# KEEL POINT CAPITAL, LLC X-17A-5 (2024-09-24) — Broker-dealer annual report - Company: KEEL POINT CAPITAL, LLC - Form: X-17A-5 - Filed: 2024-09-24 - Period: 2022-12-31 - Accession: 0000276721-24-000007 - CIK: 276721 - File #: 8-22990 - Type: Broker-dealer - Material weakness: No - Auditor: Crowe LLP - Auditor location: New York, NY - Contact: Sandra Stephens - Phone: 256-704-5113 - Email: sstephens@keelpoint.com - Website: keelpoint.com - Signed by: Sandra Stephens (CFO) Original filing: https://www.sec.gov/Archives/edgar/data/276721/000027672124000007/KeelPointConfidential22.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** 0MB APPROVAL 0MB Number: 3235-0123 Expires: Oct. 31, 2023 Estimated average burden hours per response: 12 ## **ANNUAL REPORTS FORM X-17A-S PART** Ill | SEC FILE NUMBER | |-----------------| | 8-22990 | MM/DD/VY **FACING PAGE** **Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934** FILING FOR THE PERIOD BEGINNING **O 1/01/2022** AND ENDING **12/31/2022** MM/DD/YY **A. REGISTRANT IDENTIFICATION** # NAME oF FIRM: Keel Point Capital, LLC TYPE OF REGISTRANT (check all applicable boxes): 0 Broker-dealer O Security-based swap dealer □ Major security-based swap participant □ Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) # 100 Church Street, Suite 500 | | (No. and Street) | | |------------|------------------|------------| | Huntsville | AL | 35801 | | (City) | (State) | (Zip Code) | PERSON TO CONTACT WITH REGARD TO THIS FILING | Sandra Stephens | 256-704-5113 | sstephens@keelpoint.com | |-----------------|-------------------------------|-------------------------| | (Name) | (Area Code -Telephone Number) | (Email Address) | | | | | ### **B. ACCOUNTANT IDENTIFICATION** INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\* # Crowe LLP | 435 Lexington Ave Floor 11 | (Name - if individual, state last, first, and middle name)
New York | NY | 10017 | |----------------------------------------|------------------------------------------------------------------------|---------|-------------------------------------------| | (Address) | (City) | (State) | (Zip Code) | | l"
09/24/2003 | | 173 | | | of RegJmauoa w;th PCAOB)(lf appHcableJ | | | {PCAOB Regl~,aUoa N,mbec, ;f applkableJ I | | | FOR OFFICIAL USE ONLY | | | \* Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.l 7a-S(e)(l)(ii), if applicable. **Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** {1}------------------------------------------------ ### **OATH OR AFFIRMATION** | | I, Sandra Stephens
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,,,,\ | | | | | | | | | | | | | | | | | !ii | This filing** contains (check all applicable boxes):
(a) Statement of financial condition. | | | | | | | | !ii | (b) Notes to consolidated statement of financial condition. | | | | | | | | !ii | (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of | | | | | | | | | comprehensive income (as defined in§ 210.1-02 of Regulation S-X). | | | | | | | | !! | (d) Statement of cash flows. | | | | | | | | !! | (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. | | | | | | | | 0 | (f) Statement of changes in liabilities subordinated to claims of creditors. | | | | | | | | !ii | (g) Notes to consolidated financial statements. | | | | | | | | !! | (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-l, as applicable. | | | | | | | | 0 | (i) Computation of tangible net worth under 17 CFR 240.18a-2. | | | | | | | | | □ (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. | | | | | | | | 0 | (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.lBa-4, as applicable. | | | | | | | | D | (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. | | | | | | | | 0 | (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. | | | | | | | | | □ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR | | | | | | | | | 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. | | | | | | | | | □ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net | | | | | | | | | worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, 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 subsidiaries not consolidated in the statement of financial condition.
(q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.lBa-7, as applicable. | | | | | | | | 0 | (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.lBa-7, as applicable. | | | | | | | | !ii | (t) Independent public accountant's report based on an examination of the statement of financial condition. | | | | | | | | 0 | (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 | | | | | | | | | CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. | | | | | | | | 0 | (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. | | | | | | | | 0 | (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 240.15c3-le or 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). | | | | | | | | iii | (z) Other: _S_IP_C_7 ____________________________________
_ | | | | | | | \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 24D.17a-5(e}(3) or 17 CFR 240.18a-7(d}(2), as applicable. {2}------------------------------------------------ FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION DECEMBER 31, **2022** {3}------------------------------------------------ ### **CONTENTS** ### PAGE NUMBER | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 3 | |---------------------------------------------------------|---| |---------------------------------------------------------|---| ### FINANCIAL STATEMENTS | STATEMENT OF FINANCIAL CONDITION | .4 | |-----------------------------------------|------| | STATEMENT OF INCOME | 5 | | STATEMENT OF CHANGES IN MEMBER'S EQUITY | 6 | | STATEMENT OF CASH FLOWS | 7 | | NOTES TO FINANCIAL STATEMENTS | 8-13 | ### SUPPLEMENTAL INFORMATION | COMPUTATION OF NET CAPITAL PURSUANT TO SEC RULE 15c3-1
| 14 | |------------------------------------------------------------------------------------------------|-------| | KEEL POINT CAPITAL, LLC EXEMPTION REPORT | 15 | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | 16 | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
ON APPL YING AGREED-UPON PROCEDURES | 17-18 | | GENERAL ASSESSMENT RECONCILIATION (FORM SIPC-7)
| 19-20 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) Crows LILP degrambert: Mustas: Circ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Baard of Directors and Member of Keel Paint Capital, LLC Huntsville, Alabama #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Keel Point Capital, LLC (the "Company") as of December 31, 2022, the related statements of income, changes in member's equily, and cash flows for the year ended December 31, 2022, and the related notes (collectively referred to as the "linancial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2022, and the rasults of its operations and its cash flows for the year ended December 31, 2022, in corflormity with accounting principles generally accepted in the United States of America. #### Basis for Opinion These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board ("PCAOB") and are required to be independent with respect to the Company 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 missiatement 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. #### Supplemental Information The Computation of Net Capital Pursuant to SEC Rule 15c3-1 (the "Supplemental Information") has been subjected to audit procedures performed in conjunction with the Company's financial statements. The Supplemental Information is the responsibility of the Company'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. We have served as the Company's auditor since 2022. New York. New York March 29, 2023 {5}------------------------------------------------ #### STATEMENT OF FINANCIAL CONDITION #### DECEMBER 31, 2022 #### ASSETS | Assets | | |---------------------------------|-----------------| | Cash | \$
1,630.366 | | Receivable from clearing broker | 31,844 | | Accounts receivable | 37,020 | | Deposits with clearing broker | 50,000 | | Other assets | 34,610 | | Total assets | 1,783,840 | | TOT Al ASSETS | \$
1,783,840 | #### LIABILITIES AND MEMBER'S EQUITY | Liabilities | | |----------------------------------------|-----------------| | Accounts payable and accrued expenses | \$
19,196 | | lntercompany payable | 121,614 | | T otai liabitities | 140,810 | | Member's Equity | 1,643,030 | | TOT Al LIABILITIES AND MEMBER'S EQUITY | \$
1.783,840 | {6}------------------------------------------------ #### STATEMENT **OF INCOME** #### FOR THE YEAR ENDED DECEMBER 31. 2022 | Revenues | | | |-------------------------------------|---|---------| | Commission income | | 550,620 | | DMdends and interest | | 26,989 | | other income | | 857 | | Total revenues | | 578,466 | | Expenses | | | | Salaries and employee benefits | | 240,987 | | Office and other operating expenses | | 190,886 | | Total operating expenses | | 431,873 | | Net Income | s | 146,593 | {7}------------------------------------------------ # KEEL POINT CAPITAL, LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31. 2022 | | Member's
Equity | | |--------------------------------|--------------------|-----------| | Balance. beginning of the year | \$ | 1,496.437 | | Net Income | | 146,593 | | Balance, end of year | \$ | 1.643,030 | {8}------------------------------------------------ ### STATEMENT OF CASH FLOWS ### FOR THE YEAR ENDED DECEMBER 31, 2022 ### CASH FLOWS FROM OPERA TING ACTIVITIES | Net Income | s | 146,59 1
3 | | |-----------------------------------------------------|----|---------------|--| | Adjustments to reconcile net income to net | | | | | cash used In operating activities: | | | | | Increase in cash related to changes in assets: | | | | | Receivable from clearing broker | | 123,065 | | | Accounts receivable | | 4,700 | | | Other current assets | | 9,850 | | | Decrease in cash related to changes In liabilities: | | | | | Accounts payable and accrued expenses | | (6,753) | | | lntercompany payable | | {2,466) | | | NET CASH USED IN OPERA TING ACTIVITIES | | 274,989 | | | NET INCREASE IN CASH AND CASH EQUIVALENTS | | 274,989 | | | CASH ANO CASH EQUIVALENTS. BEGINNING OF YEAR | | 1.355.377 | | | CASH AND CASH EQUIVALENTS. END OF YEAR | \$ | 1,630.366 | | | | | | | {9}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### DECEMBER 31, 2022 ### NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES ### Organization Keel Point Capital, LLC (the "Company"), is a Delaware limited liability company. The Company was formed for the purpose of conducting business as a brokerdealer in securities. The Company is a member of and is subject to regulations by the Financial Industry Regulatory Authority (FINRA). The Company is a wholly owned subsidiary of Keel Point Partners, LLC ("Keel Point Partners") and is registered with the Securities Exchange Commission ("SEC"). The Company is exempt from the provisions of SEC Rule 15c3-3 under paragraph (k)(2)(ii). ### Cash and Cash Equivalents For the purposes of the statement of cash flows, the Company considers cash and highly liquid investments with original maturities of three months or less when purchased to be cash and cash equivalents. At times, the Company maintains cash in bank deposits that, at times, exceed federally insured limits. The Company did not experience any losses and does not anticipate any losses associated with these accounts. ### Current Expected Credit Losses (CECL) The Company accounts for estimated credit losses on financial assets measured at an amortized cost basis and certain off-balance sheet credit exposures in accordance with FASB ASC 326-20, Financial Instruments - Credit Losses. FASB ASC 326-20 requires the Company to estimate expected credit losses over the life of its financial assets and certain off-balance sheet exposures as of the reporting date based on relevant information about past events, current conditions, and reasonable and supportable forecasts. The Company records the estimate of expected credit losses as an allowance for credit losses. For financial assets measured at an amortized cost basis the allowance for credit losses is reported as a valuation account on the balance sheet that adjusts the asset's amortized cost basis. Changes in the allowance for credit losses are reported in Credit Loss expense. Financial assets measured at amortized cost basis that are not eligible for the collateral maintenance practical expedient. For financial assets measured at amortized cost basis that are not eligible for the collateral maintenance practical expedient (and any unsecured amounts for instruments applying the practical expedient), the Company estimates expected credit losses over the life of the financial assets as of the reporting date based on relevant information about past events, current conditions, and reasonable and supportable forecasts. {10}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued) ### Accounts Receivable During the year, the Company recognized commissions for certain variable annuities, 401 (k) and 529 plans. The Company's management has not experienced issues collecting any of these commissions and believes the remainder is collectable, thus no allowance has been recorded. ### Deposits Held by Clearing Brokers Under the terms of the Clearing Agreement with National Financial Services, LLC ("NFS"}, the Company is required to maintain a certain level of cash on deposit with NFS which amounted to \$50,000 at December 31, 2022. Should NFS suffer a loss due to a failure of the Company's customer to complete a transaction, the Company is required to indemnify NFS to the extent of such loss. As of December 31, 2022, there were no amounts owed to the clearing broker nor did the company incur a loss during the year ended December 31, 2022 due to a customer's failure to complete a transaction. ### 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 revenues and expenses during the reporting period. Actual results could differ from those estimates. ### Income Taxes The Company is a single member limited liability company and reports on a consolidated basis with its parent company as a partnership for federal income tax purposes. The Company's taxable income or loss is therefore passed through to the parent company members and reported on their respective tax returns. Accordingly, no provision for federal income taxes has been recorded in these financial statements. The Company did not have unrecognized tax benefits as of December 31, 2022 and does not expect this to change significantly over the next twelve months. The Company recognizes interest and penalties accrued on any unrecognized tax benefits as a component of income tax expense in accordance with ASC 740-10-25. The Company files consolidated income tax returns with Keel Point Partners, LLC. As of December 31, 2022 the federal and state tax years subject to examination generally include all years from 2018 and beyond. As of December 31, 2022, the Company has not accrued interest or penalties related to uncertain tax positions. {11}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued) ### Fair Value of Financial Instruments The Company accounts for all financial assets and liabilities in accordance with ASC 820-10, "Fair Value Measurements." ASC 820-10 provides standards and disclosures for assets and liabilities that are measured and reported at fair value. As defined in ASC 820-10, 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 (exit price). ASC 820-10 requires disclosure that establishes a framework for measuring fair value and expands disclosure about fair value measurements. The statement requires fair value measurements be classified and disclosed in one of the following categories: Level 1: Unadjusted quoted prices in active markets that are accessible at the measurement date for identical, unrestricted assets or liabilities. An active market for the asset or liability is a market in which transactions for the asset or liability occur with sufficient frequency and volume to provide pricing information on an ongoing basis. Level 2: Measured based upon inputs that are observable, either directly or indirectly, for the asset or liability other than quoted market prices included in Level 1. These inputs include: a) quoted prices for similar asset or liabilities in active markets b) quoted prices for identical or similar assets or liabilities in markets that are not active c) inputs other than quoted market prices that are observable and d) inputs that are derived primarily from or corroborated by observable market data by correlation or other means. Level 3: Measured based on unobservable inputs for the asset or liability for which there is little, if any, market activity for the asset or liability at the measurement date. This input includes management's own assumptions about the assumptions that market participants would use in pricing the asset or liability. The inputs are developed based on the best information available in the circumstances, which might include management's own data. As required by ASC 820-10, financial assets and liabilities are classified based on the lowest level of input that is significant to the fair value measurement. The Company's assessment of the significance of a particular input to the fair value measurement requires judgment and may affect the valuation of the fair value of assets and liabilities and their placement within the fair value hierarchy levels. The Company has no assets or liabilities that are measured and reported at fair value as of December 31, 2022. Certain financial instruments that are not carried at fair value on the statement of financial condition are carried at amounts that approximate fair value due to their shortterm nature and generally negligible risk. These instruments include cash, {12}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### NOTE 2: RECOGNITION OF REVENUES Receivable from clearing broker, deposits with clearing broker, accounts payable and accrued expenses, and intercompany payable (all Level 1 ). ### Revenue Recognition Revenues are recognized when control of the promised services is transferred to customers, in an amount that reflects the consideration the Company expects to be entitled to in exchange for those services. Revenues are analyzed to determine whether the Company is the principal (i.e., reports revenues on a gross basis) or agent (i.e., reports revenues on a net basis) in the contract. Principal or agent designations depend primarily on the control an entity has over the product or service before control is transferred to a customer. The indicators of which party exercises control include primary responsibility over performance obligations, inventory risk before the good or service is transferred and discretion in establishing the price. ### Commission Revenue Commission revenue represents sales commissions generated by advisors for their clients' purchases and sales of securities on exchanges and over-the-counter, as well as purchases of other investment products. The Company views the selling, distribution and marketing, or any combination thereof, of investment products to such clients as a single performance obligation to the product sponsors. The Company is the principal for commission revenue, as it is responsible for the execution of the clients' purchases and sales and maintains relationships with the product sponsors. Advisors assist the Company in performing its obligations. Accordingly, total commission revenues are reported on a gross basis. The following table presents our total commission revenue disaggregated by investment product category: | | Twetve Months Ended
December 31, 2022 | | | |-------------------------------------|------------------------------------------|--|--| | Mutual Funds and Variable Annuities | 443,41}1} | | | | 401 (k) Plans | 25,902 | | | | Fixed in come | 19,628 | | | | Equities | 19,233 | | | | 529 Plans | 42,457 | | | | Total commiaaion revenue | s
550,620 | | | {13}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### NOTE 2: RECOGNITION OF REVENUES (Continued) The Company generates two types of commission revenue: sales-based commission revenue that is recognized at the point of sale on the trade date and trailing commission revenue that is recognized over time as the performance obligation is satisfied. Sales-based commission revenue varies by investment product and is based on a percentage of an investment product's current market value at the time of purchase. Trailing commission revenue is generally based on a percentage of the current market value of clients' investment holdings in trail-eligible assets, and is recognized over the period during which services, such as on-going support, are performed. As trailing commission revenue is based on the market value of clients' investment holdings, this variable consideration is constrained until the market value is determinable. ### NOTE 3: RELATED PARTY TRANSACTIONS The Company serves as a securities broker for an affiliated company, Keel Point, LLC, an investment advisor registered with the Securities and Exchange Commission. The Company relies on Keel Point, LLC's client relationships in order to generate substantially all of its business. The Company performs brokerage services at no charge for Keel Point, LLC's managed portfolios. The Company retains all fees and commissions for Keel Point, LLC's unmanaged securities portfolios and mutual funds. The Company shares office rent, salaries and certain other expenses with Keel Point, LLC. Such expenses are allocated on an historic ratio of revenues of each company. Total expenses allocated to the Company from Keel Point, LLC aggregated approximately \$258,125. Of the total allocated expenses, \$240,987 is related to shared salaries and benefits and the remaining \$17,138 is related to shared office expenses. As of December 31, 2022, the Company has an outstanding payable amount due to Keel Point, LLC in the amount of \$121,614. Additionally, the Company paid privilege taxes on behalf of Keel Point Partners during the year and has an outstanding receivable due from Keel Point Partners in the amount of \$8,300 as of December 31, 2022. ### NOTE 4: NET CAPITAL REQUIREMENTS The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC rule 15c3-1 }, which requires the maintenance of minimum net capital of \$50,000 and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31, 2022, the Company had net capital, as defined, of \$1,599,483, which was \$1,549,483 in excess of the required net capital of \$50,000. The Company's ratio of aggregate indebtedness was .09 to 1 at December 31, 2022. The Company is currently in compliance with these requirements. {14}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### NOTE 5: COMMITMENTS AND CONTINGENCIES The Company executes securities and futures transactions on behalf of its customers. If either the customer or the counterparty fails to perform, the Company may be required to discharge the obligation of the nonperforming party. In such circumstances, the Company may sustain a loss if the market value of the security or futures contract is different from the contract value of the transaction. The Company does not expect nonperformance by customers or counterparties. The Company clears all of its securities transactions through clearing brokers on a fully disclosed basis. Pursuant to the terms of the agreements between the Company and the clearing brokers, the clearing brokers have the right to charge the Company for losses that result from a counterparty's failure to fulfill its contractual obligations. As the right to charge the Company has no maximum amount and applies to all trades executed through the clearing broker, the Company believes there is no maximum amount assignable to this right. At December 31, 2022, the Company has no recorded liabilities with regard to the right. During 2022, the Company did not pay the clearing brokers any amounts related to these guarantees. The Company's policy is to monitor its market exposure, customer risk, and counterparty risk through the use of a variety of credit exposure reporting and control procedures, including marking-to-market securities and any related collateral as well as requiring adjustments of collateral levels as necessary. In addition, the Company has a policy of reviewing, as considered necessary, the credit standing of each counterparty and customer with which it conducts business. {15}------------------------------------------------ ## SUPPLEMENTAL INFORMATION {16}------------------------------------------------ COMPUTATION OF NET CAPITAL PURSUANTO SEC RULE 15c3-1 ### DECEMBER 31, **2022** | | Net capital computation: | |--|--------------------------| |--|--------------------------| | Member's equity | \$1,643,030 | |----------------------------------------------------------------|---------------| | Deduct:
Non-allowable assets | (42,910) | | Net capital before haircuts on marketable securities positions | 1,600,120 | | Other Haircuts | (637) | | Net Capital | \$1,599,483 | | Net capital required based on leverage: | | | Total liabilities -
aggregate indebtedness | 140,810
\$ | | Total capital required based on 6 2/3% of liabilities | \$
9.392 | Under its current agreement with the FINRA, KEEL POINT CAPITAL, LLC (the "Company") is required to maintain net capital of \$50,000. ### STATEMENT PURSUANTO PARAGRAPH (0)(4) OF RULE 17A-5 There was no material difference between the above computation of net capital pursuant to Rule 15c3-1 and the corresponding computation prepared by the Company and included in the Company's unaudited Part II A FOCUS report filing as of December 31, 2022. ### STATEMENT OF OMITTED SUPPLEMENTAL DATA The Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 and the Information Relating to Possession or Control Requirements Under Rule 15c3-3 have been omitted because Keel Point Capital, LLC is exempt from the requirements of Rule 15c3- 3 under condition (k)(2)(ii). {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) 100 Church Sincer, Suite 500 Huntsville, Alabama 35801 T 256.704.5111 F 256.704.5110 aver keelpairt com March 27, 2023 Keel Point Capital, LLC Exemption Report Keel Point Capital, LLC (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-5(d)(1) and (4). To the best of its Inowledge and belief, the Company states the following: (1) The Company daimed the exemption from 17 C.F.R. § 240.15c3-3 under the provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(il) during the year ended December 31, 2022. (2) The Company complied with the exemptive provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(1) during the period from January 1, 2022 to December 31, 2022, 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 effecting securities transactions va subscription way basis where the funds are payable to the Issuer or its agent and not to the Company, 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 prompliance in compliance with paragraph (a) or (b)(2) of Ruie 15c2-4); (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 without exception. Keel Point Capital, LLC I, Sandra Stephens, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. BV: Sandra Stephens CFO, Keel Point Capital, LLC Securities offered through KPC, Manter FLIARA & SIPC. Invastman Advisery Services offered by Rcc ( Polo), LLC an attaile of KPC; {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) Crowa LLP Indepercheri Mercer Liman Gildze #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We have reviewed management's statements, included in the accompanying Keel Point Capital, LLC Exemption Report for Keel Point Capital, LLC (the "Company"), in which: (1) 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) (the 'exemption provisions') and (2) the Company stated that the Company met the identified exemplion throughout the year ended Dacember 31, 2022, without exception. (3) The Company also identified the following identified conditions pursuant to Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 under which the Company is also eligible to file an Exemption Report because the Company's other business activities are limited to effecting securities transactions via subscription on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company, 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 promply transmilled in compliance with paragraph (a) or (b)(2) of Rule 15c2-4); 2) did not carry accounts of or for customers; and 3) did not carry PAB accounts (as defined in Rule 15c3-3) (the "identified conditions") throughout the mast recent fiscal vear ended December 31, 2022, without exception. The Company's management is responsible for compliance with the identified conditions and exemplian 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 modificallions that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the conditions set forth in paragraph (k)(2)(ii) of Rule 15c3-3 under the Securities Exchange Act of 1934, and the conditions set forth in Foolnate 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.178-5. Crowe LLP Naw York, New York March 29, 2023 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.