# E. MAGNUS OPPENHEIM & CO. INC. X-17A-5 (2021-03-15) — Broker-dealer annual report
- Company: E. MAGNUS OPPENHEIM & CO. INC.
- Form: X-17A-5
- Filed: 2021-03-15
- Period: 2020-12-31
- Accession: 0000276401-21-000004
- CIK: 276401
- File #: 8-23411
- Material weakness: No
- Auditor: Michael T.Remus, CPA
- Auditor location: Hamilton Square, NJ
- Contact: Paul Ebert
- Phone: 2017389373
- Signed by: Paul Ebert (FINOP)
Original filing: https://www.sec.gov/Archives/edgar/data/276401/000027640121000004/aaemagnus.pdf
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| MB Number: | 3235-0123 | |
|------------|--------------------------|--|
| | pires: October 31, 2023 | |
| | timated average burden | |
| | ours per response 12.00 | |
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| SEC FILE NUMBER | |
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| 8-23411 | |
| REPORT FOR THE PERIOD BEGINNING 01/01/2020 | | | AND ENDING 12/31/2020 | |
|---------------------------------------------------------------------------------------|---------------------------------------------------------------------|---------------|--------------------------------|--|
| | MM/DD/YY | | MM/DD/YY | |
| | A. REGISTRANT IDENTIFICATION | | | |
| NAME OF BROKER-DEALER: E Magnus Oppenheim & Co., Inc. | | | OFFICIAL USE ONLY | |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | FIRM I.D. NO. | | |
| 575 Lexington Aveneu - 17th Floor | | | | |
| | (No. and Street) | | | |
| New York | NY | | 10022 | |
| (City) | (State) | | (Zip Code) | |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Paul Ebert | | | 201-738-9373 | |
| | | | (Area Code - Telephone Number) | |
| | B. ACCOUNTANT IDENTIFICATION | | | |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | |
| Michael T. Remus, CPA | | | | |
| | (Name - if individual, state last, first, middle name) | | | |
| PO Box 2555 | Hamilton Square | N.J | 08690 | |
| (Address) | (City) | (State) | (Zip Code) | |
| CHECK ONE: | | | | |
| Certified Public Accountant | | | | |
| Public Accountant | | | | |
| | Accountant not resident in United States or any of its possessions. | | | |
| | FOR OFFICIAL USE ONLY | | | |
| | | | | |
| | | | | |
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# **E. Magnus Oppenheim & Co. Inc.**
## *FINANCIAL STATEMENTS*
*AND*
*SUPPLEMENTARY INFORMATION*
**For the Year Ended**
**December 31, 2020**
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# **MICHAEL T. REMUS** *Certified Public Accountant*
P.O. Box 2555 Hamilton Square, NJ 08690
> **Tel:** 609-540-1751 **Fax:** 609-570-5526
#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
#### To: The Stockholder **E. Magnus Oppenheim & Co. Inc.**
#### **Opinion on the Financial Statements**
I have audited the accompanying statement of financial condition of E. Magnus Oppenheim & Co., Inc. as of December 31, 2020, and the related statements of operations, changes in stockholder's equity and cash flows for the year then ended, that are filed pursuant to Rule 17a-5 under the Securities Exchange Act of 1934 and the related notes and schedules (collectively referred to as the financial statements). In my opinion, the financial statements present fairly, in all material respects, the financial position of E. Magnus Oppenheim & Co., Inc. as of December 31, 2020 and its results of 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 E. Magnus Oppenheim & Co., Inc.'s management. My responsibility is to express an opinion on E. Magnus Oppenheim & Co., Inc.'s financial statements based on my audit. I am a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and I am required to be independent with respect to E. Magnus Oppenheim & Co., 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.
I conducted my audit in accordance with the standards of the PCAOB. Those standards require that I 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. My 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. My 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. I believe that my audit provides a reasonable basis for my opinion.
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#### **Supplemental Information**
The supplemental information is the responsibility of E. Magnus Oppenheim & Co., Inc.'s management. My 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 my opinion on the supplemental information, I evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In my opinion, the Schedule I, Computation of Net Capital Under SEC Rule 15c3-1, Schedule II, Computation for Identification of Reserve Requirements Under SEC Rule 15c3-3 (*exemption*) and Schedule III, Information Relating to Possession or Control Requirements Under SEC Rule 15c3-3 (*exemption)* is fairly stated, in all material respects, in relation to the financial statements as a whole.
# *Michael T Remus*
I have served as E. Magnus Oppenheim & Co., Inc.'s auditor since 2020.
Michael T. Remus, CPA Hamilton Square, New Jersey March 8, 2021
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#### STATEMENT OF FINANCIAL CONDITION
December 31, 2020
#### **ASSETS**
| Current Assets | |
|----------------------|---------------|
| Cash | \$
73,484 |
| Due from clearing | 161,162 |
| Prepaid expense | 2,244 |
| Total Current Assets | 236,890 |
| | |
| Other Assets | |
| Deposit at clearing | 15,063 |
| Other | 1,524 |
| | |
| Total Assets | \$
253,477 |
#### **LIABILITIES AND STOCKHOLDER'S EQUITY**
| Current Liabilities | |
|----------------------------------------------|---------------|
| Accounts payable and accrued expenses | \$
19,071 |
| Advances | 4,696 |
| Total Current Liabilities | 23,767 |
| Total Liabilities | 23,767 |
| Stockholder's Equity | |
| Common stock, \$1 Par Value, 200 shares | |
| authorized, 50 shares issued and outstanding | 50 |
| Retained earnings | 229,660 |
| Total Stockholder's Equity | 229,710 |
| Total Liabilities and Stockholder's Equity | \$
253,477 |
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#### STATEMENT OF OPERATIONS
Year Ended December 31, 2020
#### **REVENUES**
| Advisory fees | \$
634,456 |
|--------------------------------------------|---------------|
| Commissions, net of clearing fees | 30,308 |
| Interest and dividend income | 5 |
| Other income | 16 |
| | |
| | 664,785 |
| OPERATING EXPENSES | |
| Employee compensation | 269,983 |
| Payroll and other taxes | 19,727 |
| Insurance | 12,557 |
| Rent | 27,854 |
| Professional fees | 191,913 |
| Custodial fees | 28,015 |
| General & administrative | 14,397 |
| Regulatory fees | 2,850 |
| Travel & marketing | 1,834 |
| | 569,130 |
| | |
| Income From Operations & Before Income Tax | 95,655 |
| Income tax | 9,107 |
| Net Income | \$
86,548 |
See accompanying notes.
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## **E. MAGNUS OPPENHEIM & CO. INC.** STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY Year Ended December 31, 2020
| | Common Stock | | | | | | Total | |
|------------------------------|--------------|----|--------|----------|----------|--------|---------------|--|
| | Number of | | | | Retained | | Stockholder's | |
| | Shares | | Amount | Earnings | | Equity | | |
| Balance at December 31, 2019 | 50 | \$ | 50 | \$ | 193,167 | \$ | 193,217 | |
| Adjustment | | | | | (55) | | (55) | |
| Net Income | - | | - | | 86,548 | | 86,548 | |
| Distributions to shareholder | - | | - | | (50,000) | | (50,000) | |
| Balance at December 31, 2020 | 50 | \$ | 50 | \$ | 229,660 | \$ | 229,710 | |
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#### STATEMENT OF CASH FLOWS Year Ended December 31, 2020
#### **CASH FLOWS FROM OPERATING ACTIVITIES**
| Net Income | \$ | 86,548 |
|----------------------------------------------------------------------------------------------------------------------------|----------|-------------------------------------|
| Adjustments to Reconcile Net Income to Net
Cash Provided by Operating Activities: | | |
| Adjustment | | (55) |
| Increase (decrease) in cash attributable to
changes in operating assets and liabilities | | |
| (Increase) Decrease in Operating Assets:
Receivables
Prepaid expenses
Due from shareholder
Deposit at clearing | | (12,062)
(1,122)
7,591
(4) |
| Increase (Decrease) in Operating Liabilities:
Accounts payable and accrued expenses
Advances | | 2,388
(456) |
| Net cash provided by operating activities | | 82,828 |
| Cash Flows From Investing Activities | | - |
| Cash Flows From Financing Activities
Shareholder Distributions | | (50,000) |
| Net cash (used in) financing activities | | (50,000) |
| Net increase in cash | | 32,828 |
| Cash, at Beginning of Year | | 40,656 |
| Cash, at End of Year | \$ | 73,484 |
| Supplemental Disclosures
Cash paid for income taxes
Cash paid for interest | \$
\$ | 9,107
- |
See accompanying notes.
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Notes to Financial Statements Year Ended December 31, 2020
#### 1 **Organization and Nature of Business**
E. Magnus Oppenheim & Co. Inc.(the Company) is a New York corporation conducting business as an investment advisor and a securities broker dealer. The Company holds no customer funds or securities and does not participate in the underwriting of Securities. The Company is registered with the Securities and Exchange Commission and is a member of the Financial Industry Regulatory Authority - FINRA and SIPC.
The Company, under Rule 15c3-3(K)(2)(ii), is exempt from the reserve and possession or control requirements of Rule 15c3-3 of the Securities and Exchange Commission. The Company does not cqarry or clear customer accounts.
## **2 Significant Accounting Policies**
## *(a) Basis of Presentation*
The financial statements and accompanying notes are prepared in accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP") unless otherwise disclosed.
#### *(b) Use of Estimates*
The preparation of financial statements in conformity with generally accepted accounting principles 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 revenue and expenses during the reporting period. Actual results could differ from those estimates.
#### *( c) Statement of Cash Flows*
For purposes of the statement of cash flows the Company has defined cash equivalents as highly liquid investments, with original maturities of less than three months, that are not held for sale in the ordinary course of business. The company has adopted the indirect method of presenting the statement of cash flows in accordance with current authoritative pronouncements.
#### *(d) Accounts Receivable*
The Company establishes an allowance for uncollectible trade accounts receivable based on managements evaluation of the collectibility of outstanding accounts receivable. Management has evaluated accounts receivable at December 31, 2020 and believes they are all collectible. Accounts receivable are not collateralized.
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Notes to Financial Statements
Year Ended December 31, 2020
#### (*e) Revenue Recognition*
The Company earns commissions from executing and clearing customer transactions in stock and bond markets. Commissions and related clearing expenses are recorded on a trade-date basis as securities transactions occur.
The Company recognizes revenue from advisory fees in the period earned in accordance with Topic 606, that is when the transaction has been completed and all performance obligations have been satisfied.
## (f) Income Taxes
The Company, with the consent of its shareholder, has elected under the Internal Revenue Code to be treated as an S Corporation. In lieu of corporation income taxes, the shareholders of an S Corporation are taxed on their proportionate share of the Company's taxable income. Therefore, no provision or liability for federal income taxes has been included in the financial statements. The Company's tax returns and the amount of income or loss allocable to each shareholder are subject to examination by federal and state taxing authorities. In the event of an examination of the Company's tax return, the tax liability of the shareholders could be changed if an adjustment in the Company's income or loss is ultimately determined by the taxing authorities.
Certain transactions of the Company's may be subject to accounting methods for federal and state income tax purposes which differ significantly from the accounting methods used in preparing the financial statements. Accordingly, the net income or loss of the Company and the resulting balances in the shareholders' capital accounts reported for federal and state income tax purposes may differ from the balances reported for those same items in these financial statements.
The Company recognizes and measures its unrecognized tax benefits in accordance with ASC Topic 740, Income Taxes. Under that guidance the Company assesses the likelihood, based on their technical merit, that tax positions will be sustained upon examination based on the facts, circumstances and information available at the end of the financial reporting period. The measurement of unrecognized tax benefits is adjusted when new information is available, or when an event occurs that requires a change.
Management has determined that there are no uncertain tax positions which require adjustment or disclosure on the financial statements at December 31, 2020 and there are no open tax years prior to 2016. In addition, no income tax related penalties or interest have been recorded for the year ended December 31, 2020.
#### *(g) Advertising and Marketing*
Advertising and marketing costs (if any)are expensed as incurred.
#### *(h) General and Administrative Expenses*
General and administrative costs are expensed as incurred.
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Notes to Financial Statements
Year Ended December 31, 2020
#### *(i) Subsequent Events*
The Company has evaluated subsequent events occurring after the statement of financial condition date through the date of March 8, 2021 which is the date the financial statements were available to be issued. Based on this evaluation, the Company has determined that no subsequent events have occurred which require disclosure in or adjustment to the financial statements.
## (j*) Fair Value Hierarchy*
FASB ASC 820 defines fair value, establishes 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 FASB ASC 820, are used to measure fair value.
The fair value hierarchy prioritizes the inputs to valuation techniques used to measure fair value into three broad levels:
Level 1 - Quoted prices (unadjusted) in active markets for identical assets or liabilities that the Company has the ability to access at the measurement date.
Level 2 - Inputs other than quoted prices included in Level 1 that are observable for the assets or liability either directly or indirectly.
Level 3 - Inputs are unobservable for the assets or liability and include situations where there is little, if any, market activity for the asset or liability..
The availability of observable inputs can vary from security to security and is affected by a wide variety of factors, including, for example, the type of security, the liquidity of markets, and other characteristics particular to the security. To the extent the valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgment. Accordingly, the degree of judgment exercised in determining the fair value is greatest for instruments categorized in level 3.
The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety is determined based on the lowest level input that is significant to the fair value measurement in its entirety.
For further discussion of fair value, see "Note 7 Fair Value"
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Notes to Financial Statements
Year Ended December 31, 2020
#### **3 Net Capital Requirements**
The Company is subject to the SEC Uniform Net Capital Rule (SEC Rule 15c3-1), 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 15 to 1 (and the rule of the "applicable" exchange also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1). At December 31, 2020, the Company had net capital of \$152,462, which was \$147,462 in excess of its required minimum net capital of \$5,000. The Company's net capital ratio was 0.1559 to 1.
## 4 **Credit Risk and Concentrations**
A significant amount of the Company's advisory fees and commission income is generated through the E.M.O. Sterling Return LT Fund.
The Company maintains its cash balances in various financial institutions. The Federal Deposit Insurance Corporation insures the Company's bank accounts up to \$250,000 but not the money market funds. The Company has not experienced any losses on these accounts and believes it is not subject to any significant credit risk.
## **5 Related Party Transactions**
The Company is an investment manager to the E.M.O. Sterling Return Fund L.P. which is an investment fund whose general partner is E.M.O. Asset Management Inc. The investment fund has a third party bank custodian of all assets, a fund accountant and an independent certified public accountant to monitor its activities and resultant asset values.
The Company earned \$634,456 in advisory fees during the year. Accounts receivable from the fund at December 31, 2020 was \$161,162.
The Company paid its principal shareholder a consulting fee in the amount of \$29,570.
#### **6 Lease**
The Company leases office space under a membership agreement dated November 30, 2018 which expired on December 15, 2019 and was not renewed. The agreement is currently on a month to month basis.
Rent expense for the year ended December 31, 2020 was \$27,854.
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Notes to Financial Statements Year Ended December 31, 2020
## **7 Fair Value**
Cash, receivables, accounts payable and other current liabilities are reflected in the financial statements at carrying value which approximates fair value because of the short-term maturity of these instruments.
## **8 Commitments and Contingencies**
Pursuant to Securities and Exchange Commission Rule 15c3-1(e)(2) the Company may not authorize distributions to its stockholder if such distributions cause the Company's net capital to fall below 120% of the Company's minimum net capital requirement. As of December 31, 2020 the Company was not in violation of this requirement.
The Company had no lease or equipment rental commitments (except as disclosed in Note 6 above), no underwriting commitments, no contingent liabilities, and had not been named as a defendant in any lawsuit at December 31, 2020 or during the year then ended.
## **9 Anti-Money Laundering Policies and Procedures**
The Company is required to implement policies and procedures relating to anti-money laundering, compliance, suspicious activities, and currency transaction reporting and due diligence on customers who open accounts with the Company. At December 31, 2020 the Company had implemented such policies and procedures.
## **10 COVID 19**
In March 2020, the World Health Organization (WHO) declared COVID-19 a global pandemic. This pandemic event has resulted in significant business disruption and uncertainty in both global and U.S. markets. While management believes the Company is in an appropriate position to weather the potential short-term effects of these world-wide events, the direct and long-term impact to the Company and its financial statements is undetermined at this time.
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**Supplementary Information**
**Pursuant to Rule 17a-5 of the**
**Securities Exchange Act of 1934**
**As of December 31, 2020**
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#### COMPUTATION OF NET CAPITAL IN ACCORDANCE WITH RULE 15c 3-1
#### Year Ended December 31, 2020
#### Schedule I
#### NET CAPITAL
| | Common stock | \$ | 50 |
|------------|---------------------------------------------------------------------------------------------------------------------|----|-------------|
| | Retained earnings | | 229,660 |
| | Total Credits | | 229,710 |
| Debits | | | |
| | Due from clearing | | 73,480 |
| | Prepaid expense | | 2,244 |
| | Other | | 1,524 |
| | Total Debits | | 77,248 |
| | NET CAPITAL | \$ | 152,462 |
| | | | |
| | CAPITAL REQUIREMENTS | | |
| | 6 2/3 % of aggregate indebtedness | \$ | 1,583 |
| | Minimum capital requirement | | 5,000 |
| | Net capital in excess of requirements | \$ | 147,462 |
| | Ratio of Aggregate Indebtedness to
Net Capital | | 0.1559 to 1 |
| | Reconciliation with Company's Computation (included in
Part II of Form X-17A-5 as of December 31, 2020) | | |
| | Reconciliation pursuant to Rule 17a-5(d) (4) of the Audited Computations
of Net Capital pursuant to Rule 15c 3-1 | | |
| | Net Capital, as reported in Company's Part II unaudited Focus Report | \$ | 152,462 |
| | Net Capital, per above | | 152,462 |
| Difference | | \$ | - |
There are no material differences between the net capital reflected in the above computation and the net capital reflected in the Company's FOCUS Report as of December 31, 2020.
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## **E. Magnus Oppenheim & Co. Inc.**
## SCHEDULE II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 (EXEMPTION)
Schedule II
## YEAR ENDED December 31, 2020
Pursuant to Rule 17a-5(d) (4) of the audited computations of Net Capital pursuant to Rule 15c 3-1 and computation for Determination of Reserve requirements pursuant to Rule 15c 3-3 submitted by E. Magnus Oppenheim & Co. Inc. in my opinion no material differences exist which would materially effect the reserve requirements pursuant to Rule 15c 3-3 or its claim for exemption.
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#### **E. Magnus Oppenheim & Co. Inc.**
## SCHEDULE III INFORMATION RELATING TO POSSESSION OR CONTROL REQUIREMENTS (EXEMPTION)
## PURSUANT TO RULE 15c 3-3 of the Securities and Exchange Commission
## As of December 31, 2020
#### **"EXEMPT UNDER 15c3-3(k)(2)(ii)**
Schedule III
Pursuant to rule 15c 3-3 relating to possession or control requirements, E. Magnus Oppenheim & Co. Inc**.** has not engaged in the clearing or trading of any securities and did not hold customer funds or securities during the year ended December 31, 2020 and therefore is claiming exemption to this schedule pursuant to paragraph (k)(2)(ii) of SEC Rule 15c3-3. The firm's minimum net capital requirement pursuant to paragraph (a)(2)(vi) of SEC Rule 15c3-1 will be \$5,000.
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## **MICHAEL T. REMUS**
# *Certified Public Accountant*
P.O. Box 2555 Hamilton Square, NJ 08690 **Tel:** 609-540-1751 **Fax:** 609-570-5526
## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
## To: The Stockholder **E. Magnus Oppenheim & Co. Inc.**
I have reviewed management's statements, included in the accompanying Schedule I Computation of Net Capital under Rule 15c3-1, Schedule II Computation for Determination of Reserve Requirements under Rule 15c3-3 (Exemption), in which (1) E. Magnus Oppenheim & Co. Inc**.** identified the following provisions of 17 C.F.R. §15c3-3(k) under which E. Magnus Oppenheim & Co. Inc. claimed an exemption from 17 C.F.R. §240.15c3-3: under—(k)(2)(ii), (the "exemption provisions") and (2) E. Magnus Oppenheim & Co. Inc**.** stated that E. Magnus Oppenheim & Co. Inc**.** met the identified exemption provisions throughout the most recent fiscal year without exception and Schedule III Information for Possession or Control Requirements under Rule 15c3-3 (Exemption). E. Magnus Oppenheim & Co. Inc**.** management is responsible for compliance with the exemption provisions and its statements.
My 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 E. Magnus Oppenheim & Co. Inc**.** 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, I do not express such an opinion.
Based on my review, I am 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 on the provisions set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934.
*Michael T. Remus*
Michael T. Remus, CPA Hamilton Square, New Jersey March 8, 2021
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E. Magnus Oppenheim & Co., Inc. Exemption Report Pursuant to SEC Rule 17a-5 For the Year Ending December 31, 2020
E. Magnus Oppenheim & Co., 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- s: Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17CFR 240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following:
The Company claimed an exemption from 17C.F.R. 240.15c3-3 under the following provisions of17C.F.R. 240.15c3-3(k):
• Operate pursuant to SEC Rule 15c3-3{k)(2)(ii) {the Customer Protection Rule). E. Magnus Oppenheim & Co., Inc. an exemption from SEC Rule 15c3-3.
During the fiscal year ending December 31, 2019, E. Magnus Oppenheim & Co., Inc. met without exception the aforementioned exemption provisions from17C.F.R. 240.15c3-3.
I, E. Magnus Oppenheim, affirm that, to my best knowledge and belief, this Exemption Report is true and correct.
Chief Compliance Officer
Dated:
Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.