair    value          The      hierarchy gives                the
                    the                    to    valuation         techniques
prioritizes                  inputs
                                                                                     in active          markets for identical                   assets       or    liabilities        level
highest        priority        to   unadjusted             quoted       prices
                                                                                                                                              measurements                         The    three
                               and       the    lowest                         to    unobservable                inputs       level
measurements                                                    priority

 levels       of the    fair      value hierarchy under                    ASC           820   are     described         as   follows



                                                                                                                                              prices         for       identical
                                  to     the    valuation          methodology                   are    unadjusted              quoted
 Level             Inputs
                                                                         markets          that    the       Company           has the ability to access
                   assets or           liabilities        in active



                                                                                                                                      for similar assets or                   liabilities        in
                                  to the    valuation           methodology                include          quoted       prices
 Level             Inputs
                                                                                                       or similar assets              or   liabilities        in inactive          markets
                   active         markets quoted                prices        for identical
                                                                                                                                                                                   that   are
                                  other than quoted               prices        that are observable                    for the       asset or liability                inputs
                   inputs
                                                                                                                                                     by      correlation           or other
                   derived principally                    from     or   corroborated              by observable               market data
                                                                                                                                                                                   must     be
                                                                               has         specified         contractual              term      the    level            input
                   means            If the asset or liability

                   observable             for substantially              the      full    term of the asset or liability




                                                                                               Page


                         Piret Securities                             Inc
Newbury
      subsidiary of Newbury Piret                                                          Company Inc

Notes        to    Financial Statements
December              31       2013




Note               Fair Value Measurements                                    continuedi


                                                                                                     unobservable                    and                                 to    the    fair
                                       the     valuation             methodology             are                                                    significant
Level             Inputs         to
                                                                                                                                                              level      within        the
                                                           The                                            fair    value measurement
                  value measurement                                   asset       or liabilitys
                                                                                                                                               that                               to the
                                                           is   based        on   the    lowest level of any input                                     is   significant
                  fair    value hierarchy
                                                                                                                               need                  maximize            the     use      of
                                                                        Valuation          techniques              used                        to
                  fair    value         measurement
                  observable                             and    minimize           the    use of unobservable                       inputs
                                         inputs


                                                                                                                                                                                                  value
                                                                                                                  used for investments                             measured          at   fair
                   is       description              of the valuation methodologies
Following




                                                         include        mutual        funds          In    general            and         where         applicable               we       use    quoted
Investments                 Investments
                                                                                                   liabilities           to      determine                  fair    value            This        pricing
                                  markets            for       identical          assets     or
prices       in    active

methodology               applies        to our Level                      investments



                                                                                                                                                     value     on             recurring         basis     at
                                                                 the Companys                assets         measured                at    fair
The        following           table     represents

December            31 2013

                                                                                                                                               Level


                                                                                                                                                11.424
              Marketable               securities



                         securities                             readily         marketable          shares         in   mutual funds invested                            in    money market
Marketable                                    represent
                                                                                                                           bank                                    and    commercial              paper
                                                                            Government                                                    obligations
                          primarily United
instruments                                                    States                             obligations
                                                                                                                                                             of $1.00
           fund manages                                         to    maintain            constant         market price                  per share
The                                    its    portfolio



 Note              Income              Taxes


                                                                              consolidated              basis     with                               company             which has              elected
 The Company                   files    its   tax    returns          on                                                      its    parent

                                                                                                                                         tax                        whereby           all    elements
                                                                     for   both    federal        and     state     income                      purposes
 to   be    treated       as    an       corporation
                                                                                              return        of the stockholder                         of the       Company               Therefore
 of income and                 deduction            are included             in the tax


 no income            tax      provision            is   recorded          by   the     Company

                                                                                                                                 material             uncertain           tax     positions         to    be
                                                                                                                 has no
 For the          year ended
                                         December               31 2013             the    Company
                                                                                                             and                         income         tax        returns        are       subject        to
                                       the      financial             statements            Federal                      state
 accounted               for     in
                                                                                                                                                                                          Federal and
                                               authorities             for                   of three            years     from the date                    they are filed
 examination              by taxing                                               period
                                                                                                                                 examination                         the taxing           authorities
            income        tax     returns        for      2012 2011               and     2010     are subject             to                                 by
 state




                                                                                              Page


Newbury            Piret       Securities Inc

      subsidiary of              Newbury             Piret          Company Inc

Notes       to   Financial Statements

December 31 2013




Note             Subsequent       Events


                                                                                                                            and     transactions        for
                                                                                                             events
In                     these   financial        statements    the Company has evaluated
      preparing                                                                                                                     statements were
                                                                                the date                     the    financial
                                                    through    February 25 2014
potential    recognition or disclosure

available    to   be    issued




Note             Part X-17A-5


                                                                                                              for   examination          and    copying
                          most   recent    annual report      on Form X-        7A-5      is   available
The Companys                                                                                                                                   Securities
                                                                                          Boston                       office       of the
                                                                 office   or   at   the                Regional
at    the   Companys Waltham                Massachusetts

and    Exchange Commission



Note             Commitments and ContingencI

                                                                                                                    arbitration      claims       and   has
                                                                                                   lawsuits
                                                         does not have         any   pending
The     company has made no guarantees                                                                                                          under    an
                                                                                                that    is   owed      to     its   parent
       commitments             except     for    approximately      $4632      per    year
 no

 agreement        dated    February       25 2014




                                                                      Page     10


                     Piret Securities             Inc
Newbury
Schedule
December          31    2013




                                                                15c3-1                               Securities   and
                                      of Net Capital Under Rule                             of the
               Computation
                                              Exchange   Commission


                                                                                                                    33649
Total    Capital


Deductions           for Nonallowable        Assets
                                                                                                                         1018
   Other assets
                                                                                                                        20.975
   Notes       and    loans    receivable
                                                                                                                        11656
         Net    capital before       haircuts



Haircuts       on Securities         computed       where   applicable

pursuant        to    15c3-1f
                                                                                                                           228
   Stocks       and    money market accounts
                                                                                                                        11.428
Net Capital




                                  Computation           of Basic Net Capital Requirement

                                                                                                                           213
Minimum         Net               Required        2/3%    of total aggregate indebtedness
                       Capital


                                                            of Reporting     Broker    or   Dealer                       5.000
Minimum         Dollar Net Capital          Requirement

                                                                                              or
          Requirement Greater of Minimum        Capital          Net            Required
Net   Capital
                                           Accordance                           with Rule       5c3-l                    5000
 Minimum Dollar Net Capital Requirement in


                                                                                                                          6.428
Excess Net           Capital



                                            10%   of aggregate   indebtedness         or    120% of
Net     capital      less   greater of
                                                                                                                         5.428
minimum           dollar net capital         requirement




                                                                 Page   11


Newbury            Piret Securities Inc

Schedule            Continued
December          31   2013




                                                                                        Indebtedness
                                      Computation           of Aggregate

                                                                                                                                   3195
Total Liabilities



   Subordinated         debt

                                                                                                                                   3195
   Total      Aggregate Indebtedness

                                                                                                                                   27.96
                  of Aggregate    Indebtedness to Net Capital
Percentage




                                                    Reconciliation       of Net Capital

                                                                                                                                  11.428
                                 on   Part   11A Focus    Report
  Net   Capital     reported


                                                                                                                                  11428
                                        financial    statements
  Net Capital per audited

                                                                                            of   net              and   the    corresponding
                                 difference      between      this   computation                        capital
There    is   no    material

                                                         for inclusion      in    its   unaudited      Part   hA FOCUS        Report   filing   as
computation         prepared by the          Company
of December         31 2013




                                                                     Page    12


Newbury             Piret     Securities Inc

                                                         to   Requirements
Schedule II- Information Relating

for Broker-Dealers                Under Rule 15c3-3

December 31 2013




                                                              Requirements Under Rule
                                                                                      15c3-3                of the    SEC
Computation     for Determination            of the Reserve




   The Company        operates under        the   exemptive   provisions of Paragraph            k2i   of   SEC      Rule    5c3-3




                                                                          Rule 15c3-3                       of the    SEC
                            to   Possession or Control Requirements Under
Information     Relating




   The   Company       operates      under     the   exemptive    provisions      of Paragraph     k2i        of     SEC    Rule

                                                                                                 funds or   securities      as   of
                                                                             of any   customer
     5c3-3    and   did not      maintain    possession or control

   December 31 2013




                                                                 Page   13


                    Piret Securities               Inc
Newbury
Schedule        III       Report on Material Inadequacies
Year Ended           December 31 2013




                                          Report on Material Inadequacies




                                                                            Piret   Securities   Inc   for the   year ended
                                               statements of Newbury
We   have    audited the financial
                                                                                                                       found   to   have
                                                                                     inadequacies existing        or
                                                did not disclose   any material
December       31 2013           Our   audit

                    the   date   of the previous      audit
existed     since




 ki\ \JGNM\
Holliston      Massachusetts

February      25 2014




                                                                     Page    14


                MILLER             WACHMAN                       LLP
                CERTIFIED           PUBLIC          ACCOUNTANTS
                www.millerwachman.com


                760    Washington          Street

                Holliston         MA 01746
                Tel        508    429-2395

                Fax        508    429-8797                                                                                                                                              Offices     in

                email        holliston@millerwachman.com                                                                                                                                Boston      and       Worcester




To    the Board            of Directors             and Stockholder                          of

Newbury          Piret       Securities             Inc

Waltham           Massachusetts




In planning            and performing our audit of the financial statements                                                                and supplemental                       schedules              of

Newbury          Piret       Securities             Inc       the         Company                 as   of and for the year ended December 31 2013                                                        in

accordance             with       auditing               standards               generally             accepted            in   the        United          States           of America                we
considered            the    Companys                internal             control          over      financial reporting                                                                  basis for
                                                                                                                                              internal control                    as

designing            our auditing               procedures                     for    the     purpose          of expressing                   our      opinion              on the       financial

statements             but        not     for       the        purpose                of expressing                 an       opinion           on      the       effectiveness                 of the

Companys              internal          control              Accordingly                     we     do not         express           an    opinion          on the effectiveness                         of
the   Companys               internal         control


Also      as    required           by Rule               l7a-5g1                      of the        Securities            and Exchange                     Commission                  SEC           we
have      made               study         of the              practices               and                                 followed              by     the
                                                                                                  procedures                                                      Company                including
consideration               of control          activities                for safeguarding                   securities               This       study          included          tests       of such

practices and procedures                         that         we         considered            relevant        to       the     objectives            stated          in    Rule        7a-5g            in

making         the periodic             computations                      of aggregate              indebtedness                or        aggregate             debits           and net       capital

under Rule                 7a-3           11    and for determining                               compliance               with       the exemptive                    provisions             of Rule

15c3-3         Because            the      Company                       does        not     carry      securities              accounts             for     customers              or     perform
custodial         functions             relating               to        customer             securities                we      did        not       review            the       practices           and
procedures            followed by the Company                                   in    any of the following

      Making           the    quarterly             securities                                                                                          and comparisons and the
                                                                               examinations counts                         verifications
          recordation             of differences required                              by Rule              7a- 13


       Complying                 with     the       requirements                       for                                           for      securities          under           Section                of
                                                                                              prompt          payment
          Federal          Reserve         Regulation                          of the Board of Governors of the Federal                                           Reserve              System

The management of                       the    Company                    is   responsible             for establishing                   and maintaining                    internal         control

and    the     practices            and       procedures                       referred        to      in    the        preceding             paragraph                     In   fulfilling         this

responsibility               estimates           and judgments                             by management                      are     required             to     assess the             expected
benefits       and related                costs          of controls                  and     of the                              and procedures                       referred                in    the
                                                                                                             practices                                                                   to

preceding         paragraph               and       to     assess              whether         those        practices           and procedures                        can    be expected                 to

achieve        the    SECs        previously                mentioned                  objectives             Two         of the objectives of                        internal      control and
the    practices            and     procedures                   are       to                                                     with         reasonable                  but    not     absolute
                                                                                     provide         management
assurance        that       assets      for     which the Company has responsibility are                                                                                                loss      from
                                                                                         safeguarded                                                                       against
unauthorized                use      or       disposition                      and     that         transactions                are        executed              in        accordance               with

managements                  authorization                    and          recorded            properly             to       permit           the      preparation                 of    financial

statements            in    conformity              with            generally                                                                                     Rule            7a-5
                                                                                           accepted           accounting               principles                                                   lists


additional       objectives             of the practices and procedures                                       listed       in   the preceding                   paragraph


                              member      of             International          world-wide     oraganization       of   accounting    firms    and    business    advisers


 Newbury             Piret      Securities          Inc

 WalthamMassachusetts                                                                                                                                                     Page



Because          of inherent                limitations             in   internal          control        and the practices and procedures                                          referred          to

above        error        or fraud           may      occur         and not be detected                       Also            projection             of any evaluation                    of them
       future
                                                                                                   may become
to               periods                                 to    the risk            that
                                      is    subject                                        they                                        inadequate           because          of changes               in
conditions            or that         the effectiveness                  of   their                    and operation
                                                                                          design                                        may     deteriorate


     deficiency            in       internal control                exists      when        the    design              or operation               of        control       does not allow

management                     or    employees            in       the     normal           course         of performing                       their        assigned           functions              to

prevent      or detect                misstatements                on         timely basis                    significant deficiency                          is         deficiency              or
combination                of deficiencies                    in   internal         control        that      is    less       severe          than          material       weakness               yet
important            enough           to    merit     attention           by those charged with governance

     material          weakness               is
                                                      deficiency               or combination                     of                                   in    internal                            such
                                                                                                                            deficiencies                                       control
that     there       is             reasonable                                  that           material           misstatement of the
                                                        possibility                                                                                              companys                financial

statements            will      not be prevented                   or detected             and corrected                on             timely basis

Our     consideration                  of   internal      control          was       for   the limited purpose described                                    in   the     first   and second
paragraphs            and would               not                                                       deficiencies
                                                        necessarily identify                     all                                   in    internal        control         that    might be
material        weaknesses                         We    did        not       identify         any      deficiencies                    in    internal           control         and      control
activities       for           safeguarding             securities            that        we    consider               to     be material              weaknesses                   as    defined

previously


We      understand                  that    practices         and procedures                    that
                                                                                                          accomplish                   the    objectives            referred         to     in    the
second       paragraph                 of   this    report          are considered                by      the      SEC            to    be adequate                for   its                          in
                                                                                                                                                                                 purposes
accordance            with           the Securities            Exchange              Act of 1934 and related regulations                                            and      that    practices
and procedures                  that       do not accomplish                    such       objectives             in    all   material                             indicate              material
                                                                                                                                                  respects
inadequacy            for       such                           Based on
                                           purposes                                 this    understanding                     and on our study                     we    believe          that    the

Companys              practices             and procedures                    as    described           in    the           second                               of   this
                                                                                                                                            paragraph                          report        were
adequate        at    December 31 2013                         to    meet the             SECs         objectives


This     report           is    intended           solely for             the      information               and            the              of      the
                                                                                                                                   use                        Board          of Directors
management                 the       SEC F1NRA                 and other regulatory                       agencies            that       rely on Rule                 7a-5g          under the
Securities           Exchange               Act of 1934             in    their      regulation           of registered brokers                          and dealers                and     is    not
intended        to    be and should                 not be used by anyone                         other than                these specified parties




Holliston        Massachusetts

February        25        2014



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