# KEEL POINT CAPITAL, LLC X-17A-5 (2025-04-01) — Broker-dealer annual report - Company: KEEL POINT CAPITAL, LLC - Form: X-17A-5 - Filed: 2025-04-01 - Period: 2024-12-31 - Accession: 0000276721-25-000001 - CIK: 276721 - File #: 8-22990 - Type: Broker-dealer - Material weakness: No - Auditor: Crowe LLP - Auditor location: New York, NY - Contact: Michael Bates - Phone: 256-704-5111 - Email: mbates@keelpoint.com - Website: keelpoint.com - Signed by: Robert C. Mayes (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/276721/000027672125000001/KPCAudit24.pdf --- {0}------------------------------------------------ ## FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION DECEMBER 31, 2024 {1}------------------------------------------------ ### **CONTENTS** | PAGE
NUMBER | | |----------------------------------------------------------------------------------------------------------|--| | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
3 | | | FINANCIAL
STATEMENTS | | | 4
STATEMENT OF FINANCIAL CONDITION | | | STATEMENT OF INCOME···································

5 | | | STATEMENT OF CHANGES IN MEMBER'S EQUITY
6 | | | STATEMENT OF CASH FLOWS
7 | | | NOTES TO FINANCIAL STATEMENTS
8-14 | | | SUPPLEMENTAL
INFORMATION | | | COMPUTATION OF NET CAPITAL PURSUANT TO SEC RULE 15c3-1

15 | | | COMPUTATION
FOR DETERMINATION OF THE RESERVE
REQUIREMENTS
PURSUANT TO SEC RULE 15c3-3

16 | | | INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS
UNDER RULE 15c3-3

17 | | | KEEL POINT CAPITAL, LLC EXEMPTION REPORT
18 | | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
19 | | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
ON APPLYING AGREED-UPON PROCEDURES
20-21 | | | GENERAL ASSESSMENT RECONCILIATION (FORM SIPC-7)

22-23 | | {2}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** ### **ANNUAL REPORTS FORM X-17A-5 PART** Ill | 0MB APPFlOVAL | | |---------------------------|--| | 0MB Number: 3235-0123 | | | Expires: Nov 30, 2026 | | | Estimate □ average burden | | | 12
hours per response: | | | | | SEC FILE NUMBER 8-22990 #### **FACING PAGE** **Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities E,cchange Act of 1934** FILING FOR THE PERIOD BEGINNING 01 /01 l 24AND ENDING 12131124 ---------- ----------- MM/DD/VY MM/DD/VY **A. REGISTRANT IDENTIFICATION** NAME OF FIRM: Keel Point Capital, LLC TYPE OF REGISTRANT (check all applicable boxes): ■ Broker-dealer □ Security-based swap dealer □ Major security-based swap participant D 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 S.W. Suite 500 (No. and Street) Huntsville AL (City) (State) PERSON TO CONTACT WITH REGARD TO THIS FILING 35801 (Zip Code) Michael Bates 256-704-5111 mbates@keelpoint.com (Name) (Area Code - Telephone Number) (Email Address) **B. ACCOUNTANT IDENTIFICATION** INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\* Crowe LLP (Name - if individual, state last, first, and middle name) 485 Lexington Ave, Floor 11 New York **NY** (Address) (City) (State) 09/24/2003 173 10017 (Zip Code) lte **of Regl>tcatlo, with PCAOBl{lf applicable) FOR OFFICIAL USE ONLY (PCAOB Reglst,atloo N"mbec,** If **applicable)** I \* 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 240.17a-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.** {3}------------------------------------------------ #### **OATH OR AFFIRMATION** | I, Robert C. Mayes | . swear (or affirm) that, to the best of my knowledge and belief, the | |-----------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------| | to the firm of Keel Point Capital, LLC
financial report pertaining | . as of | | December 31
2024 | , is true and correct. I further swear (or affirm) that neither the company nor any | | | 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. | ,,,,,11111,,,, | | | .,,, \jHHB1 '1,
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"; -,,,,, J •• •• ,\.'ii , | | ,, | 'Art l1\'",,'' | | | ,,,,,,,"'''' | #### **This filing\*\* contains (check all applicable boxes):** - (a) Statement of financial condition. - D (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 S-X). - (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 consolidated financial statements. - (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-l, as applicable. - D (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. - D (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. - □ (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - D (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - D (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-l, 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. - 0 (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 240.18a-7, as applicable. - D (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. - D (t) Independent public accountant's report based on an examination of the statement of financial condition. - D (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. - D (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. - D (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. - D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable. - D (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). - D (z) Other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_ \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e}(3) or 17 CFR 240.18a-7(d)(l}, as applicable. {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Member of Keel Point 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, 2024, the related statements of income, changes in member's equity, and cash flows for the year ended December 31, 2024, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2024, and the results of its operations and its cash flows for the year ended December 31, 2024, in conformity 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 (United States) ("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 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. #### **Supplemental Information** The Schedule I Computation of Net Capital Pursuant to SEC Rule 15c3-1, Schedule II Computation for Determination of the Reserve Requirements Pursuant to Rule 15c3-3, and Schedule Ill Information Relating to the Possession or Control Requirements Under Rule 15c3-3 (the "Supplemental Information") has been subjected to audit procedures performed in conjunction with the audit of 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. & du/(\_ ~ Crowe LLP We have served as the Company's auditor since 2022. New York, New York March 31, 2025 {5}------------------------------------------------ #### ST A TEMENT OF FINANCIAL CONDITION #### DECEMBER 31 202 #### ASSETS | Assets | | |---------------------------------|-----------------| | Cash | \$
2,299,192 | | Receivable from clearing broker | 208,677 | | Accounts receivable | 59,545 | | Deposits with clearing broker | 50,000 | | Other assets | 63,476 | | TOTAL ASSETS | \$
2,680,890 | #### LIABILITIES AND MEMBER'S EQUITY | liabilities | | |----------------------------------------|-----------------| | Accounts payable and accrued expenses | \$
34,145 | | lntercompany payable | 586,276 | | Total liabilities | 620,421 | | Member's Equity | 2,060,469 | | TOT AL LIABILITIES AND MEMBER'S EQUITY | \$
2,680,890 | {6}------------------------------------------------ #### **STATEMENT OF INCOME** #### FOR THE YEAR ENDED DECEMBER 31. 2024 | Revenues | | |-------------------------------------|---------------| | Commission income | 575,417 | | Dividends and interest | 40,465 | | Platform Fees | 105,938 | | Total revenues | 721,820 | | Expenses | | | Salaries and employee benefits | 207,708 | | Office and other operating expenses | 262122 | | Total operating expenses | 469.830 | | Net Income | \$
251.990 | {7}------------------------------------------------ ## KEEL POINT CAPITAL. LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31 2024 | | Member's
Equity | | |--------------------------------|--------------------|-----------| | Balance. beginning of the year | \$ | 1,808,479 | | Net Income | | 251,990 | | Balance, end of year | \$ | 2,060,469 | {8}------------------------------------------------ #### STATEMENT OF CASH FLOWS #### FOR THE YEAR ENDED DECEMBER 31. 2024 #### **CASH FLOWS FROM OPERA TING ACTIVITIES** | Net Income | \$
251,990 | |-------------------------------------------------------------------------------------------------------------------------------------|--------------------------------| | Adjustments to reconcile net income to net
cash used in operating activities: | | | (Increase) decrease in cash related to changes in assets:
Receivable from clearing broker
Accounts receivable
Other assets | (166,712)
4,806
(12,434) | | Increase in cash related to changes in liabilities:
lntercompany payable
Accounts payable and accrued expenses | 410,347
11,595 | | NET CASH PROVIDED BY OPERATING ACTIVITIES | 499,592 | | NET INCREASE IN CASH AND CASH EQUIVALENTS | 499,592 | | CASH AND CASH EQUIVALENTS, BEGINNING OF YEAR | 1,799,600 | | CASH AND CASH EQUIVALENTS, END OF YEAR | \$
2,299,192 | {9}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS #### DECEMBER 31, 2024 ### 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 earned 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, 2024. 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, 2024, there were no amounts owed to the clearing broker nor did the company incur a loss during the year ended December 31, 2024 due to a customer's failure to complete a transaction. #### Receivables from Clearing Broker The Company's receivables from clearing broker include amounts receivable from settled transactions and accrued interest receivable. The Company's trades and contracts are cleared through a clearing broker and settled daily between the clearing broker and the Company. Because of this daily settlement, the amount of unsettled credit exposures is limited to the amount owed the Company for a very short period of time. The Company continually reviews the credit quality of its counterparties. Overnight receivable balances from the clearing broker are swept into money market funds to earn interest. #### 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, 2024 and does not expect this to change significantly over the next twelve {11}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued) months. The Company recognizes interest and penalties accrued on any unrecognized tax benefits as a component of income tax expense in accordance with ASC 7 40-10-25. The Company files consolidated income tax returns with Keel Point Partners, LLC. As of December 31, 2024 the federal and state tax years subject to examination generally include all years from 2020 and beyond. As of December 31, 2024, the Company has not accrued interest or penalties related to uncertain tax positions. ### 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 {12}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS ### NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued) 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, 2024. 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 short-term nature and generally negligible risk. These instruments include cash, receivable from clearing broker, deposits with clearing broker, accounts payable and accrued expenses, and intercompany payable (all Level 1 ). #### Segment Reporting The Company is engaged in a single line of business as a securities-broker dealer. The Company has identified its President as the chief operating decision maker (CODM), who uses net income to evaluate the results of the business, predominantly in the forecasting process, to manage the Company. Additionally, the CODM uses excess net capital, which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to reinvest profits or pay dividends. The Company's operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies. The significant expenses of the segment are reported on the accompanying statement of income of this report. #### NOTE 2: RECOGNITION OF REVENUES #### 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 revenues consist of brokerage commissions and distribution fees. The Company buys and sells securities on behalf of its customers. Each time a customer enters into a buy or sell transaction, the Company charges a commission. Commissions and related clearing expenses are recorded on {13}------------------------------------------------ #### NOTES TO FINANCIAL STATEMENTS ### NOTE 2: RECOGNITION OF REVENUES (Continued) the trade date (the date that the Company fills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). The Company believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified, the pricing is agreed upon and the risks and rewards of ownership of the securities have been transferred to/from the customer. Distribution fees. The Company enters into arrangements with managed accounts or other pooled investment vehicles (funds) to distribute shares to investors. The Company may receive distribution fees paid by the fund up front, over time, upon the investor's exit from the fund (that is, a contingent deferred sales charge), or as a combination thereof. The Company believes that its performance obligation is the sale of securities to investors and as such this is fulfilled on the trade date. Any fixed amounts are recognized on the trade date and variable amounts are recognized to the extent it is probable that a significant revenue reversal will not occur once the uncertainty is resolved. For variable amounts, as the uncertainty is dependent on the value of the shares at future points in time as well as the length of time the investor remains in the fund, both of which are highly susceptible to factors outside the Company's influence, the Company does not believe that it can overcome this constraint until the market value of the fund and the investor activities are known, which are usually monthly or quarterly. Distribution fees recognized in the current period are primarily related to performance obligations that have been satisfied in prior periods. 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: **Twelve Months Ended** | | December 31, 2024 | | |-------------------------------------|-------------------|---------| | Mutual Funds and Variable Annurties | \$ | 438,592 | | 401 (k) Plans | | 33,574 | | Fixed income | | 13,986 | | Equities | | 42,228 | | 529 Plans | | 47,037 | | Total commission revenue | s | 575,417 | {14}------------------------------------------------ ### NOTES TO FINANCIAL STATEMENTS ### NOTE 2: RECOGNITION OF REVENUES (Continued) ### Platform Fees The Company earns platform fees from independent contractors that are registered representatives on the Company's registered broker/dealer. Platform fees earned from these representatives represent a percentage of the monthly commissions earned by the representative, as well as monthly fees per registered advisor on the Company's platform. Platform fees are presented net of total revenue and the commissions paid to the representatives. The total net revenue earned by the company in platform fees totaled \$105,807 during 2024. ### 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 \$226,745. Of the total allocated expenses, \$210,972 is related to shared salaries and benefits and the remaining \$15,773 is related to shared office expenses. As of December 31, 2024, the Company has unsecured advances due to Keel Point, LLC in the amount of \$586,276. 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, 2024. ### 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 (including subordinated indebtedness) and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At December 31, 2023, the Company had net capital, as defined, of \$1,887,448, which was \$1,837,448 in excess of the required net capital of \$50,000. The Company's ratio of aggregate indebtedness was .34 to 1 at December 31, 2024. The Company is currently in compliance with these requirements. {15}------------------------------------------------ #### 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, 2024, the Company has no recorded liabilities with regard to the right. During 2024, 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. In the normal course of business, the Company is or may be subject to regulatory proceedings, including examinations, arising in connection with the conduct of its operations. These matters could result in censures, fines, or other sanctions. {16}------------------------------------------------ ## SUPPLEMENTAL INFORMATION {17}------------------------------------------------ | KEEL POINT CAPITAL, LLC
SCHEDULE I | | |------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------| | COMPUTATION OF NET CAPITAL
PURSUANTO SEC RULE 15c3-1 | | | DECEMBER 31, 2024 | | | Net capital computation: | | | Member's equity | \$2,060,469 | | Deduct:
Accounts Receivable
Deposits with Clearing Broker
Other Assets
Total non allowable assets
Net Capital | (59,545)
(50,000)
(63,476)
(173,021)
\$1,887,448 | | Net capital required based on leverage: | | | Total liabilities -
aggregate indebtedness | 620 421 | | Total capital required based on 6 2/3% of liabilities | \$
41.361 | | FINRA required Net Capital | \$
50,000 | | Excess Net Capital | 1 837 448 | ### 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 amended, unaudited Part II A FOCUS report filing as of December 31, 2024. {18}------------------------------------------------ ### SCHEDULE II COMPUTATION FOR DETERMINATION OF THE RESERVE REQUIREMENTS PURSUANT TO RULE 15c3-3 DECEMBER 31 , **2024** The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934 under Paragraph (k)(2)(ii), in addition the Company has additional activities that are not subject to Rule 15c3-3, as those activities are limited to those set forth in the conditions for exemption appearing in and as a non-covered firm because its business activities are limited to Investment banking. {19}------------------------------------------------ ### SCHEDULE 111 INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 DECEMBER **31, 2024** The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934 under Paragraph (k)(2)(ii), in addition the Company has additional activities that are not subject to Rule 15c3-3, as those activities are limited to those set forth in the conditions for exemption appearing in and as a non-covered firm because its business activities are limited to Investment banking. {20}------------------------------------------------ ![](_page_20_Picture_0.jpeg) 100 Orurch 5tre:, SUite !iOO ~nm,ille,. Alabama 35901 T 256.JOt,5111 F 256, 704,5110 \_,...,.,,~ Mardi 27, 2025 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 Exd,ange Commission (17 C.F.R. § 24O,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 bmwlerlqe and belief, the Company stat.es the followw,g: (1) The Comp.iny claimed the exemption from 17 C,F,R. § 240,15c3-3 under the provisions of 17 C.F,R. § 24O.1Sc3-3 (k)(2){ii) during the year ended December 31, 2024, (2) The Company complied with the exemptive provisions of 17 C.F.R. § 240,15c3-3 (k)(2)(i) during the period horn January 1, 211H to December 31, 2024, without exception. (3) The Company is also filng this Exemption Report because the Company's other business ac:tivit:ies conh!mplated by Footnote 74 ol the SEC Release No, 34-70073 adopting amendments to 17 C.F.R. § 240,17a-5 are ~mit:ed to effecting securities transactions via subscriptions on a subscriptioo way basis where the funds are payable to the issuer or its agent and not to the Company, and the Company (1) did not directfy or indirectly receive, hold, or othl!IWise owe funds or securities for or to customers, (other than funds received and promptly bansmitted 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) cid not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year ended December 31, 2024 without exception, Keel Point Capital, LLC I, Robert Mayes, swear (or affirm) that;. to my best knowiedge and belief, tf1is Exemption Report is true and correct. {21}------------------------------------------------ ![](_page_21_Picture_1.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We have reviewed management's statements, included in the accompanying Keel Point Capital, LLC Exemption Report in which: (1) Keel Point Capital, LLC (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 exemption provisions throughout the year ended December 31, 2024, 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 sub\$criptions 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 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) (the "identified conditions") throughout the most recent fiscal year ended December 31, 2024, without exception. The Company's management is responsible for compliance with the identified conditions and 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 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 Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5. Gtttwt.l/,/1 Crowe LLP New York, New York March 31, 2025 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.