# RAPHAEL ARYEH X-17A-5 (2021-04-12) — Broker-dealer annual report - Company: RAPHAEL ARYEH - Form: X-17A-5 - Filed: 2021-04-12 - Period: 2020-12-31 - Accession: 0000789488-21-000002 - CIK: 789488 - File #: 8-35565 - Material weakness: Yes - Auditor: Ohab and Company PA - Auditor location: Maitland, FL - Contact: Raphael Aryeh - Phone: 7182634852 - Email: pam@ohabco.com - Website: ohabco.com - Signed by: Raphael Aryeh (General Partner) Original filing: https://www.sec.gov/Archives/edgar/data/789488/000078948821000002/x17a5report.pdf.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** QMB APPROVAL MB Number. 3235-0123 xpires: October 31 , 2023 stimated average burden hours er res onse ..... 12.00 # **ANNUAL AUDITED REPORi FORM X-17 A-5 PART Ill** | SEC FILE NUMBER | |-----------------| | | ## **FACING PAGE** **Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder** | REPORT FOR THE PERIOD BEGINING ___ | ___
J_A_N_U_A_R_Y_l,._2_0_20
MM/DD/YY | AND ENDING | DECEMBER 31, 2020
MM/DD/YY | |---------------------------------------------------------------------------|------------------------------------------------------------|--------------------------------|-------------------------------| | | A. REGISTRANT IDENTIFICATION | | | | NAME OF BROKER DEALER: | RAPHAEL ARYEH AND ASSOCIATES | | OFFICAL USE ONLY | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | FIRM ID. NO. | | | | 141-51 72ND CRESCENT | | | | | '
(No. and Street) | | | | FLUSHING | -
NY | | 11367 | | (City) | (State) | | (Zip Code) | | | B. ACCOUNTANT DESIGNATION | | | | | | | | | INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained in this Report* | | | | | | OHAB AND COMPANY, PA
(Name - if individual, state last, | | | | 100 E. SYBELIA A VENUE, SUITE 130, MAITLAND | | first, middle name)
FLORIDA | 32751 | | (Address and City) | | (State) | (Zip Code) | | CHECK ONE: | | | | | Iii Certified Public Accountant | | | | | D Public Accountant | | | | | | | | | | D Accountant not resident in United States or any of its possessions | | | | *\*Claims for exemption from the requirement that the annual audit be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See section 240. l 7a-5(e)(2).* > **Potential persons who are to respond to the collection of information contained in this form are required to respond unless the form displays a current valid 0MB control number.** **SEC 1410 (11-05)** {1}------------------------------------------------ # **OATH OR AFFIRMATION** | I, | RAPHAEL ARYEH | · | , swear (or affirm) that, to the | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------|----------------------------------------------------------------------------| | best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm or | RAPHAEL ARYEH AND ASSOCIATES | | , as of | | DECEMBER
nor any partner, proprietor, principal officer or director has any proprietary interest in any account classified solely as that of
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2020 | | are true and correct. I further swear (or affirm) that neither the company | | | | | | | r/-
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Title | | This report** contains (check all applicable boxes);
(a) Facing page.
181
~ (b) Statement of Financial Condition.
~ (c) Statement oflncome (Loss) or, ifthere is other comprehensive income in the period(s) presented, a Statement of Comprehensive | Income (as defined in §210. 1-02 of Regulation S-X). | | | | 181 ( d) Statement of Changes in Financial Condition.
~ (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietor's Capital.
D (t) Statement of changes in Liabilities Subordinated to Claims of Creditors.
~ (g) Computation of Net Capital.
181 (h) Computation for Determination of Reserve Requirements Pursuant to Rule l5c3-3.
~ (i) Information Relating to the Possession or control Requirements Under Rule 15c3-3.
D G) A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3-1 and the | Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | | | | D (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of con
solidation.
181 (I) An Oath or Affinnation.
D (m) A copy of the SIPC Supplemental Report.
D (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. | | | | \*\* *For conditions of confidential treatment of certain portions of this filing, see section 240. 17 a-5(e)(3).* {2}------------------------------------------------ Raphael Aryeh And Associates (A Partnership) Financial Statements December 31, 2020 3 {3}------------------------------------------------ #### **RAPHAEL ARYEH AND ASSOCIATES** #### **FINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2020** #### **TABLE OF CONTENTS** | Report of Independent Registered Public Accounting Firm | 1 | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----| | Financial Statements | | | Statement of Financial Condition | 2 | | Statement of Operations | 3 | | Statement of Changes in Partners' Equity | 4 | | Statement of Cash Flows | 5 | | Notes to Financial Statements | 6-8 | | Supplemental Information | | | Schedule I - Computation of Net Capital Pursuant to
SEC Rule 15c3-1 and Reconciliation of Net Capital
Pursuant to SEC Rule 17a-5(d)(4) | 9 | | Schedule II - Computation of Aggregate Indebtedness
Under Rule 1 ?a-5 of the Securities and Exchange Commission | 10 | | Computation for Determination of Reserve
Schedule Ill -
Requirements and Information Related to Possession and
Control Requirements Under Rule 15c3-3 of the Securities
and Exchange Commission | 11 | {4}------------------------------------------------ # **Raphael Aryeh And Associates Financial Statements Statement of Financial Condition As of and for the Year-Ended December 31, 2020** ## **ASSETS** | AsaJts: | | | |-------------------------------------------|----|---------| | Cash and cash equivalents | \$ | 380,460 | | Accounts receivable | | 59,969 | | Vehicle (net of accumulated depreciation) | | 8,632 | | | \$ | 449,061 | | LIABILITIES AND PARTNERS' EQUITY | | | | Liabilities: | | | | Accrued expenses | | 583 | | | | 583 | | Partners' equity: | | 448,478 | | | \$ | 449,061 | The accompanying notes are an integral part of these financial statements. {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) 100 E. Sybelia **Ave.** Suite 130 Maitland, FL 32751 *Certified Public Acco11nta11ts* Email: pam@ohabco.com Telephone 407-740-7311 Fax 407-740-6441 #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Partners' of Raphael Aryeh and Associates #### **Opinion on the Flnanclal Statements** We have audited the accompanying statement of financial condition of Raphael Aryeh and Associates as of December 31, 2020, the related statements of operations, changes in partners' equity, and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, In all material respects, the financial position of Raphael Aryeh and Associates as of December 31, 2020, and the results of its operations and Its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** These financial statements are the responsibility of Raphael Aryeh and Associates' management. Our responsibility is to express an opinion on Raphael Aryeh and Associates' 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 Raphael Aryeh and Associates in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### **Auditor's Report on Supplemental Information** The Schedules I, II and ill have been subjected to audit procedures performed in conjunction with the audit of Raphael Aryeh and Associates' financial statements. The supplemental Information is the responsibility of Raphael Aryeh and Associates' 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 Schedules I, II and Iii are fairly stated, In all material respects, in relation to the financial statements as a whole. ~*c,r-efl* ~ *,()/Y* We have served as Raphael Aryeh and Associates' auditor since 2015. Maitland, Florida April 6, 2021 {6}------------------------------------------------ ![](_page_6_Picture_0.jpeg) I 00 E. Sybelia **Ave.** Suite 130 Maitland, FL 3275 I *Certified Public Accountants* Email: pam@ohabco.com Telephone 407-740-7311 Fax 407-740-6441 ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Partners' of Raphael Aryeh and Associates ### **Opinion on the Ftnanctal Statement** We have audited the accompanying statement of financial condition of Raphael Aryeh and Associates as of December 31, 2020, and the related notes (collectively referred to as the ''financial statemenr). In our opinion, the financial statement presents fairly, in all material respects, the financial position of Raphael Aryeh and Associates as of December 31, 2020 in conformity with accounting principles generally accepted in the United States of America. ### **Basis for Opinion** This financial statement is the responsibility of Raphael Aryeh and Associates' management. Our responsibility is to express an opinion on Raphael Aryeh and Associates' financial statement 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 Raphael Aryeh and Associates 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 statement Is 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 statement, 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. We have served as Raphael Aryeh and Associates' auditor since 2018. Maitland, Florida April 6, 2021 {7}------------------------------------------------ # **Raphael Aryeh And Associates Financial Statements Statement of Operations** **As of and for the Year-Ended December 31, 2020** | Revenues: | | |------------------------------|--------------| | Advisory fees | 75,587
\$ | | Mutual Funds and 12B-1's | 23,819 | | Interest income | 406 | | Total revenues | 99,812 | | Expenses: | | | Pension | 10,000 | | Property taxes | 1,277 | | Regulatory fees and expenses | 1,468 | | Telephone and communications | 2,747 | | Other operating expenses | 29,358 | | Total expenses | 44,850 | | Net Income | 54,962
\$ | | | | The accompanying notes are an integral part of these financial statements. {8}------------------------------------------------ # **Raphael Aryeh And Associates Financial Statements Statement of Changes in Partners Equity As of and for the Year-Ended December 31, 2020** | | 2020
Partners'
Equity | |-------------------------------------|-----------------------------| | Balances, December 31, 2019 | 353,615 | | Prior period adjustment | 31,594 | | Net income
Partner contributions | 54,962
21,307 | | Partner distributions | (13,000) | | Balances, December 31 | \$ 448,478 | The accompanying notes are an integral part of these financial statements. {9}------------------------------------------------ # **Raphael Aryeh And Associates Financial Statements Statement of Cash Flows As of and for the Year-Ended December 31, 2020** | Cash flows from operating activities: | | |--------------------------------------------------|---------------| | Net income | \$
54,962 | | Adjustments to reconcile net income to net | | | cash flows from operating activities: | | | Depreciation | 5,755 | | (Increase) decrease in: | | | Accounts receivable | (6,982) | | Accrued expenses | (376) | | Net cash provided by operating activities | 53,359 | | Cash flows from financing activities: | | | Partner contributions | 21,307 | | Partner distributions | (13,000) | | Net cash provided by financing activities | 8,307 | | Net increase in cash | 61,666 | | Cash and cash equivalents at beginning of period | 318,794 | | Cash and cash equivalents at end of period | \$
380,460 | | Supplemental disclosure: | | |--------------------------|-------------| | Cash paid for interest | \$ -
O - | | Cash paid for taxes | o -
\$ - | The accompanying notes are an integral part of these financial statements. 5 I v {10}------------------------------------------------ # **Raphael Aryeh And Associates Notes to Financial Statements As of and for the Year-Ended December 31, 2020** ### *Note 1* - *Summary of Significant Accounting Policies* ### Nature of Business Raphael Aryeh & Associates (a partnership) ("the Company") is a broker-dealer, registered with the Securities Exchange Commission ("SEC"), and a member of the Financial Industry Regulatory Authority ("FINRA"). The Company was formed in the state of New York in 1978. The Company's business is limited to selling mutual funds on an application basis, selling variable life insurance or annuities and advisory fees. ### Cash and Cash Equivalents For purposes of reporting the statement of cash flows, the Company considers all cash accounts, which are not subject to withdrawal restrictions or penalties, and all highly liquid debt instruments purchased with a maturity of three months or less to be cash equivalents. Cash balances in excess of FDIC and similar insurance coverage are subject to the usual banking risks associated with funds in excess of those limits. Accounts at each institution are insured by the Federal Deposit Insurance Corporation ("FDIC") up to \$250,000. At December 31, 2020, the Company had \$112,257 in excess of the FDIC insured limit. ### Revenue and Cost Recognition Commissions from the sale of mutual funds and variable annuities and 12b-1's are recognized as revenue at the point in time the associated service is fulfilled which is based on the trade date. ### Investment Advisory Fees The company provides advisory services on a daily basis. The Company believes the performance obligation for providing advisory services is satisfied over time because the customer is receiving and consuming the benefits as they are provided by the Company. Fee arrangements are based on a percentage applied to the customer's assets under management. Fees are received annually and are recognized as revenue at that time as they relate specifically to the services provided in that period, which are distinct from the services provided in other periods. ### Estimates The preparation of financial statements in accordance with accounting principles generally accepted in the United States of America 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 revenues and expenses during ·the reporting period. Actual results could differ from those estimates. ## Property and Equipment Property and equipment are recorded at cost. Repair and maintenance costs are charged to operations as incurred. When assets are retired or disposed of, the cost and accumulated depreciation are removed from the accounts, and any gains or losses are included in operations. Depreciation of property and 611 {11}------------------------------------------------ # **Raphael Aryeh And Associates Notes to Financial Statements As of and for the Year-Ended December 31, 2020** # *Note 1* - *Summary of Significant Accounting Policies* - *continued* equipment is provided utilizing the straight line method over the estimated useful lives of the related assets. ### Income Taxes The Company files its income tax returns as a partnership for federal and state income tax purposes. As such, the Company does not pay income taxes, as any income or loss is included in the income tax returns of the individual partners. Accordingly, no provision is made for income taxes in the financial statements. As defined by Financial Accounting Standards Board Accounting Standards Codification (ASC) Topic 740, Income Taxes, no provision or liability for materially uncertain tax positions was deemed necessary by management. Therefore, no provision or liability for uncertain tax positions has been included in these financial statements. Since tax matters are subject to some degree of uncertainty, there can be no assurance that the Company's tax returns will not be challenged by the taxing authorities and that the Company or its partners will not be subject to additional tax, penalties, and interest as a result of such challenge. Generally, the Company's tax returns remain open for three years for federal and state income tax examination. As such, the Company's income tax returns for the years ended December 31, 2017, 2018 and 2019 respectively, are subject to possible federal and state examinations, generally three years after they are filed. ### Financial Instruments All of the Company's financial assets and liabilities are carried at market value or at amounts, which, because of their short-term nature, approximate current fair value. ### Business Concentrations The Company earned revenue for investment advisory fees from four major customers that accounted for 80% of revenue for the year. Financial instruments that potentially subject the Company to concentration of credit risk consist principally of cash deposits. {12}------------------------------------------------ # **Raphael Aryeh And Associates Notes to Financial Statements As of and for the Year-Ended December 31, 2020** ### **Note Z** - **Prior Period Adjustment** An adjustment of \$31,594 was made to the prior period to correct the under statement of commission revenues earned and accounts receivable. ### **Note 3** - **Net Capital Requirements** The Company is subject to the Securities and Exchange Commission's Uniform Net Capital Rule (Rulel5c3-1), which requires the maintenance of minimum net capital at an amount equal to the greater of \$5,000 or 6 2/3% of aggregate indebtedness, and requires that the ratio of aggregate indebtedness to net capital not to exceed 15 to 1. At December 31, 2020, the Company had excess net capital of \$374,877 and a net capital rate of .0016 to 1. ### **Note 4** - **Property and Equipment** ### **Property and equipment consists of:** Vehicle | Total Vehicle at Cost | \$28,773 | | |--------------------------------|----------|--| | Less: Accumulated depreciation | (20,141) | | | Vehicle, net | \$ 8,632 | | Depreciation expense was \$5,755 for the year ended December 31, 2020. ### **Note 5** - **Related Party** The Company had transactions with its general partner throughout the year. These transactions included payments of bills by the general partner from his personal accounts treated as contributions of capital, and charges for utilities, vehicle and other expenses that amounted to \$21,306 for the year ended December 31, 2020. ## **Note 6** - **Commitments and contingencies** Raphael Aryeh & Associates does not have any commitments, guarantees, or contingencies, including arbitration or other litigation claims that may result in a loss or a future obligation. The Company is not aware of any threats or other circumstances that may lead to the assertion of a claim at a future date. ### **Note 7** - **Subsequent Events** In preparing these financial statements, management of the Company has evaluated events and transactions through the date the financial statements were available to be issued. The Company has determined that no events and transactions occurred that require disclosure. 8 11 {13}------------------------------------------------ # **Schedule** I # **Raphael Aryeh And Associates Supplementary Schedules Pursuant to SEA Rule 17a-5 Of the Securities and Exchange Act of 1934 As of and for the Year-Ended December 31, 2020** ## **Computation of Net Capital Computation of Net Capital Requirement** | Computation of basic net capital requirements: | | |-------------------------------------------------------------|---------------| | Total member's equity qualified for net capital | 448,478
\$ | | Deductions: | | | Non-allowable assets | | | Accounts receivable | 59,969 | | Vehicle (net of accumulated depreciation) | 8,632 | | Total non-allowable assets | | | Net capital before haircuts and securities positions | 379,877 | | Haircuts: | | | | | | | | | Net capital | 379,877 | | Minimum net capital requirements: | | | 6 2/3% of total aggregate indebtedness (\$958) | | | Minimum dollar net capital for this broker-dealer (\$5,000) | | | Net capital requirement (greater of abow two requirements) | \$
5,000 | | Excess net capital | \$
374,877 | ### **Computation of Reconciliation of Net Capital** There were no material differences existing between the above computations included in the Company's corresponding unaudited Form X-17A-5 Part IIA filing as of December 31, 2020. Accordingly, no reconciliation is necessary. {14}------------------------------------------------ # **Schedule** 11 # **Raphael Aryeh And Associates Computation of Aggregate Indebtedness Under Rule 17a-5 Of the Securities and Exchange Act of 1934 As of and for the Year-Ended December 31, 2020** ## **Computation of Aggregate Indebtedness** | Total aggregate indebtedness | | |-------------------------------------------|-----------| | Accrued expenses | \$
583 | | Aggregate indebtedness | \$
583 | | Percentage of indebtedness to net capital | 0.16% | {15}------------------------------------------------ # **SCHEDULE** III # **RAPHAEL ARYEH** & **ASSOCIATES** **COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS AND INFORMATION RELATED TO POSSESSION AND CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AT DECEMBER 31, 2020** The Company is not claiming an exemption from SEA Rule 15c3-3, in reliance on footnote 74 to SEC Release 34-70073 and as discussed in Q&A 8 of the related FAQ issued by SEC staff. In order to avail itself of this option, the Company has represented that it does not, and will not, hold customer funds or securities. 11 I~ {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) 100 E. Sybelia Ave. Suite 130 Maitland, FL 32751 *Certified Public Accountants* Email: pam@ohabco.com Telephone407-740-731 I Fax 407-740-6441 ### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors and Partners' of Raphael Aryeh and Associates We have reviewed management's statements, included in the accompanying Exemption Report, In which {1) Raphael Aryeh and Associates Identified that It does not claim an exemption under the exemption provisions of SEA Rule 15c3-3, but is exempt in reliance on footnote 74 to SEC Release 34-70073, dated July 30, 2013, and as discussed in **Q&A #8** of the related FAQ issued by SEC staff on April 4, 2014 {the "Identified Exemption") and (2) Raphael Aryeh and Associates stated that Raphael Aryeh and Associates met the identified exemption provisions throughout period January 1, 2020 through December 31, 2020 without exception. Raphael Aryeh and Associates's management is responsible for compliance with the exemption 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 Raphael Aryeh and Associates's compliance with the exemption. 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 Identified Exemption from Rule 15c3-3 under the Securities Exchange Act of 1934 identified above. ~~ Maitland, Florida April 6, 2021 l7 {17}------------------------------------------------ *?2apleaet ~e11elt and ~.uDciate,* **INDEPENDENT FINANCIAL SERVICES 141-51 72ND CRESCENT FLUSHING, NEW YORK 11367 (718) 263-4852 MEMBER: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. SECURITl~S INVESTOR PROTECTION CORP. (SIPC)** ~arch 30, 2021 Ohab and Company, P.A. 100 Sybellia A venue, Suite 130 Maitland, FL 32751 Re: Raphael Aryeh & Associates Exemption Report Raphael Aryeh & Associates (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.l 7a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.l 7a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to (include all that apply, for example,): (1) mutual fund services; (2) variable annuities and (3) investment advisory services, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, ( other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. I, Rapahel Aryeh, affirm that, to my best knowledge and belief, this Exemption Report is true and correct. Regards, t~Pr~ RAPHAEL ARYEI-r GENERAL PARTNER RAPHAEL ARYEH AND ASSOCIATES Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.