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Clear Street Derivatives LLC – ‘SBSE’ on 9/28/23

On: Thursday, 9/28/23, at 3:40pm ET · Accession #: 1983408-23-5 · File #: 26-00231

  As Of               Filer                 Filing    For·On·As Docs:Size

 9/28/23  Clear Street Derivatives LLC      SBSE                   2:219K

Application for Registration by a Security-Based Swap Dealer or Major Security-Based Swap Participant — Form SBSE

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: SBSE        Application for Registration by a Security-Based    HTML     25K 
                Swap Dealer or Major Security-Based Swap                         
                Participant -- primary_doc.xml                                   
 2: EX-99.35 OTHER  Supplemental Information -- ex99.35              PDF    195K

‘SBSE’ — Application for Registration by a Security-Based Swap Dealer or Major Security-Based Swap Participant — primary_doc.xml

This ‘SBSE’ Document is an XML Data File that may be rendered in various formats:

Form SBSE – Plain Text – SEC Website – EDGAR System – XML Data – <?xml?> File

SEC Info℠ rendering: Application for Registration by a Security-Based Swap Dealer or Major Security-Based Swap Participant

SBSE: Filer Information

Filer CIK

0001983408

Filer CCC

**********

Is this a LIVE or TEST Filing?

LIVE

TEST

Would you like a Return Copy?

Submission Contact Information

Name

Phone

E-Mail Address

Notify via Filing Website only?

Notification E-mail Address

SBSE: Applicant Data - Page 1

FORM SBSE

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

WARNING: Failure to keep this form current and to file accurate supplementary information on a timely basis, or the failure to keep accurate books and records or otherwise to comply with the provisions of law applying to the conduct of business as an SBS Entity, would violate the Federal securities laws and may result in disciplinary, administrative, injunctive or criminal action.

INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACTS MAY CONSTITUTE FEDERAL CRIMINAL VIOLATIONS.

See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a)

1. Exact name, principal business address, mailing address, if different, and telephone number of the applicant:

A. Full name of the applicant:

Clear Street Derivatives LLC

B. Tax Identification No.:

88-2035501

Applicant's UIC # (if any):

Applicant's CIK #:

0001983408

C (1). The business name under which the applicant primarily conducts business, if different from 1A.

(2). List on Schedule D, Page 1, Section I any other name by which the applicant conducts business and where it is used.

D. If this filing makes a name change on behalf of an applicant, enter the new name and specify whether the change is to the applicant's name (1A) or to the business name (1C):

Applicant's name (1A) Radio button not checked

Business name (1C)

Please check above.

Name:

E. Applicant's Main Address: (Do not use a P.O. Box)

Street Address 1:

4WTC 150 GREENWICH STREET

Street Address 2:

FLOOR 45

City:

NEW YORK

State/Province/Country:

NEW YORK

Zip/ Postal Code:

10007

Other business locations must be reported on Schedule E. Security-based swap dealers and major security-based swap participants that do not reside in the United States of America shall designate a U.S. agent for service of process on Schedule F.

F. Mailing Address, if different:

Street Address 1:

4WTC 150 GREENWICH STREET

Street Address 2:

FLOOR 45

City:

NEW YORK

State/Province/Country:

NEW YORK

Zip/ Postal Code:

10007

G. Business Telephone Number:

646-845-0036

H. Website/URL:

I. Contact Employee:

Prefix:

First Name:

Ursula

Middle Name:

Last Name:

Clay

Suffix:

Title:

Chief Compliance Officer

Phone:

646-876-2616

Email Address:

uclay@clearstreet.io

J. Chief Compliance Officer designated by the applicant in accordance with Exchange Act Section 15F(k):

Prefix:

First Name:

Ursula

Middle Name:

Last Name:

Clay

Suffix:

Title:

Chief Compliance Officer

Phone:

646-876-2616

E-Mail Address:

uclay@clearstreet.io

SBSE: EXECUTION

EXECUTION:

The applicant consents that service of any civil action brought by or notice of any proceeding before the Securities and Exchange Commission in connection with the applicant's security-based swap activities, unless the applicant is a nonresident SBS Entity, may be given by registered or certified mail or confirmed telegram to the applicant's contact employee at the main address, or mailing address if different, given in Items 1E and 1F. If the applicant is a nonresident SBS Entity, it must complete Schedule F to designate a U.S. agent for service of process. The undersigned certifies that he/she has executed this form on behalf of, and with the authority of, said applicant. The undersigned and applicant represent that the information and statements contained herein, including schedules attached hereto, and other information filed herewith are current, true and complete. The undersigned and applicant further represent that to the extent any information previously submitted is not amended such information is currently accurate and complete.

Date

9/28/23

Name of Applicant

Clear Street Derivatives LLC

By: Signature

Ursula Clay

Name of Person Signing on Applicant's behalf

Ursula Clay

Title of Person Signing on Applicant's behalf

Chief Compliance Officer

SBSE: Applicant Data - Page 2

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

2.

A. The applicant is registering as a security-based swap dealer:

Yes

B. The applicant is registering as a major security-based swap participant:

Yes

3.

A. Is the applicant a foreign security-based swap dealer that intends to:

work with the Commission and its primary regulator to have the Commission determine whether the requirements of its primary regulator's regulatory system are comparable to the Commission's

Yes

avail itself of a previously granted substituted compliance determination

Yes

with respect to the requirements of Section 15F of the Exchange Act of 1934 and the rules and regulations thereunder?

4.

Does the applicant intend to compute capital or margin, or price customer or proprietary positions, using mathematical models?

Yes

5.

Is the applicant subject to regulation by a prudential regulator, as defined in Section 1a(39) of the Commodity Exchange Act.

Yes

6.

Is the applicant a U.S. branch of a non-resident entity?

Yes

7.

Briefly describe the applicant's business:

Clear Street Derivatives (CSD) offers clients exposure to securities through Total Return Swaps (TRS) and fully hedges CSD's market exposure by creating a delta neutral position by purchasing the underlying securities.

8.

A. Indicate legal status of the applicant:

Corporation
Radio button not checked

Partnership
Radio button checked

Limited Liability Company
Radio button not checked

Other (specify)

B. Month applicant's fiscal year ends:

January

February

March

April

May

June

July

August

September

October

November

December

C. Indicate date and place applicant obtained its legal status (i.e., state or country where incorporated, where partnership agreement was filed, or where applicant entity was formed):

State of formation:

DELAWARE

Country of formation:

UNITED STATES

Date of formation:

1/27/22

Schedule A and, if applicable, Schedule B must be completed as part of all initial applications.

9.

Is the applicant at the time of this filing succeeding to the business of a currently registered SBS Entity?

Yes

If "Yes," complete appropriate items on Schedule D, Page 1, Section III.

10.

Does the applicant hold or maintain any funds or securities to collateralize counterparty Transactions?

Yes

SBSE: Applicant Data - Page 3

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

11.

Does the applicant have any arrangement:

A. With any other person, firm, or organization under which any books or records of the applicant are kept, maintained, or audited by such other person, firm or organization?

Yes

B. Under which any other person, firm or organization executes, trades, custodies, clears or settles on behalf of the applicant (including any SRO or swap execution facility in which the applicant is a member)?

Yes

If "Yes" to any part of Item 11, complete appropriate items on Schedule D, Page 1, Section IV.

12.

Does any person directly or indirectly:

A. Control the management or policies of the applicant through agreement or otherwise?

Yes

B. Wholly or partially finance the business of the applicant?
Do not answer "Yes" to 12B if the person finances the business of the applicant through: 1) a public offering of securities made pursuant to the Securities Act of 1933; or 2) credit extended in the ordinary course of business by suppliers, banks, and others.

Yes

If "Yes" to any part of Item 12, complete appropriate items on Schedule D, Page 1, Section IV.

13.

A. Directly or indirectly, does the applicant control, is the applicant controlled by, or is the applicant under common control with, any partnership, corporation, or other organization that is engaged in the securities or investment advisory business?

Yes

If "Yes" to item 13A, complete appropriate items on Schedule D, Page 2, Section V.

B. Directly or indirectly, is applicant controlled by any bank holding company or does applicant control, is applicant controlled by, or is applicant under common control with any bank (as defined in 15 U.S.C.78c(a)(6)) or any foreign bank?

Yes

If "Yes" to item 13B, complete appropriate items on Schedule D, Page 3, Section VI.

14.

Use the appropriate DRP for providing details to "yes" answers to the questions in Item 14. Refer to the Explanation of Terms section of Form SBSE Instructions for explanations of italicized terms.

CRIMINAL DISCLOSURE

A. In the past ten years has the applicant or a control affiliate:

(1) Been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign or military court to any felony?

Yes

(2) Been charged with a felony?

Yes

B. In the past ten years has the applicant or a control affiliate:

(1) Been convicted of or pled guilty or or nolo contendere ("no contest") in a domestic, foreign or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?

Yes

(2) Been charged with a misdemeanor specified in 14B(1)?

Yes

SBSE: Applicant Data - Page 4

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

REGULATORY ACTION DISCLOSURE

C. Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:

(1) Found the applicant or a control affiliate to have made a false statement or omission?

Yes

(2) Found the applicant or a control affiliate to have been involved in a violation of its regulations or statutes?

Yes

(3) Found the applicant or a control affiliate to have been a cause of an investment-related business having its authorization to do business denied, revoked, or restricted?

Yes

(4) Entered an order against the applicant or a control affiliate in connection with investment-related activity?

Yes

(5) Imposed a civil money penalty on the applicant or a control affiliate, or ordered the applicant or a control affiliate to cease and desist from any activity?

Yes

D. Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority:

(1) Ever found the applicant or a control affiliate to have made a false statement or omission or been dishonest, unfair, or unethical?

Yes

(2) Ever found the applicant or a control affiliate to have been involved in a violation of investment-related regulations or statutes?

Yes

(3) Ever found the applicant or a control affiliate to have been a cause of an investment-related business having its authorization to do business denied, revoked, or restricted?

Yes

(4) In the past ten years, entered an order against the applicant or a control affiliate in connection with an investment-related activity?

Yes

(5) Ever denied, suspended, or revoked the applicant’s or a control affiliate’s registration or license or otherwise, by order, prevented it from associating with an investment-related business or restricted its activities?

Yes

E. Has any self-regulatory organization:

(1) found the applicant or a control affiliate to have made a false statement or omission?

Yes

(2) found the applicant or a control affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the U.S. Securities and exchange Commission)?

Yes

(3) found the applicant or a control affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?

Yes

(4) Disciplined the applicant or a control affiliate by expelling or suspending it from membership, barring or suspending its association with other members, or otherwise restricting its activities?

Yes

F. Has the applicant's or a control affiliate's authorization to act as an attorney, accountant, or federal contractor ever been revoked or suspended?

Yes

G. Is the applicant or a control affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of 14C, D, or E?

Yes

CIVIL JUDICIAL DISCLOSURE

H. (1) Has any domestic or foreign civil judicial court:

(a) In the past ten years, enjoined the applicant or a control affiliate in connection with any investment-related activity?

Yes

(b) Ever found that the applicant or a control affiliate was involved in a violation of investment-related statutes or regulations?

Yes

(c) Ever dismissed, pursuant to a settlement agreement, an investment-related civil judicial action brought against the applicant or control affiliate by a state or foreign financial regulatory authority?

Yes

(2) Is the applicant or a control affiliate now the subject of any civil judicial proceeding that could result in a "yes" answer to any part of 14H(1)?

Yes

SBSE: Applicant Data - Page 5

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

FINANCIAL DISCLOSURE

I. In the past ten years has the applicant or a control affiliate ever been a securities firm or a futures firm, or a control affiliate of a securities firm or a futures firm that:

(1) Has been the subject of a bankruptcy petition?

Yes

(2) Has had a trustee appointed or a direct payment procedure initiated under the Securities Investor Protection Act?

Yes

15.

Is the applicant registered with the Commission as an investment adviser or municipal securities advisor or with the CFTC as a commodity trading adviser?

Yes

If "yes," provide all unique identification numbers assigned to the firm relating to this business on Schedule D, Page 1, Section II.

16.

A. Does applicant effect transactions in commodity futures, commodities or commodity options as a broker for others or as a dealer for its own account?

Yes

If "yes," provide all unique identification numbers assigned to the firm relating to this business on Schedule D, Page 1, Section II.

B. Does applicant engage in any other investment-related, non-securities business?

Yes

If "yes," provide all unique identification numbers assigned to the firm relating to this business and describe each other business briefly on Schedule D, Page 1, Section II.

17.

Is the applicant registered with a foreign financial regulatory authority?

Yes

If "yes," list all such registrations on Schedule F, Page 1, Section II.

SBSE: Schedule A of FORM SBSE

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

DIRECT OWNERS AND EXECUTIVE OFFICERS(Answer for Form SBSE Item 8)

1. Use Schedule A to provide information on the direct owners and executive officers of the applicant. Use Schedule B to provide information on indirect owners. Complete each column.
2. List below the names of:
- (a) Each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer, Director, and individuals with similar status or function;
- (b) In the case of an applicant that is a corporation, each shareholder that directly owns 5% or more of a class of a voting security of the applicant, unless the applicant is a public reporting company (a company subject to Sections 12 or 15(d) of the Securities Exchange Act of 1934). Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of a voting security of the applicant. For purposes of this Schedule, a person beneficially owns any securities (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in- law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence, or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant or right to purchase the security.
- (c) In the case of an applicant that is a partnership, all general partners, and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or more of the partnership’s capital; and
- (d) In the case of a trust that directly owns 5% or more of a class of a voting security of the applicant, or that has the right to receive upon dissolution, or has contributed, 5% or more of the applicant’s capital, the trust and each trustee.
- (e) In the case of an applicant that is a Limited Liability Company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Are there any indirect owners of the applicant required to be reported on Schedule B?
Yes No
4. In the "DE/FE/I" column, enter "DE" if the owner is a domestic entity, or enter "FE" if owner is an entity incorporated or domiciled in a foreign country, or enter "I" if the owner is an individual.
5. Complete the "Title or Status" column by entering board/management titles; status as partner, trustee, sole proprietor, or shareholder; and for shareholders, the class of securities owned (if more than one is issued).
6. Ownership codes are:
- NA - less than 5%
- A - 5% but less than 10%
- B - 10% but less than 25%
- C - 25% but less than 50%
- D - 50% but less than 75%
- E - 75% or more
7. (a) In the "Control Person" column, enter "Yes" if person has control as defined in the instructions to this form, and enter "No" if the person does not have control. Note that under this definition most executive officers and all 25% owners, general partners, and trustees would be "control persons".

(b) In the "PR" column, enter “PR” if the owner is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button not checked

I (Individual)

Title or Status

Sole Class A Member

Date Title or Status Acquired(MM/YYYY)

01/2022

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

833532659

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

CEO / Director

Date Title or Status Acquired(MM/YYYY)

06/2022

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

003189055

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Pat Travers joined Clear Street in June 2022 from Wells Fargo where he served as Co-Head of Equity Finance and Global Head of Distribution of Equities from 2014 through 2022. Prior to Wells Fargo, Mr. Travers was a Managing Director Head of Prime Finance Sales at BoA/Merrill Lynch from 2009 to 2013.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

Chief Compliance Officer

Date Title or Status Acquired(MM/YYYY)

09/2023

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Before joining Clear Street, Ms. Clay was the CCO of Nearwater Capital, an SEC registered security-based swap dealer, from 2021 to Aug. 2023. Prior to Nearwater, Ms. Clay was a Chief of Staff to the Head of Member Supervision at FINRA from 2019 through 2021. She has also held various senior level compliance and legal roles for over 25 years at Morgan Stanley, Barclays, Exos Securities, Bressler Amery & Ross, and managing her own swap dealer consulting practice.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

General Counsel / Director

Date Title or Status Acquired(MM/YYYY)

09/2021

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Prior to Clear Street, Mr. Gutmanstein served as Assistant General Counsel at Cantor Fitzgerald Securities from 2015 to 2021, where he provided legal and regulatory advice to its broker dealer and swap dealer businesses. Before Cantor, Mr. Gutmanstein was an Associate GC at Convergex Group from 2013 to 2015, providing regulatory guidance and negotiating agreements, including ISDAs, CSAs, and Prime Brokerage agreements for its broker dealer business. From 2007 through 2013, he was a Senior Associate at Lehman & Eilen, representing domestic and foreign broker dealers and security-based swap clients on Dodd-Frank requirements, SEC and FINRA requirements.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

Chief Operations Officer

Date Title or Status Acquired(MM/YYYY)

02/2023

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

005730417

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Prior to Clear Street, Jordan Brodsky led the Client Asset Protection team for Prime Derivative Services at Barclays from 2017 to 2022, responsible for daily Segregation, Secured, and Cleared Swap reporting. Before Barclays, Ms. Brodsky worked at Reval from 2015 to 2017, processing and reporting hedge transactions and hedge accounting. From 2012-2015, she was on the middle-office and back-office teams at Conifer Financial Services (formerly Vastardis Capital Services), responsible for all derivative SMA accounts.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

Chief Financial Officer

Date Title or Status Acquired(MM/YYYY)

10/2022

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Before joining Clear Street, Mr. Wenger was an audit executive at Ernst & Young LLP with more than 12 years of experience in financial audit (US GAAP and IFRS), including attestation engagements over financial responsibility rules (SEC Rule 15c3-1 net capital calculation, SEC Rule 15c3-3 customer reserve calculation, customer statement rules and quarterly security count rules) and review of FOCUS filings, as well as regulatory compliance projects (including market conduct, market risk, credit risk, AML/BSA, and investment suitability) in the financial industry, serving public registrants and private companies including wealth management, investment banking, broker dealer and swap dealer clients.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

Chief Risk Officer

Date Title or Status Acquired(MM/YYYY)

09/2023

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

006683631

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Mr. Gunawan joined Clear Street from Goldman Sachs where he was the Head of OTC Swaps Clearing Risk from 2016 to 2021, in addition to providing Prime Brokerage Risk & Futures risk oversight for the firm. He represented Goldman, globally, on the CME's Risk Committee providing guidance on IRS & CDS products including risk management policies, margin, default management, and oversight of new product initiatives. From 2010 to 2016, Mr. Gunawan was a Vice President in Goldman's Market Risk Management & Analysis Dept. covering multiple asset classes, and acted as lead coordinator for CCAR stress test and Volcker rule implementation.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

Director

Date Title or Status Acquired(MM/YYYY)

09/2023

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

004808674

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Andy Volz joined Clear Street in August 2021 as Chief Operating Officer and Head of Sales. Prior to Clear Street, Mr. Volz was a Chief Operating Officer and Head of Prime Services at Jones Trading from 2016 through 2021. Mr. Volz has almost 20 year of experience in various sales / product management roles, including at Citi, Reval, Merlin Securities, among others.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

Director

Date Title or Status Acquired(MM/YYYY)

09/2023

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

004855629

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Christy Moccia serves as the Global Chief Compliance Officer for the Clear Street group of companies, responsible for all aspects of Clear Street's enterprise-wide regulatory compliance program. Prior to joining Clear Street, Ms. Moccia was the CCO and AML Compliance Officer for Virtu Americas LLC and Virtu Financial Capital Markets LLC, both FINRA member broker-dealers. Previous to Virtu, Ms. Moccia served in a similar role at KCG Americas LLC between January 2014 and July 2017 and in a variety of compliance roles at Knight Capital Group between September 2009 and January 2014. Ms. Mocchia has more than 25 years of regulatory compliance experience with expertise in prime brokerage, market making, high frequency trading and electronic trading.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button checked

I (Individual)

Title or Status

Director

Date Title or Status Acquired(MM/YYYY)

09/2023

Ownership Code

NA-less than 5%
Radio button not checked

A-5% but less than 10%
Radio button not checked

B-10% but less than 25%
Radio button not checked

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

005491470

IARD No

Foreign business No.

IRS Tax No.

UIC, if any

For individuals not presently registered through CRD or IARD, describe prior investment-related experience (e.g., for each prior position - employer, job title, and dates of service):

Mr. Bhatt joined Clear Street from Bank of America where he was the Head of Risk for all Market Making and Joint Back Office clients within its Prime Brokerage Division from 2015-2020. In this capacity, he was responsible for enhancing the House Risk Methodologies, stress testing and risk management controls. Prior to BofA, Mr. Bhatt was at Goldman Sachs from 2008 to 2015 where he served as the Americas Market Risk Head overseeing Market Risk management across Commodities, Currencies, Emerging Markets and Global Liquidity Products.

SBSE: Schedule B of FORM SBSE

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

INDIRECT OWNERS (Answer for Form SBSE Item 8)

1. Use Schedule B to provide information on the indirect owners of the applicant. Use Schedule A to provide information on direct owners. Complete each column.
2. With respect to each owner listed on Schedule A, (except individual owners), list below:
- (a) In the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 25% or more of a class of a voting security of that corporation. For purposes of this Schedule, a person beneficially owns any securities (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence, or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant or right to purchase the security.
- (b) In the case of an owner that is a partnership, all general partners, and those limited and special partners that have the right to receive upon dissolution, or have contributed, 25% or more of the partnership's capital; and
- (c) In the case of an owner that is a trust, the trust and each trustee.
- (d) In the case of an owner that is a Limited Liability Company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public company (a company subject to Sections 12 or 15(d) of the Securities Exchange Act of 1934) is reached, no ownership information further up the chain of ownership need be given.
4. In the "DE/FE/I" column, enter "DE" if the owner is a domestic entity, or enter "FE" if owner is an entity incorporated or domiciled in a foreign country, or enter "I" if the owner is an individual.
5. Complete the "Status" column by status as partner, trustee, shareholder, etc., and if shareholder, class of securities owned (if more than one is issued).
6. Ownership codes are:
- C - 25% but less than 50%
- D - 50% but less than 75%
- E - 75% or more
- F – Other General Partners
7. (a) In the "Control Person" column, enter "Yes" if person has control as defined in the instructions to this form, and enter "No" if the person does not have control. Note that under this definition most executive officers and all 25% owners, general partners, and trustees would be "control persons".

(b) In the "PR" column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934.

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button not checked

I (Individual)

Entity in Which Interest is Owned

Clear Street Holdings LLC

Status

Owner

Date Title or Status Acquired(MM/YYYY)

05/2022

Ownership Code

C-25% but less than 50%
Radio button not checked

D-50% but less than 75%
Radio button not checked

E-75% or more
Radio button not checked

F-Other General Partners

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

IARD No

Foreign business No.

IRS Tax No.

86-2376416

UIC, if any

Firm or Individual?

Firm

Individual

Domestic Entity/Foreign Entity (entity organized, incorporated, or domiciled in a foreign country)/Individual:

DE (Domestic Entity) Radio button not checked

FE (Foreign Entity) Radio button not checked

I (Individual)

Entity in Which Interest is Owned

Clear Street Holdings LLC

Status

Owner

Date Title or Status Acquired(MM/YYYY)

02/2021

Ownership Code

C-25% but less than 50%
Radio button checked

D-50% but less than 75%
Radio button not checked

E-75% or more
Radio button not checked

F-Other General Partners

Control Person

Yes

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD No

IARD No

Foreign business No.

IRS Tax No.

66-0925803

UIC, if any

SBSE: Schedule D of Form SBSE Page 1

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

Use Schedule D Page 1 to report details for items listed below.

This is an INITIAL / AMENDED detail filing for the Form SBSE items checked below:

INITIAL

AMENDED

Section I

Other Business Names

(Check if Applicable)

Item 1C(2)

List each of the "other" names and the state(s) or country(ies) in which they are used.

Name

State/Country

Section IV

Record Maintenance Arrangements / Business Arrangements / Control Persons / Financings

(Check one)

Item 11A

Item 11B

Item 12A

Item 12B

Applicant must complete a separate Schedule D Page 1 for each affirmative response in this section including any multiple responses to any item. Complete the “Effective Date” box with the Month, Day and Year that the arrangement or agreement became effective. When reporting a change or termination of an arrangement, enter the effective date of the change.

Firm or Individual?

Firm

Individual

(Check one)

Item 11A

Item 11B

Item 12A

Item 12B

Firm or Individual?

Firm

Individual

(Check one)

Item 11A

Item 11B

Item 12A

Item 12B

Firm or Individual?

Firm

Individual

(Check one)

Item 11A

Item 11B

Item 12A

Item 12B

Firm or Individual?

Firm

Individual

SBSE: Schedule D of Form SBSE Page 2

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

Use this Schedule D Page 2 to report details for Item 13A. Supply details for all partnerships, corporations, organizations, institutions and individuals necessary to answer each item completely. Use additional copies of Schedule D Page 2 if necessary.

Use the "Effective Date" box to enter the Month, Day, and Year that the affiliation was effective or the date of the most recent change in the affiliation.

This is an INITIAL / AMENDED detail filing for the Form SBSE item 13A

INITIAL

AMENDED

Directly or indirectly, does applicant control, is applicant controlled by, or is applicant under common control with, any partnership, corporation, or other organization that is engaged in the securities or investment advisory business?

13A

Section V

Complete this section for control issues relating to ITEM 13A only.

The details supplied relate to:

Partnership, Corporation, or Organization Name

Clear Street Canada Inc.

CRD Number (if any)

UIC Number (if any)

(check only one) This Partnership, Corporation, or Organization

controls applicant
Radio button not checked

is controlled by applicant
Radio button checked

under common control with applicant

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Street Address 1

30 Adelaide St. East,

Street Address 2

12 Fl,

City

Toronto

State/Country

ONTARIO, CANADA

Zip + 4 Postal Code

M5C

Effective Date MM DD YYYY

5/12/23

Termination Date MM DD YYYY

Is Partnership, Corporation or Organization a foreign entity"

Yes

If Yes, provide country of domicile or incorporation"

CANADA (FEDERAL LEVEL)

Check "Yes" or "No" for activities of this partnership Corporation, or organization:

Security Activities:

Yes

Investment Advisory Activities:

Yes

Briefly describe the control relationship.

The applicant and Clear Street Canada Inc. are under common control as both are directly owned by Clear Street Holdings LLC.

If applicant has more than 3 organizations to report, complete additional Schedule D Page 2s.

Section V

Complete this section for control issues relating to ITEM 13A only.

The details supplied relate to:

Partnership, Corporation, or Organization Name

Clear Street LLC

CRD Number (if any)

000288933

UIC Number (if any)

(check only one) This Partnership, Corporation, or Organization

controls applicant
Radio button not checked

is controlled by applicant
Radio button checked

under common control with applicant

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Street Address 1

4 WTC, 150 GREENWICH STREET,

Street Address 2

45TH FLOOR

City

NEW YORK

State/Country

NEW YORK

Zip + 4 Postal Code

10007

Effective Date MM DD YYYY

1/27/22

Termination Date MM DD YYYY

Is Partnership, Corporation or Organization a foreign entity"

Yes

If Yes, provide country of domicile or incorporation"

Check "Yes" or "No" for activities of this partnership Corporation, or organization:

Security Activities:

Yes

Investment Advisory Activities:

Yes

Briefly describe the control relationship.

Applicant and Clear Street LLC are under common control as both are directly owned by Clear Street Holdings LLC.

If applicant has more than 3 organizations to report, complete additional Schedule D Page 2s.

Section V

Complete this section for control issues relating to ITEM 13A only.

The details supplied relate to:

Partnership, Corporation, or Organization Name

Clear Street Investments LLC

CRD Number (if any)

UIC Number (if any)

(check only one) This Partnership, Corporation, or Organization

controls applicant
Radio button not checked

is controlled by applicant
Radio button checked

under common control with applicant

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Street Address 1

55 BROADWAY,

Street Address 2

SUITE 2102

City

NEW YORK,

State/Country

NEW YORK

Zip + 4 Postal Code

10006

Effective Date MM DD YYYY

1/27/22

Termination Date MM DD YYYY

Is Partnership, Corporation or Organization a foreign entity"

Yes

If Yes, provide country of domicile or incorporation"

Check "Yes" or "No" for activities of this partnership Corporation, or organization:

Security Activities:

Yes

Investment Advisory Activities:

Yes

Briefly describe the control relationship.

Applicant and Clear Street Investments are under common control as both are directly owned by Clear Street Holdings LLC.

If applicant has more than 3 organizations to report, complete additional Schedule D Page 2s.

Section V

Complete this section for control issues relating to ITEM 13A only.

The details supplied relate to:

Partnership, Corporation, or Organization Name

Precision Securities, LLC

CRD Number (if any)

000103976

UIC Number (if any)

(check only one) This Partnership, Corporation, or Organization

controls applicant
Radio button not checked

is controlled by applicant
Radio button checked

under common control with applicant

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Street Address 1

2010 Jimmy Durante Blvd

Street Address 2

Suite 270

City

Del Mar

State/Country

CALIFORNIA

Zip + 4 Postal Code

92014

Effective Date MM DD YYYY

1/27/22

Termination Date MM DD YYYY

Is Partnership, Corporation or Organization a foreign entity"

Yes

If Yes, provide country of domicile or incorporation"

Check "Yes" or "No" for activities of this partnership Corporation, or organization:

Security Activities:

Yes

Investment Advisory Activities:

Yes

Briefly describe the control relationship.

The applicant and Precision Securities are under common control as both are directly owned by Clear Street Holdings LLC.

If applicant has more than 3 organizations to report, complete additional Schedule D Page 2s.

Section V

Complete this section for control issues relating to ITEM 13A only.

The details supplied relate to:

Partnership, Corporation, or Organization Name

Clear Street Markets LLC

CRD Number (if any)

000159283

UIC Number (if any)

(check only one) This Partnership, Corporation, or Organization

controls applicant
Radio button not checked

is controlled by applicant
Radio button checked

under common control with applicant

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Street Address 1

55 Broadway, 21st Fl

Street Address 2

City

New York

State/Country

NEW YORK

Zip + 4 Postal Code

10006

Effective Date MM DD YYYY

1/27/22

Termination Date MM DD YYYY

Is Partnership, Corporation or Organization a foreign entity"

Yes

If Yes, provide country of domicile or incorporation"

Check "Yes" or "No" for activities of this partnership Corporation, or organization:

Security Activities:

Yes

Investment Advisory Activities:

Yes

Briefly describe the control relationship.

Applicant and Clear Street Markets LLC are under the common control of Clear Street Holdings LLC.

If applicant has more than 3 organizations to report, complete additional Schedule D Page 2s.

SBSE: Schedule D of Form SBSE Page 3

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

Use Schedule D Page 3 to report details for Item 13B. Report only new information or changes/updates to previously submitted details. Do not report previously submitted information. Supply details for all partnerships, corporations, organizations, institutions and individuals necessary to answer each item completely. Use additional copies of Schedule D Page 3 if necessary.

Use the "Effective Date" box to enter the Month, Day, and Year that the affiliation was effective or the date of the most recent change in the affiliation.

This is an INITIAL / AMENDED detail filing for the Form SBSE item 13B

INITIAL

AMENDED

Directly or indirectly, is applicant controlled by any bank holding company or does applicant control, is applicant controlled by, or is applicant under common control with any bank (as defined in 15 U.S.C. 78c(a)(6)) or any foreign bank?

13B

SBSE: Schedule E of Form SBSE Page 1

FORM SBSE

Applicant Name: Clear Street Derivatives LLC

Uniform Application for Security-based Swap Dealer and
Major Security-based Swap Participation Registration

Date: SEC Filer No:

INSTRUCTIONS

General: Use this schedule to identify other business locations of the applicant. Repeat Items 1-6 for each other business location. Each item must be completed unless otherwise noted. Use additional copies of this schedule as necessary.

Specific:
Item 1. Specify only one box. Check “Add” when the applicant is filing the initial notice to inform the Commission that it has opened another "Delete" when the applicant closes another business location, and "Amendment" to indicate any other change to previously filed information.

Item 2. Complete this item for all entries. Provide the date that the other business location was opened (ADD), closed (DELETE), or the effective date of the change (AMENDMENT).

Item 3. Complete this item for all entries. A physical location must be included; post office box designations alone are not sufficient.

Item 4. Complete this item only when the applicant changes the address of an existing other business location.

Item 5. If the other business location occupies or shares space on premises within a bank, or other financial institution, enter the name of the institution in the space provided.

Item 6. Complete this item for all entries. Enter the name of the associated person who is responsible for the operations of, and is physically at, this location.

1. Check only one box:

Add

Delete

Amendment

2. Effective Date:

9/1/23

3. Street Address 1:

WeWork, 1 Poultry

Street Address 2:

City:

London

State/Country:

UNITED KINGDOM

Zip + 4 Postal Code:

EC2R 8EJ

Institution Name:

Clear Street Services UK Limited

Responsible Associated Person:

Colin Bridges

REGULATORY ACTION DISCLOSURE REPORTING PAGE (SBSE)

GENERAL INSTRUCTIONS

You must provide a valid response to each question on every section of this DRP before any of your information can be saved. Invalid or incomplete responses will prevent you from closing the DRP with your information saved. It is recommended that you consult the Print Form of this DRP to make sure you have gathered all the required information before beginning your entry of information online.

This Disclosure Reporting Page [(DRP SBSE)] is an INITIAL OR AMENDED response to report details for affirmative responses to Items 14C, 14D, 14E, 14F, or 14G of Form SBSE;

INITIAL

AMENDED

Check item(s) being responded to:

14C. Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:

(1) Found the principal to have made a false statement or omission?
Checkbox not checked

(2) Found the principal to have been involved in a violation of its regulations or statutes?
Checkbox not checked

(3) the principal to have been a cause of an investment-related business having its authorization to do business denied, revoked, or restricted?
Checkbox not checked

(4) Entered an order against the principal in connection with investment-related activity?
Checkbox not checked

(5) Imposed a civil money penalty on the principal, or ordered the principal to cease and desist from any activity?

14D. Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority:

(1) Ever found the principal to have made a false statement or omission or been dishonest, unfair, or unethical?
Checkbox not checked

(2) Ever found the principal to have been involved in a violation of investment-related regulations or statutes?
Checkbox not checked

(3) Ever found the principal to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?
Checkbox not checked

(4) In the past ten years, entered an order against the principal in connection with an investment-related activity?
Checkbox not checked

(5) Ever denied, suspended, or revoked the principal's registration or license or otherwise, by order, prevented it from associating with an investment-related business or restricted its activities?

14E. Has any self-regulatory organization or commodities exchange ever:

(1) found the principal to have made a false statement or omission?
Checkbox checked

(2) found the principal to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the U.S. Securities and exchange Commission)?
Checkbox not checked

(3) found the principal to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?
Checkbox not checked

(4) Disciplined the principal by expelling or suspending it from membership, barring or suspending its association with other members, or otherwise restricting its activities?

14F.

Has the applicant's or a control affiliate's authorization to act as an attorney, accountant, or federal contractor ever been revoked or suspended?

14G.

Is the applicant or a control affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of 14C, D, or E?

Use a separate DRP for each event or proceeding. An event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page.

One event may result in more than one affirmative answer to Items 14C, 14D, 14E, 14F or 14G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.

It is not a requirement that documents be provided for each event or proceeding. Should they be provided, they will not be accepted as disclosure in lieu of answering the questions on this DRP.

If a control affiliate is an individual or organization registered through the CRD, such control affiliate need only complete Part I of the applicant's appropriate DRP (SBSE). Details of the event must be submitted on the control affiliate's appropriate DRP (BD) or DRP (U-4). If a control affiliate is an individual or organization not registered through the CRD, provide complete answers to all the items on the applicant's appropriate DRP (SBSE). The completion of this DRP does not relieve the control affiliate of its obligation to update its CRD records.

PART I

A. The person(s) or entity(ies) for whom this DRP (SBSE) is being filed is (are):

The Applicant
Radio button not checked

Applicant and one or more control affiliate(s)
Radio button checked

One or more control affiliate(s)

If this DRP is being filed for a control affiliate, give the full name of the control affiliate below (for individuals, Last name, First name, Middle name).
If the control affiliate is registered with the CRD, provide the CRD number. If not, indicate "non-registered" by checking the appropriate checkbox.

SBSE DRP - CONTROL AFFILIATE

CRD NUMBER

000159283

UIC NUMBER (if any)

This Control Affiliate is

Firm

Individual

Is the control affiliate registered

Yes

NAME

Clear Street Markets LLC

B. If the control affiliate(s) is registered through the CRD, has the control affiliate(s) submitted a DRP (with Form U-4) or DRP (BD) to the CRD System for the event?

Yes

If the answer is "Yes," no other information on this DRP must be provided: If "No," complete Part II.
Note: The completion of this Form does not relieve the control affiliate of its obligation to update its CRD records.

This Disclosure Reporting Page [(DRP SBSE)] is an INITIAL OR AMENDED response to report details for affirmative responses to Items 14C, 14D, 14E, 14F, or 14G of Form SBSE;

INITIAL

AMENDED

Check item(s) being responded to:

14C. Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:

(1) Found the principal to have made a false statement or omission?
Checkbox not checked

(2) Found the principal to have been involved in a violation of its regulations or statutes?
Checkbox not checked

(3) the principal to have been a cause of an investment-related business having its authorization to do business denied, revoked, or restricted?
Checkbox not checked

(4) Entered an order against the principal in connection with investment-related activity?
Checkbox not checked

(5) Imposed a civil money penalty on the principal, or ordered the principal to cease and desist from any activity?

14D. Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority:

(1) Ever found the principal to have made a false statement or omission or been dishonest, unfair, or unethical?
Checkbox checked

(2) Ever found the principal to have been involved in a violation of investment-related regulations or statutes?
Checkbox not checked

(3) Ever found the principal to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?
Checkbox not checked

(4) In the past ten years, entered an order against the principal in connection with an investment-related activity?
Checkbox not checked

(5) Ever denied, suspended, or revoked the principal's registration or license or otherwise, by order, prevented it from associating with an investment-related business or restricted its activities?

14E. Has any self-regulatory organization or commodities exchange ever:

(1) found the principal to have made a false statement or omission?
Checkbox checked

(3) found the principal to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted?
Checkbox not checked

(4) Disciplined the principal by expelling or suspending it from membership, barring or suspending its association with other members, or otherwise restricting its activities?

14F.

Has the applicant's or a control affiliate's authorization to act as an attorney, accountant, or federal contractor ever been revoked or suspended?

14G.

Is the applicant or a control affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of 14C, D, or E?

PART I

A. The person(s) or entity(ies) for whom this DRP (SBSE) is being filed is (are):

The Applicant
Radio button not checked

Applicant and one or more control affiliate(s)
Radio button checked

One or more control affiliate(s)

SBSE DRP - CONTROL AFFILIATE

CRD NUMBER

000103976

UIC NUMBER (if any)

This Control Affiliate is

Firm

Individual

Is the control affiliate registered

Yes

NAME

Precision Securities, LLC

B. If the control affiliate(s) is registered through the CRD, has the control affiliate(s) submitted a DRP (with Form U-4) or DRP (BD) to the CRD System for the event?

Yes

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Filing Submission 0001983408-23-000005 – Alternative Formats (Word / Rich Text, HTML, Plain Text, et al.)

Clear Street Derivatives LLC – ‘SBSE’ on 9/28/23

On: Thursday, 9/28/23, at 3:40pm ET · Accession #: 1983408-23-5 · File #: 26-00231

Previous ‘SBSE’: None · Next: ‘SBSE/A’ on 11/16/23 · Latest: ‘SBSE/A’ on 3/11/24

Application for Registration by a Security-Based Swap Dealer or Major Security-Based Swap Participant — Form SBSEFiling Table of Contents

‘SBSE’ — Application for Registration by a Security-Based Swap Dealer or Major Security-Based Swap Participant — primary_doc.xml

This ‘SBSE’ Document is an XML Data File that may be rendered in various formats:

SBSE: Filer Information

Submission Contact Information

SBSE: Applicant Data - Page 1

1. Exact name, principal business address, mailing address, if different, and telephone number of the applicant:

SBSE: EXECUTION

SBSE: Applicant Data - Page 2

2.

3.

4.

5.

6.

7.

8.

9.

10.

SBSE: Applicant Data - Page 3

11.

12.

13.

14.

CRIMINAL DISCLOSURE

SBSE: Applicant Data - Page 4

REGULATORY ACTION DISCLOSURE

CIVIL JUDICIAL DISCLOSURE

SBSE: Applicant Data - Page 5

FINANCIAL DISCLOSURE

15.

16.

17.

SBSE: Schedule A of FORM SBSE

DIRECT OWNERS AND EXECUTIVE OFFICERS(Answer for Form SBSE Item 8)

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

SBSE: Schedule B of FORM SBSE

INDIRECT OWNERS (Answer for Form SBSE Item 8)

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

CRD and/or IARD No. and/or foreign business No. If None, IRS Tax No.

SBSE: Schedule D of Form SBSE Page 1

Use Schedule D Page 1 to report details for items listed below.

Section I

Other Business Names

Section IV

Record Maintenance Arrangements / Business Arrangements / Control Persons / Financings

SBSE: Schedule D of Form SBSE Page 2

Section V

Complete this section for control issues relating to ITEM 13A only.

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Section V

Complete this section for control issues relating to ITEM 13A only.

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Section V

Complete this section for control issues relating to ITEM 13A only.

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Section V

Complete this section for control issues relating to ITEM 13A only.

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

Section V

Complete this section for control issues relating to ITEM 13A only.

Business Address (Street, City, State/Country, Zip + 4 Postal Code)

SBSE: Schedule D of Form SBSE Page 3

SBSE: Schedule E of Form SBSE Page 1

REGULATORY ACTION DISCLOSURE REPORTING PAGE (SBSE)

GENERAL INSTRUCTIONS

PART I

SBSE DRP - CONTROL AFFILIATE

PART I

Application for Registration by a Security-Based Swap Dealer or Major Security-Based Swap Participant — Form SBSE

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