# AMERICAN TRUST INVESTMENT SERVICES, INC. X-17A-5 (2022-03-31) — Broker-dealer annual report

- Company: AMERICAN TRUST INVESTMENT SERVICES, INC.
- Form: X-17A-5
- Filed: 2022-03-31
- Period: 2021-12-31
- Accession: 0000076964-22-000003
- CIK: 76964
- File #: 8-14394
- Type: Broker-dealer
- Material weakness: No
- Auditor: Bradford Dooley
- Auditor location: Chicago, IN
- Contact: Michael Grady
- Phone: 6304359128
- Email: m.grady@amtruinvest.com
- Website: amtruinvest.com
- Signed by: Michael Grady (CFO)

Original filing: https://www.sec.gov/Archives/edgar/data/76964/000007696422000003/fixed1.pdf

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American Trust Investment Services, Inc. Financial Statements and Supplementary Information and Report of Independent Registered Public Accounting Firm Year Ended December 31, 2021

> Filed as **CONFIDENTIAL** Information Pursuant to Rule 17a-S(e)(3) under the Securities Exchange Act of 1934

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| MARCH 24, 2009<br>(Date of Registration with PCAOB)(If applicable)                                                                |              |                                                            | 3429                                                                                                                  |                 | (PCAOB Registration Number, if applicable) |  |
|-----------------------------------------------------------------------------------------------------------------------------------|--------------|------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|-----------------|--------------------------------------------|--|
|                                                                                                                                   |              |                                                            |                                                                                                                       |                 |                                            |  |
|                                                                                                                                   |              |                                                            |                                                                                                                       |                 |                                            |  |
| 209 W JACKSON BLVD STE 404<br>(Address)                                                                                           |              | CHICAGO<br>(City)                                          | (State)                                                                                                               | ILLINOIS        | 60806<br>(Zip Cade)                        |  |
|                                                                                                                                   |              | (Name - if individual, state last, first, and middle name) |                                                                                                                       |                 |                                            |  |
| BRADFORD R DOOLEY & ASSOCIATES                                                                                                    |              |                                                            |                                                                                                                       |                 |                                            |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing *                                                        |              |                                                            |                                                                                                                       |                 |                                            |  |
|                                                                                                                                   |              | B. ACCOUNTANT IDENTIFICATION                               |                                                                                                                       |                 |                                            |  |
| (Name)                                                                                                                            |              | (Area Code - Telephone Number)                             |                                                                                                                       | (Email Address) |                                            |  |
| MICHAEL GRADY                                                                                                                     |              | 630-435-9128                                               |                                                                                                                       |                 | m.grady@amtruinvest.com                    |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                      |              |                                                            |                                                                                                                       |                 |                                            |  |
| (City)                                                                                                                            |              | (State)                                                    |                                                                                                                       |                 | (Zip Code)                                 |  |
| WHITNG                                                                                                                            |              |                                                            | INDIANA                                                                                                               |                 | 46394                                      |  |
|                                                                                                                                   |              | (No. and Street)                                           |                                                                                                                       |                 |                                            |  |
| 1244 119th STREET                                                                                                                 |              |                                                            |                                                                                                                       |                 |                                            |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                               |              |                                                            |                                                                                                                       |                 |                                            |  |
| TYPE OF REGISTRANT (check all applicable boxes):<br>& Broker-dealer<br>Check here if respondent is also an OTC derivatives dealer |              |                                                            | J Security-based swap dealer Major security-based swap participant                                                    |                 |                                            |  |
| NAME OF FIRM: AMERICAN TRUST INVESTMENT SERVICES INC                                                                              |              |                                                            |                                                                                                                       |                 |                                            |  |
|                                                                                                                                   |              | A. REGISTRANT IDENTIFICATION                               |                                                                                                                       |                 |                                            |  |
|                                                                                                                                   |              | MM/DD/YY                                                   |                                                                                                                       |                 | MM/DD/YY                                   |  |
| FILING FOR THE PERIOD BEGINNING                                                                                                   |              | 01/01/2021                                                 | AND ENDING                                                                                                            |                 | 12/31/2021                                 |  |
| Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934                         |              | FACING PAGE                                                |                                                                                                                       |                 |                                            |  |
|                                                                                                                                   |              | PART III                                                   |                                                                                                                       |                 |                                            |  |
|                                                                                                                                   | FORM X-17A-5 |                                                            |                                                                                                                       | 8-14394         |                                            |  |
|                                                                                                                                   |              | ANNUAL REPORTS                                             |                                                                                                                       | SEC FILE NUMBER |                                            |  |
| UNITED STATES<br>SECURITIES AND EXCHANGE COMMISSION<br>Washington, D.C. 20549                                                     |              |                                                            | OMB APPROVAL<br>OMB Number: 3235-0122<br>Expires: Oct. 31, 2023<br>Estimated average burden<br>hours per response: 12 |                 |                                            |  |
|                                                                                                                                   |              |                                                            |                                                                                                                       |                 |                                            |  |

Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number.

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#### OATH OR AFFIRMATION

| swear (or affirm) that, to the best of my knowledge and belief, the<br>MICHAEL GRADY                                                                                                                                   |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| AMERICAN TRUST INVESTMENT SERVICES INC   as of<br>financial report pertaining to the firm of acres and                                                                                                                 |
| 2 021 , is true and correct. I further swear (or affirm) that neither the company nor any<br>DECEMBER 31                                                                                                               |
| partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely                                                                                    |
| as that of a customer.                                                                                                                                                                                                 |
| Britander<br>"OFFICIAL SEAL<br>Sworn and subscribed to me on the<br>DANIEL P. O'HALLOR<br>day of March, 2022                                                                                                           |
| NOTARY PUBLIC, STATE OF ILLIN                                                                                                                                                                                          |
| MY COMMISSION EXPIRES 4/19/26                                                                                                                                                                                          |
| Notary Public                                                                                                                                                                                                          |
|                                                                                                                                                                                                                        |
| This filing ** contains (check all applicable boxes):                                                                                                                                                                  |
| a) Statement of financial condition.                                                                                                                                                                                   |
| (b) Notes to consolidated statement of financial condition.                                                                                                                                                            |
| & (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of                                                                                                 |
| comprehensive income (as defined in § 210.1-02 of Regulation 5-X).                                                                                                                                                     |
| 2 (d) Statement of cash flows.                                                                                                                                                                                         |
| & (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.                                                                                                                                  |
| [f] Statement of changes in liabilities subordinated to claims of creditors.                                                                                                                                           |
| (g) Notes to conselident financial statements.                                                                                                                                                                         |
| 2 (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.                                                                                                                           |
| (i) Computation of tangible net worth under 17 CFR 240.188-2.                                                                                                                                                          |
| 8 (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.                                                                                                       |
| [k] Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or                                                                                            |
| Exhibit A to 17 CFR 240.18a-4, as applicable.                                                                                                                                                                          |
| [1] Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.                                                                                                                                 |
| 8 (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.                                                                                                                |
| [ ] Information relating to possession or control requirements for security-based swap customers under 17 CFR                                                                                                          |
| 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable.                                                                                                                                                                   |
| O (o) Reconcliations, including appropriate explanations, of the FOCUS Report with computation of tangible net                                                                                                         |
| worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-2, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17                                                                                             |
| CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences                                                                                          |
| exist.                                                                                                                                                                                                                 |
| [ (p) Summary of financial data for subsidiated in the statement of financial condition.                                                                                                                               |
| 2 (q) Oath or affirmation in accordance with 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.                                                                                                                    |
| [r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.                                                                                                                          |
| (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.                                                                                                                           |
| [t] Independent public accountant's report based on an examination of the statement of financial condition.<br>(u) Independent public accountant's report based on an examination of the financial statements under 17 |
| CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.                                                                                                                                                  |
| [v] Independent public accountant's report based on an examination of certain statements in the compliance report under 17                                                                                             |
| CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable,                                                                                                                                                                      |
| 2 (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17                                                                                                    |
| CFR 240.18a-7, as applicable.                                                                                                                                                                                          |
| (x) Supplemental reports on applying agreed upon procedures, in accordance with 17 CFR 240.17a-12,                                                                                                                     |
| as applicable.                                                                                                                                                                                                         |
|                                                                                                                                                                                                                        |

[] (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).

□ (z) Other: \_\_

\*\* To request confidential treatment of chis filing, see 17 CFR 240.170-5(e)(3) or 17 CFR 240.186-7(d)(2), as applicable.

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### Contents

Report Of Independent Registered Public Accounting Firm Statement of Financial Condition Statement of Income Statement of Changes in Shareholder's Equity Statement of Cash Flows Notes to Financial Statement Supplementary Information:

Computation of Net Capital under Rule 15c3-1 of the Securities and Exchange Commission Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 December 31,2021

Computation for Determination of PAIB Reserve Requirements pursuant to Rule 15c3-3 December 31, 2021

Information Relating to Possession or Control Requirements pursuant to Rule 15c3-3

Report of Independent Registered Public Accounting Firm

Management's Exemption Letter

Independent Auditor's Report on Applying Agreed-upon Procedures related to the Entity's SIPC Assessment Reconciliation

Sipe-7 General Assessment Reconciliation

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#### BRADFORD R. DOOLEY & ASSOCIATES *.ftccoontants ana ..Auditors*  209 WEST JACKSON BLVD-SUITE 404 cmCAGO, ILLINOIS 60606

*!Mem6er*  AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNT ANTS ILLINOIS CPA SOCIETY

OFFICE (312) 939-0477 FAX (312) 939-8739

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Shareholder of American Trust Investment Services, Inc.

#### **Opinion on the Financial Statements**

We have audited the accompanying statement offinancial condition of American Trust Investment Services, Inc. as of December 31, 2021, the related statements of income, changes in shareholder's equity, and cash flows for the year then ended, and the related notes [and schedules] (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of American Trust Investment Services, Inc. as of December 31, 2021, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America.

#### **Basis for Opinion**

These financial statements are the responsibility of American Trust Investment Services, Inc's management. Our responsibility is to express an opinion on American Trust Investment Services, Inc's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to American Trust Investment Services, Inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

#### **Auditor's Report on Supplemental Information**

The supplementary information, which is comprised of Schedule I - Computation of Net Capital and Aggregate Indebtedness, Schedule II - Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3, Schedule Ill - Computation for Determination of PAIB Reserve Requirements Pursuant to Rule 15c3-3, and Schedule IV - Information Relating to Possession or Control Requirements Pursuant to Rule 15c3-3, has been subjected to audit procedures performed in conjunction with the audit of American Trust Investment Services, Inc's financial statements. The supplemental information is the responsibility of American Trust Investment Services, Inc's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole.

American Trust Investment Services, Inc's auditor since 2021 .

<fli!)\_ Bradford R.

Chicago, Illinois March 29, 2022

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#### STATEMENT OF FINANCIAL CONDITION

#### DECEMBER 31, 2021

#### ASSETS

| Cash                                        | \$   | 866,549         |
|---------------------------------------------|------|-----------------|
| Receivable from clearing broker/<br>dealers |      | 118,094         |
| Brokerage account money markets position    |      | 625,138         |
| Securities owned, at fair value             |      | 3,437           |
| Furniture,<br>equipment and leasehold       |      |                 |
| ovements, at cost, net of<br>impr           |      |                 |
| \$23,366 accumulated depreciation           |      |                 |
| Other assets                                |      | ,208<br>33      |
|                                             |      |                 |
|                                             |      |                 |
| TOTAL ASSETS                                |      | \$ 1,646,426    |
|                                             |      |                 |
|                                             |      |                 |
| LIABILITIES AND SHAREHOLDER'S EQUITY        |      |                 |
|                                             |      |                 |
| LIABILITIES                                 |      |                 |
| Accounts payable and accrued expenses       | \$   | 460,010         |
| Commissions payable                         |      | 857,777         |
| Accrued Tax Payable                         |      | 24,916          |
| Total Liabilities                           | \$1, | 342<br>703<br>, |
|                                             |      |                 |
| SHAREHOLDER'S EQUITY                        |      |                 |
| Common stock,<br>no par value, 100 shares   |      |                 |
| authorized,<br>issued and outstanding       | \$   | 45,000          |
| Additional paid in capital                  |      | 63,800          |
| Retained earnings                           |      | 194,923         |
|                                             |      |                 |
|                                             |      |                 |
| Total Shareholder's Equity                  | \$   | 303,723         |
|                                             |      |                 |
| TOTAL LIABILITIES AND SHAREHOLDER'S EQUITY  | \$   | 1,646,<br>426   |

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### STATEMENT OF INCOME

#### YEAR ENDED DECEMBER 31, 2021

| REVENUE                                           |                  |
|---------------------------------------------------|------------------|
| Commissions                                       | 3,753,918<br>\$  |
| Concessions                                       | 6,007,982        |
| Referral/Consulting                               | 465,505          |
| Interest                                          | 23,511           |
| Other                                             | 111,616          |
| Total Revenue                                     | \$10,362,532     |
| EXPENSES                                          |                  |
| salaries<br>Commissions,                          |                  |
| and related expenses                              | 7,906,233<br>\$  |
| Clearing and execution charges                    | 313,365          |
| Accounting, consulting, registration<br>and legal | 1,651,378        |
| Occupancy                                         | 44,800           |
| Other expenses                                    | 348,592          |
|                                                   |                  |
| Total Expenses                                    | 10,264,368<br>\$ |
| NET INCOME before tax                             | 98,164<br>\$     |
| Tax Provision                                     | 24,916           |
| NET INCOME after tax                              | 73,248<br>\$     |

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## STATEMENT OF CHANGES IN SHAREHOLDER'S EQUITY

### YEAR ENDED DECEMBER 31, 2021

|                                 | Common<br>Stock | Additional<br>Paid-in<br>Capital | Retained<br>Earnings | Total<br>Shareholder's<br>Equity |  |
|---------------------------------|-----------------|----------------------------------|----------------------|----------------------------------|--|
| Balance<br>Beginning<br>of Year | \$ 45,000       | 63,800<br>\$                     | 146,675<br>\$        | 255,475<br>\$                    |  |
| Capital<br>Withdrawn            |                 |                                  | (25,000)             | (25,000)                         |  |
| Net Income                      |                 |                                  | 73,248               | 73,248                           |  |
| BALANCE-END<br>OF YEAR          | \$ 45,000       | 63,800<br>\$                     | 194,923<br>\$        | \$ 303,723                       |  |

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#### STATEMENT OF CASH FLOWS

#### YEAR ENDED DECEMBER 31. 2021

| Cash Flows from Operating Activities<br>Net Income | \$  | 73,248              |
|----------------------------------------------------|-----|---------------------|
| Adjustments:                                       |     |                     |
| Decrease in receivable from                        |     |                     |
| Clearing broker/dealers                            |     | 36,218              |
| Increase in brokerage account                      |     |                     |
| Money markets position                             |     | (197,273)           |
| Decrease in securities owned                       |     | 3,575               |
| Decrease in other assets                           |     | 26,000              |
| Increase in accounts payable, accrued expenses     |     |                     |
| and commissions payable                            |     | _<br>536,528        |
| Increase in income tax payable                     | \$  | __ ______<br>24,916 |
|                                                    |     |                     |
|                                                    |     |                     |
| Net Cash Flow Provided (Used)<br>by                |     |                     |
| Operating Activities                               | \$  | 503,212             |
|                                                    |     |                     |
|                                                    |     |                     |
| Net Cash Flow Provided {Used) by                   |     |                     |
| Investing Activities                               | \$  | 0                   |
|                                                    |     |                     |
|                                                    |     |                     |
| Cash Flows Provided (Used)<br>by                   |     |                     |
| Financing Activities                               |     |                     |
| Dividend Distributions                             | \$  | (25 I 000)          |
|                                                    |     |                     |
|                                                    |     |                     |
| Net Increase in Cash                               | \$  | 478,212             |
|                                                    |     |                     |
|                                                    |     |                     |
| Cash at December 31, 2020                          | \$  | 388,337             |
|                                                    |     |                     |
|                                                    |     |                     |
| Cash at December 31, 2021                          | \$  | 866,549             |
|                                                    |     |                     |
| Cash paid for :Interest Expense                    | \$4 |                     |
| ncome Taxes<br>I                                   | \$0 |                     |

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### NOTES TO FINANCIAL STATEMENTS

### DECEMBER 31, 2021

#### NOTE 1 - ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES

Organization - American Trust Investment Services, Inc. (the "Company") was incorporated in the state of Indiana on December 23, 1968 as Peerson & Company, Inc. CCIG Acquisition Company, LLC closed on the purchase of the Company from Amtru, Inc. on May 15, 2012. The Company is registered with the Securities and Exchange Commission and is a member of the Financial Industry Regulatory Authority (FINRA). The Company's principal business activity is the sale of securities.

Basis of Presentation - The financial statements have been prepared in conformity with accounting principles generally accepted in the United States of America (GAAP).

Revenue - Commission Revenue earned on customer security transactions is accounted for on a trade-date basis. Revenue is recognized when fees are charged in compliance with GAAP and with F ASB ASC 606 when performance obligations have been satisfied and, in the period earned.

Securities Transactions - Securities transactions of the Company, including commission revenue and related expense, are recorded on a trade date basis, which is the same business day as the transaction date.

Depreciation - Depreciation of fixed assets was provided for using the straightline method over five years.

Concentrations of Credit Risk - The Company is engaged in various trading and brokerage activities in which the counterparties primarily include broker/dealers, banks, other financial institutions and the Company's own customers. In the event the counterparties do not fulfill their obligations, the Company may be exposed to risk. The risk of default depends on the creditworthiness of the counterparty or issuer of the instrwnent. It is the Company's policy to review, as necessary, the credit standing of each counter party.

In addition, the Company's cash is on deposit at three financial institutions but uses one primarily for its operations and the balance at times may exceed the federally insured limit. The Company believes it is not exposed to any significant credit risk to cash.

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### NOTES TO FINANCIAL STATEMENTS

### DECEMBER 31, 2021

#### NOTE 1 - ORGANIZATION AND SIGNIFICANT ACCOUNTING POLICIES - *(Continued)*

Estimates - The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.

Subsequent Events - The Company evaluated all significant events or transactions that occurred through the audit report date, the date these financial statements were available to be issued.

#### NOTE 2 - INCOME TAXES

The Company accounts for any potential interest or penalties related to possible future liabilities for unrecognized income tax benefits as interest/other expense. The Company is no longer subject to examination by tax authorities for federal, state or local income taxes for periods before 2018.

#### NOTE 3 - FAIR VALUE MEASUREMENT

F ASB ASC 820 defines fair value, creates a framework for measuring fair value, and establishes a fair value hierarchy which prioritizes the inputs to valuation techniques. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. A fair value measurement assumes that the transaction to sell the asset or transfer the liability occurs in the principal market for the asset or liability or, in the absence of a principal market, the most advantageous market. Valuation techniques that are consistent with the market, income or cost approach, as specified by F ASB ASC 820, are used to measure fair value.

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## NOTES TO FINANCIAL STATEMENTS

## DECEMBER 31, 2021

## NOTE 3 - FAIR VALUE MEASUREMENT - *(Continued)*

The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels:

- Level 1 inputs are quoted prices (unadjusted) in active markets for identical assets or liabilities the Company has the ability to access.
- Leve] 2 inputs are inputs ( other than quoted prices included within level I) that are observable for the asset or liability, either directly or indirectly.
- Level 3 inputs are unobservable inputs for the asset or liability and rely on management's own assumptions about the assumptions that market participants would use in pricing the asset or liability.

The Company's financial assets that are reported at fair value in the accompanying statement of financial condition as of December 31 , 2020 are as follows:

|                            | Level 1 | Level 2   | Level 3 | Total     |
|----------------------------|---------|-----------|---------|-----------|
| Securities                 | \$3,437 | \$625,138 | \$<br>- | \$628,575 |
| Total assets at fair value | \$3,437 | \$625,138 | \$      | \$628,575 |

#### NOTE 4 - NET CAP IT AL REQUIREMENTS

As a registered broker/dealer and member of the Financial Industry Regulatory Authority, the Company is subject to the Uniform et Capital Rule (rule l 5c3-l ), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 1500%. On December 31 , 2021, the Company's net capital and required net capital were \$255,008 and \$100,000 respectively. The ratio of aggregate indebtedness to net capital was 526.53%.

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#### NOTES TO FINANCIAL STATEMENTS

### DECEMBER 31, 2021

#### NOTE 5 - LEASE COMMITMENTS

The Company leases three office spaces, one for \$1 ,150 on a 2-year lease and the other two on a month-to-month basis, for a total amount of \$4,100 per month. \$2,000 a month is paid to an LLC that manages the finance office which is controlled by two of the officers of the Company. It is the opinion of the officers that it could attain similar rent if rented by another company. The rent was not negotiated by a third party and therefore there has been no secondary check as to whether the Company is paying more for rent than they would elsewhere. The lease payments for the year ended December 31, 2021, was \$44,800 which has been met.

#### NOTE 6 - CLEARING AGREEMENT WITH OFF-BALANCE-SHEET RISK

In order to facilitate securities transactions, there is a secondary clearing agreement (Tri-Party agreement) among LaSalle St. Securities, L.L.C. ("Primary Correspondent"), the Company ("Secondary Correspondent"), and National Financial Services, LLC. The new Clearing Broker/dealer (NFS) has accepted the introduction of brokerage accounts of Secondary Correspondent through Primary Correspondent and to provide to such accounts the Clearing Services provided to the other accounts introduced to NFS by Primary Correspondent pursuant to the Clearing Agreement. The Secondary Correspondent is willing to indemnify, defend, and hold harmless Primary Correspondent and NFS for losses incurred by Primary Correspondent or NFS, respectively, in connection with all accounts introduced by Secondary Correspondent to NFS through Primary Correspondent. The Secondary Correspondent is not required to have a deposit with the Primary Correspondent or NFS. The Company may therefore be exposed to off-balance-sheet risk in the event the customer is unable to fulfill its contracted obligations and it is necessary for the Primary Correspondent or NFS to purchase or sell the securities at a loss. The Company's exposure to risk would consist of the amount of the loss realized and any additional expenses incurred pertaining to the transaction or other customer activity.

The Company added a second clearing arrangement on a Fully Disclosed basis with RBC correspondent sources. They have provided the clearing firm with a \$50,000.00 security deposit. The Company may therefore be exposed to off-

{13}------------------------------------------------

## NOTES TO FINANCIAL STATEMENTS

## DECEMBER 31, 2021

### NOTE 6 - CLEARING AGREEMENT WITH OFF-BALANCE-SHEET *RISK-(Continued)*

balance-sheet risk in the event the customer is unable to fulfill its contracted obligations and it is necessary for the Primary Correspondent or NFS to purchase or sell the securities at a loss. The Company's exposure to risk would consist of the amount of the loss realized and any additional expenses incurred pertaining to the transaction or other customer activity in excess the security deposit.

### NOTE 7 - AFFILIATED TRANSACTIONS

The Company currently uses an affiliate to act as a Professional Employment Organization ("PEO") to provide payroll and consulting fees on behalf the Company. Other Affiliates of the Company also use the same PEO. The Company also splits the cost of the E and O Insurance with affiliates of the Company.

### NOTE 8 - Contingent Liabilities

The Company may be involved in a number of legal and regulatory proceedings concerning matters arising from the normal conduct of the Company's business activities. Although there can be no assurances as to the ultimate outcome, the Company has generally denied, or believes it has a meritorious defense, and will deny, liability in all significant litigation pending against the Company, and it intends to defend vigorously each case. Based upon information currently available and advice of counsel the Company believes that the eventual outcome of such matters will not, individually or in the aggregate, have a material adverse effect on the Company's financial position or results of operation

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## SUPPLEMENTAL INFORMATION

{15}------------------------------------------------

### COMPUTATIO OF NET CAPITAL AND AGGREGATE INDEBTEDNESS

### DECEMBER 31. 2021

| COMPUTATION OF NET CAPITAL                                                      |               |
|---------------------------------------------------------------------------------|---------------|
| Total shareholder's equity                                                      | 303,723<br>\$ |
| Non-allowable assets<br>Deduct -                                                | (35,697}      |
|                                                                                 |               |
| Net Capital Before Haircuts                                                     | 268,026<br>\$ |
| Securities Haircuts<br>Less -                                                   | (13,018)      |
|                                                                                 |               |
| NET CAPITAL                                                                     | 255,008       |
|                                                                                 | \$            |
|                                                                                 |               |
|                                                                                 |               |
|                                                                                 |               |
| COMPUTATION OF BASIC NET CAPITAL REQUIREMENT<br>Minimum net capital requirement |               |
| (6 2/3%                                                                         |               |
| of total aggregate indebtedness}                                                | 89,514<br>\$  |
|                                                                                 |               |
|                                                                                 |               |
| Minimum dollar net capital requirement                                          | 100,000<br>\$ |
|                                                                                 |               |
|                                                                                 |               |
| Net capital requirement                                                         | 100,000<br>\$ |
|                                                                                 |               |
|                                                                                 |               |
| INDEBTEDNESS<br>COMPUTATION OF AGGREGATE                                        |               |
| Total liabilities                                                               | \$1,342,703   |
|                                                                                 |               |
| Percentage of Aggregate Indebtedness to                                         |               |
| Net Capital                                                                     | 526.53%       |
|                                                                                 |               |

NOTE: There are no material differences between the computations above and the computations included in the Company's corresponding unaudited Form X-17A-5 Part IIA filing.

# See Accompanying Auditors' Report.

{16}------------------------------------------------

### **American Trust Investment Services, Inc.**

**Schedule** II - **Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 December 31, 2021** 

None, the Company is exempt from Rule 15c3-3 pursuant to the provisions of subparagraph (k)(2)(ii) thereof. Other firm activities are excluded under SEC Footnote 74.

Schedule Ill - Computation for Determination of **PAIB** Reserve Requirements pursuant to Rule 15c3-3 **December 31, 2021** 

None, the Company is exempt from Rule 15c3-3 pursuant to the provisions of subparagraph (k)(2)(ii) thereof. Other firm activities are excluded under SEC Footnote 74.

**Schedule IV** - **Information Relating to Possession or Control Requirements pursuant to Rule 15c3-3 December 31, 2021** 

None, the Company is exempt from Rule 15c3•3 pursuant to the provisions of subparagraph (k)(2)(ii) thereof. Other firm activities are excluded under SEC Footnote 74.

{17}------------------------------------------------

## EXEMPTION REPORT

DECEMBER 31, 2021

{18}------------------------------------------------

BRADFORD R. DOOLEY & ASSOCIATES *)lccountants anti Jl:ud'itors*  209 WEST JACKSON BLVD - SUITE 404 CHICAGO, ILLINOIS 60606

!M.em6er AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNT ANTS

**OFFICE (312) 939-0477 FAX (312) 939-8739** 

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Shareholder of American Trust Investment Services, Inc.

We have reviewed management's statements, included in the accompanying Rule 15c3-3 Exemption Report pursuant to SEC Rule 17a-5, in which (1) American Trust Investment Services, Inc. (the Company) identified the following provisions of 17 C.F.R. §15c3-3{k) under which the Company claimed an exemption from 17 C.F.R. §240.15c3-3:(k)(2)(ii) and (2) the Company stated that it met the identified exemption provisions throughout the most recent fiscal year ended December 31, 2021 without exception.

The Company is also filing this Exemption Report because the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 are limited to: (1) engages in the sale of private placements on a best-efforts basis, (2) receiving compensation for referring securities transactions to other broker dealers, (3) engages in direct sales of mutual funds, (4) engages in the direct sales of annuities and insurance, (5) provided merger acquisition advisory services, (6) provided investment banking consulting services, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b )(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year ending December 31, 2021 without exception.

The Company's management is responsible for compliance with the exemption provisions and its statements.

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.

Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based upon the provisions set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934 and the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions.

Chicago, Illinois March 29, 2022

{19}------------------------------------------------

## Exemption Report

American Trust Investment Services, Inc. (the "Company") is a registered broker--dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-S(d)(l) and (4). To the best of its knowledge and belief, the Company states the following:

(1) The Company claimed an exemption from 17 c. F. R. § 240. 15c3-3 under the following provisions ofl 7 C.F.R. § 24O.1Sc3-3 (k): (2)(ii).

(2) The Company met the identified exemption provisions in 17 C.F.R. § 240.15c3-3(k) throughout the most recent fiscal year ended December 31, 2021, without exception.

(3). The Company is also filing this Exemption Report because the Company's other business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 are limited to: (1) engages in the sale pf private placements on a best-efforts basis, (2) receiving compensation for referring securities transactions to other broker dealers (3) engages in direct sales of mutuals funds,(4) engages in the direct sales of annuities and insurance, (5) provided merger acquisition advisory services, (6) provided investment banking consulting services, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or ( b )(2) ofRu le 15c2-4 and/ or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined by Rule 15c3-3) throughout the most recent fiscal year ending December 31, 2021, without exception.

I, Michael Grady, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

By: **Titl'-ti~~t~-:-7.~~~•~-,**  Da .

{20}------------------------------------------------

### SIPC SUPPLEMENTAL REPORT

DECEMBER 31, 2021

{21}------------------------------------------------

#### **BRADFORD R.** DOOLEY & ASSOCIATES *}lccountants ana }Luditors*  209 WEST JACKSON BLVD - SUITE 404 CHICAGO, ILLINOIS 60606

!Mem6er AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNT ANTS ILLINOIS CPA SOCIETY

OFFICE (312) 939-0477

**FAX**  (312) 939-8739

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES**

Shareholder of American Trust Investment Services, Inc.

We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2021. Management of American Trust Investment Services, Inc. (Company) is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7.

Management of the Company has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting you and SIPC in evaluating the Company's compliance with the applicable instructions on Form SIPC-7 for the year ended December 31 , 2021. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows:

- 1) Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries, noting no differences;
- 2) Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17A-5 Part Ill for the year ended December 31 , 2021 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31 , 2021 , noting no differences;
- 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences;
- 4) Recalculated the arithmetical accuracy ofthe calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments, noting no differences; and
- 5) Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed, noting no differences.

We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). We were not engaged to and did not conduct an examination or a review engagement, the objective of which would be the expression of an opinion or conclusion, respectively, on the Company's Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31 , 2021 . Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

We are required to be independent of the Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.

This report is intended solely for the information and use of the Company and SIPC and is not intended to be and should not be used by anyone other than these specified parties.

Chicago, Illinois March 29, 2022

{22}------------------------------------------------

| SECURITIES INVESTOR PROTECTION CORPORATION<br>SIPC-7<br>Mail Code: 8967 P.O. Box 7247 Philadelphia, PA 19170-0001<br>(36-REV 12/18)<br>(Read carefully the instructions in your Working Copy before completing this Form)<br>TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS<br>1. Name of Member, address, Designated Examining Authority, 1934 Act registration no. and month in which listed year ends for<br>purposes of the audit requirement of SEC Rule 17a-5:<br>American Trust Investment Services, Inc.<br>1244 199th St.<br>Whiting, IN 46394 | General Assessment Reconciliation<br>For the fiscal year ended 12/31/2021 | Note: If any of the information shown on the<br>mailing label requires correction, please e-mail<br>any corrections to form@sipc.org and so<br>indicate on the form tiled.<br>Name and telephone number of person to<br>contact respecting this form. | SIPO<br>(36-REV 12/18 | es<br>ORKING |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------|--------------|
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |                                                                           | Mike Grady                                                                                                                                                                                                                                            |                       | 10           |
| 2. A. General Assessment (item 2e from page 2)<br>B. Less payment made with SIPC-6 filed (exclude Interest)<br>#2345 71/27                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                           | 12,732<br>5,288                                                                                                                                                                                                                                       |                       |              |
| Date Paid<br>C. Less prior overpayment applied                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                           | 160                                                                                                                                                                                                                                                   |                       |              |
| D. Assessment balance due or (overpayment)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |                                                                           | 7,384                                                                                                                                                                                                                                                 |                       |              |
| E. Interest computed on late payment (see instruction E) for _________________________________________________________________________________________________________________                                                                                                                                                                                                                                                                                                                                                                                    |                                                                           |                                                                                                                                                                                                                                                       |                       |              |
| F. Total assessment balance and interest due (or overpayment carried forward)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     |                                                                           |                                                                                                                                                                                                                                                       |                       |              |
| G. PAYMENT: V the box<br>Check mailed to P.O. Box V Funds Wired<br>Total (must be same as F above)                                                                                                                                                                                                                                                                                                                                                                                                                                                                | ACH<br>7384                                                               |                                                                                                                                                                                                                                                       |                       |              |
| H. Overpayment carried forward                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    | \$1 60                                                                    |                                                                                                                                                                                                                                                       |                       |              |
| 3. Subsidiaries (S) and predecessors (P) included in this form (give name and 1934 Act registration number):                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                           |                                                                                                                                                                                                                                                       |                       |              |
| The SIPC member submitting this form and the<br>person by whom it is executed represent thereby<br>that all information contained herein is true, correct<br>and complete.<br>Dated the 8th day of February<br>This form and the assessment payment is due 60 days atter the end of the fiscal year. Retain the Working Copy of this torm<br>for a period of not less than 6 years, the latest 2 years in an easily accessible place.                                                                                                                             | CFO                                                                       | American Tryst Investigent Services, Inc.<br>Corporation, Parinesship Parinership<br>alher bigacization)<br>(Atthofized Signature)<br>(Title)                                                                                                         |                       |              |
| Dates:<br>Postmarked<br>Received<br>Reviewed                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                           |                                                                                                                                                                                                                                                       |                       |              |

프로 Calculations \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Documentation \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Forward Copy -------

{23}------------------------------------------------

#### DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT

|                                                                                                                                                                                                                                                                                                                                                                                               | Amounts for the fiscal period<br>beginning 1/1/2021<br>and ending 12031291 |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|
|                                                                                                                                                                                                                                                                                                                                                                                               |                                                                            |
| Item No.<br>2a. Tolal revenue (FOCUS Line 12/Par( IIA Line 9. Code 4030)                                                                                                                                                                                                                                                                                                                      | Eliminate cents<br>\$ 10,362,533                                           |
| 2b. Additions:<br>(1) Total revenues from the securities business of subsidiaries [except toreign subsidiaries) and<br>predecessors not included above.                                                                                                                                                                                                                                       |                                                                            |
| (2) Net loss from principal transactions in securities in trading accounts.                                                                                                                                                                                                                                                                                                                   |                                                                            |
| (3) Net loss from principal transactions in commodities in trading accounts.                                                                                                                                                                                                                                                                                                                  |                                                                            |
| (4) Inferest and dividend expense deducted in determining them 2a.                                                                                                                                                                                                                                                                                                                            |                                                                            |
| (5) Net loss from management of or participation in the underwriting or distribution of securities.                                                                                                                                                                                                                                                                                           |                                                                            |
| (6) Expenses other than advertising, printing, registration lees and legal fees deducted in defermining nel<br>profit from management of or participation in underwriting or distribution of securities.                                                                                                                                                                                      |                                                                            |
| (7) Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                          |                                                                            |
| Total additions                                                                                                                                                                                                                                                                                                                                                                               |                                                                            |
| 2c. Deductions:<br>(1) Revenues from the distribulion of shares of a registered open end investment company or unit<br>investment Irust, from the sale of variable annufies, from the business of insurance, from investment<br>advisory services rendered to registered investment companies or insurance company separate<br>accounts, and from transactions in security fullures products. | 88,177                                                                     |
| (2) Revenues from commodity fransactions.                                                                                                                                                                                                                                                                                                                                                     |                                                                            |
| (3) Commissions. floor brokerage and clearance paid to other SIPC members in connection with<br>securities fransactions.                                                                                                                                                                                                                                                                      | 736,337                                                                    |
| (4) Reimbursements for postage in connection with proxy solicitation.                                                                                                                                                                                                                                                                                                                         |                                                                            |
| (5) Net gain from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                          | 40,514                                                                     |
| (6) 100% of commissions and markups earned from transactions in (i) certificates of deposit and<br>(ii) Treasury bills, bankers acceptances or commercial paper That mature nine months of less<br>from issuance date.                                                                                                                                                                        |                                                                            |
| (7) Direct expenses of printing advertising and legal lees incurred in connection with other revenue<br>related to the securities business (revenue defined by Section 16(9)(L) of the Acl).                                                                                                                                                                                                  |                                                                            |
| (B) Other revenue not related Bither directly or indirectly to the securities business.<br>(See Instruction C).                                                                                                                                                                                                                                                                               |                                                                            |
| Annuities                                                                                                                                                                                                                                                                                                                                                                                     | 1,000,338                                                                  |
| (Deductions in excess of \$100,000 require documentation)<br>(9) {} Total Interest and dividend expense (FOCUS Line 22/PART IIA Line 13,<br>Code 4075 plus line 2b(4) above) but not in excess<br>of lotal interest and dividend income.                                                                                                                                                      |                                                                            |
| (ii) 40% of margin interest earned on customers securities<br>9,009<br>accounts (40% of FOCUS line 5, Code 3960).                                                                                                                                                                                                                                                                             |                                                                            |
| Enter the greater of line (i) or (ii)                                                                                                                                                                                                                                                                                                                                                         | 9,008                                                                      |
| Tolal deductions                                                                                                                                                                                                                                                                                                                                                                              | 1,874,375                                                                  |
| 2d. SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                                               | 8,488,158                                                                  |
| 2e. General Assessment @ . 0015                                                                                                                                                                                                                                                                                                                                                               | 12,732                                                                     |
|                                                                                                                                                                                                                                                                                                                                                                                               | (10 page 1, line 2.A.)                                                     |


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
