# COLUMBIA MANAGEMENT INVESTMENT DISTRIBUTORS, INC. X-17A-5 (2022-02-25) — Broker-dealer annual report

- Company: COLUMBIA MANAGEMENT INVESTMENT DISTRIBUTORS, INC.
- Form: X-17A-5
- Filed: 2022-02-25
- Period: 2021-12-31
- Accession: 0000862988-22-000001
- CIK: 351106
- File #: 8-25845
- Type: Broker-dealer
- Material weakness: No
- Auditor: Pricewaterhouse Coopers LLP
- Auditor location: Chicago, IL
- Contact: Michael S. Mattox
- Phone: 612-678-0262
- Signed by: Michael S. Mattox (Chief Financial Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/351106/000086298822000001/cmidsrt.pdf

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## S TATEMENT O F FINANCIAL CONDITION

Columbia Management Investment Distributors, Inc. SEC File Number: 8-25845 December 31, 2021 With Report of Independent Registered Public Accounting Firm

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UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

> ANNUAL REPORTS FORM X-17A-5 PART III

OMB APPROVAL OMB Number: 3235-0123 Expires: Oct. 31, 2023 Estimated average burden hours per response: 12

SEC FILE NUMBER

8-25845

FACING PAGE

Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934

AND ENDING 12/31/2021 FILING FOR THE PERIOD BEGINNING 01/01/2021 MM/DD/YY MM/DD/YY A. REGISTRANT IDENTIFICATION NAME OF FIRM: Columbia Management Investment Distributors, Inc TYPE OF REGISTRANT (check all applicable boxes): [ Security-based swap dealer \_ \_ Major security-based swap participant Z Broker-dealer O Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) 225 Franklin Street (No. and Street) Boston MA 02110-2804 (City) (State) (Zip Code) PERSON TO CONTACT WITH REGARD TO THIS FILING michael.s.mattox @ampf.com Michael Mattox 612-678-0262 (Email Address) (Name) (Area Code - Telephone Number) B. ACCOUNTANT IDENTIFICATION INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing\* PricewaterhouseCoopers, LLP (Name - if individual, state last, first, and middle name) One North Wacker Dr. Chicago IL 60606 (Address) (City) (State) (Zip Code) 10/20/2003 238 (Date of Registration with PCAOB)(if applicable) (PCAOB Registration Number, if applicable) FOR OFFICIAL USE ONLY \* Claims for exemption from the requirement that the annual 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-5(e)(1)(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 OMB control number.

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#### OATH OR AFFIRMATION

1. Michael S. Mattox

, swear (or affirm) that, to the best of my knowledge and belief, the

financial report pertaining to the firm of Columbia Management Investment Distributors, Inc. as of as a manager as as of December 31 2 021 , 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.

![](_page_2_Picture_5.jpeg)

| Signature:           |  |
|----------------------|--|
| Title:               |  |
| ALL FELL ARE LED FOR |  |

Chief Financial Officer

Notary Public

#### This filing\*\* contains (check all applicable boxes):

- Z (a) Statement of financial condition.
- Z (b) Notes to consolidated statement of financial condition.
- [c] Statement of income (loss) or, if there is other comprehensive 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-1, as applicable.
- [ (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- [] (i) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- [ {k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- [ (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- [ (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 het capible 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.
- 2 (q) Oath or affirmation in accordance with 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- [ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- [ (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- 7 (t) Independent public accountant's report based on an examination of the statement of financial condition.
- [ {u] Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- □ (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- [ (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- | (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.17a-12, as applicable.
- □ (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).
- [ (z) Other:
- \*\* To request confidential treatment of certain portions of this filing, see 17 CFR 240.170-5(c)(2), as applicable.

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## Columbia Management Investment Distributors, Inc. Statement of Financial Condition December 31, 2021

## **Contents**

| Report of Independent Registered Public Accounting Firm 1                |  |
|--------------------------------------------------------------------------|--|
| Statement of Financial Condition 2                                       |  |
| Notes to Statement of Financial Condition…………………………………………………………………………….3 |  |

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![](_page_4_Picture_0.jpeg)

## **Report of Independent Registered Public Accounting Firm**

To the Board of Directors and Shareholder of Columbia Management Investment Distributors, Inc.

### *Opinion on the Financial Statement – Statement of Financial Condition*

We have audited the accompanying Statement of Financial Condition of Columbia Management Investment Distributors, Inc. (the "Company") as of December 31, 2021, including the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2021 in conformity with accounting principles generally accepted in the United States of America.

### *Basis for Opinion*

The financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's 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 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 of this financial statement 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 statement. 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 statement. We believe that our audit provides a reasonable basis for our opinion.

February 25, 2022

We have served as the Company's auditor since 2010.

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# Columbia Management Investment Distributors, Inc. Statement of Financial Condition December 31, 2021

(in thousands except share amounts)

| Assets                                                        |              |
|---------------------------------------------------------------|--------------|
| Cash and cash equivalents                                     | \$<br>83,936 |
| Receivables:                                                  |              |
| Distribution fees from associated mutual funds                | 1,231        |
| Due from affiliates                                           | 1,606        |
| Other                                                         | 1,579        |
| Deferred acquisition costs                                    | 4,748        |
| Intangible assets, net of accumulated amortization of \$1,756 | 244          |
| Total assets                                                  | \$<br>93,344 |
| Liabilities and Stockholder's Equity                          |              |
| Liabilities:                                                  |              |
| Payables:                                                     |              |
| Due to affiliates                                             | \$<br>45,351 |
| Distribution fees to outside distributors                     | 22,749       |
| Other                                                         | 1,800        |
| Deferred income taxes, net                                    | 1,203        |
| Total liabilities                                             | 71,103       |
| Commitments and contingencies (see note 8)                    |              |
| Stockholder's equity:                                         |              |
| Common stock \$1 par value per share:                         |              |
| Authorized, issued and outstanding shares - 250               | —            |
| Additional paid - in capital                                  | 23,083       |
| Accumulated deficit                                           | (842)        |
| Total stockholder's equity                                    | 22,241       |
| Total liabilities and stockholder's equity                    | \$<br>93,344 |

*The accompanying notes are an integral part of the Statement of Financial Condition.* 

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### **1. Organizationand Significant Accounting Policies**

### **Organization**

Columbia Management Investment Distributors, Inc. (the Company) is incorporated under the laws of the state of Delaware. The Company is a wholly owned subsidiary of J. & W. Seligman & Co, Inc., which is a wholly owned subsidiary of Columbia Management Investment Advisers, LLC, (CMIA), which is a wholly owned subsidiary of Ameriprise Financial, Inc. (the Parent). The Company is a limited purpose broker-dealer registered with the Securities and Exchange Commission (SEC) and the various states in which the Company conducts business and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA) and the Securities Investor Protection Corporation (SIPC).

The Company provides underwriting and distribution services for financial productswhich consist of both retail funds and variable product funds, open-end investment companies and 529 plans managed by affiliated companies. The Company's distribution services are performed pursuant to distribution agreements under which the Company, where applicable, retains distribution concessions, net of commissions paid to dealers for distribution of the investment companies' shares. The Company serves as the distributor of the combined Columbia complex of open-end investment companies and 529 plans, which includes funds known collectively as the Columbia Funds (the Funds), and serves as a placement agent or distributor of exchange traded funds (ETFs) andprivate and foreign funds managed by CMIA. The Company also provides certain marketing, distribution and sales support services for the Columbia Trust collective funds, which are sub-advised by CMIA.

### **Basis of Financial Statement Presentation**

The preparation of the financial statements in conformity with accounting principles generally accepted in the United States (U.S. GAAP) requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities. These accounting estimates reflect the best judgment of management and actualamounts could differsignificantly from those estimates.

## **Significant Accounting Policies**

*Income taxes:* The Company's provision for income taxes represents the net amount of income taxes that the Company expects to pay or to receive from various taxing jurisdictions in connection with its operations. The Company provides for income taxes based on amounts that the Company believes it will ultimately owe taking into account the recognition and measurement for uncertain tax positions. Inherent in the provision for income taxes are estimates and judgments regarding the tax treatment of certain items. The Company's taxable income is included in the consolidated federal and state income tax returns of the Parent. The Company provides for income taxes on a separate return basis, except that, under an agreement between the Parent and the Company, tax benefits are recognized for losses to the extent they can be used in the consolidated return. It is the policy of the Parent to reimburse its subsidiaries for any tax benefits recorded.

In connection with the provision for income taxes, the financial statements reflect certain amounts related to deferred tax assets and liabilities, which result from temporary differences between the assets and liabilities measured for financial statement purposes versus the assets and liabilities measured for tax return purposes.

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*Fair value of financial instruments:* Substantially all of the Company's financial assets and liabilities are carried at fair value or at amounts which, because of their short-term nature and based on market interest rates available to the Company onDecember 31, 2021, approximate fair value.

*Cash and cash equivalents:*Cash equivalents include money market funds, time deposits and commercial paperwith original or remaining maturities at the time of purchase of 90 days or less. The Company has evaluated the cash equivalents for credit risk and has determined it is negligible due to the short term nature of the investment.

*Deferred acquisition costs:* Certain commissions are advanced to affiliates and outside distributors by the Company in connection with the sales of class C mutual funds where customers are not charged a time of sale commission. As such these amounts paid by the Company are deferred and are amortized over the period for which the shares are subject to a contingent deferred sales charge which is generally for 1 year. The Companyhas a process to evaluate impairment annually or whenever events and circumstances indicate that an impairment may have occurred, such as a significant adverse change in the business climate. No impairments were identified as a result of these tests for the year ended December 31, 2021.

*Intangible assets:* Intangible assets are composed of acquired distribution relationships and are amortized over their estimated useful lives of 15 years. TheCompany evaluates the definite lived intangible assets' remaining useful lives annually on the measurement date of July 1 and tests for impairment whenever events and circumstances indicate that an impairment may have occurred, such as a significant adverse change in the business climate. For definite lived intangible assets, impairment to fair value is recognized if the carrying amount is not recoverable. No impairments were identified as a result of these tests for the year ended December 31, 2021.

### **2. Recent Accounting Pronouncements**

### **Adoption of New Accounting Standards**

#### *Income Taxes – Simplifying the Accounting for Income Taxes*

In December 2019, the Financial Accounting Standards Board ("FASB") updated the accounting standards to simplify the accounting for income taxes. The update eliminates certain exceptions to: (1) accounting principles related to intraperiod tax allocation to be applied on a prospective basis, (2) deferred tax liabilities related to outside basis differences to be applied on a modified retrospective basis through a cumulative-effect adjustment to retained earnings as of the beginning of the period of adoption, and (3) year-to-date losses in interim periods to be applied on a prospective basis. The update also amends existing guidance related to situations when an entity receives: (1) a step-up in the tax basis of goodwill to be applied on a prospective basis, (2) an allocation of income tax expense when members of a consolidated tax filing group issue separate financial statements to be applied on a retrospective basis for all periods presented, (3) interim recognition of enactment of tax laws or rate changes to be applied on a prospective basis, and (4) franchise taxes and other taxes partially based on income to be applied on a retrospective basis for all periods presented or a modified retrospective basis through a cumulative-effect adjustment to retained earnings as of the beginning of the period of adoption. The standard is effective for interim and annual periods beginning after December 15, 2020, with early adoption permitted. The Company adopted the standard on January 1, 2021. The adoption of this standard had no impact on the Company's consolidated results of operations and financial condition.

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#### **3. Intangible Assets**

Intangible assets representing acquired distribution relationships are amortized over an assigned useful life of 15 years. The Company evaluates the definite lived intangible assets' remaining useful lives annually. No impairments were identified as a result of these tests for the year ended December 31, 2021.

|                           | Gross Carrying<br>Amount |    | Accumulated<br>Amortization |    | Net Carrying<br>Amount |  |
|---------------------------|--------------------------|----|-----------------------------|----|------------------------|--|
| December 31, 2020 balance | \$<br>2,000              | \$ | (1,622)                     | \$ | 378                    |  |
| Amortization              | —                        |    | (134)                       |    | (134)                  |  |
| December 31, 2021 balance | \$<br>2,000              | \$ | (1,756)                     | \$ | 244                    |  |

## **4. Income Taxes**

The Company had a payable to the Parent for federal income taxes of \$213 and a payable for state income taxes of \$83 at December 31, 2021, which were included in Due to affiliates on the statement of financial condition.

Significant components of the Company's deferred income tax assets and liabilities as of December 31, 2021 are as follows:

| Deferred income tax assets:           |               |
|---------------------------------------|---------------|
| Loss carryovers                       | 4\$           |
| Less: valuation allowance             | (4)           |
| Total deferred income tax assets      | -             |
| Deferred income tax liabilities:      |               |
| Deferred commission                   | (1,144)       |
| Intangible asset amortization         | (59)          |
| Total deferred income tax liabilities | (1,203)       |
| Net deferred income tax liability     | \$<br>(1,203) |

Included in the Company's deferred income tax assets are tax benefits related to state net operating losses of \$4, net of federal benefit, which will expire beginning December 31, 2026. Based on analysis of the Company's tax position, management believes it is more likely than not that the Company will not realize certain state deferred tax assets and state net operating losses and therefore a valuation allowance has been established.

For all open tax years and all major taxing jurisdictions, management of the Company has concluded that there are no significant uncertain tax positions that would require recognition in the financial statements. Furthermore, management of the Company is also not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months. The Company has no unrecognized tax benefits or related interest and penalties for the year ended December 31, 2021.

The Company files income tax returns, as part of its inclusion in the consolidated federal income tax return of Ameriprise Financial (the Parent), in the U.S. federal jurisdiction and various state jurisdictions. The federal statute

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of limitation are closed on years through 2015, except for one issue for 2014 and 2015 which was claimed on amended returns. The IRS is currently auditing the Parent's U.S. income tax returns for 2016 through 2020. Ameriprise Financial's or its subsidiaries', including the Company's, state tax returns are currently under examination by various jurisdictions for years ranging from 2015 through 2019.

### **5. Fair Values of Assets and Liabilities**

U.S. GAAP defines fair value as 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; that is, an exit price. The exit price assumes the asset or liability is not exchanged subject to a forced liquidation or distressed sale.

## **Valuation Hierarchy**

The Company categorizes its fair value measurements according to a three-level hierarchy. The hierarchy prioritizes the inputs used by the Company's valuation techniques. A level is assigned to each fair value measurement based on the lowest level input that is significant to the fair value measurement in its entirety. Thethree levels of the fair value hierarchy are defined as follows:

- Level 1 Unadjusted quoted prices for identical assets or liabilities in active markets that are accessible at the measurement date.
- Level 2 Prices or valuations based on observable inputs other than quoted prices in active markets for identical assets and liabilities.
- Level 3 Prices or valuations that require inputs that are both significant to the fair value measurement and unobservable.

## **Determination of Fair Value**

The Company uses valuation techniques consistent with the market and income approaches to measure the fair value of its assets and liabilities. The Company's market approach uses prices and other relevant information generated by market transactions involving identical or comparable assets or liabilities. TheCompany's income approach uses valuation techniques to convert future projected cash flows to a single discounted present value amount. When applying either approach, the Company maximizes the use of observable inputs and minimizes the use of unobservable inputs. The following is a description of the valuation techniques used to measure fair value and the general classification of these instruments pursuant to the fair value hierarchy.

#### **Assets**

### *Cash equivalents*

The Company's cash equivalents, consisting of money market funds which are classified as Level 1 and commercial paperwhich are classified as Level 2, are measured at amortized cost, which approximatesfair value because of the short time between the purchase of the instrument and its expected realization.

When available, the fair value of securities is based on quoted prices in active markets. If quoted prices are not available, fair values are obtained from third party pricing services, non-binding broker quotes, or other model-based valuation techniques.

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The following table presents the balances of assets and liabilities measured at fair value on a recurring basis:

|                            | December 31, 2021 |       |         |        |         |   |    |        |
|----------------------------|-------------------|-------|---------|--------|---------|---|----|--------|
|                            | Level 1           |       | Level 2 |        | Level 3 |   |    | Total  |
| Assets                     |                   |       |         |        |         |   |    |        |
| Cash equivalents           |                   |       |         |        |         |   |    |        |
| Money market funds         | \$                | 5,203 | \$      | —      | \$      | — | \$ | 5,203  |
| Commercial paper           |                   | —     |         | 78,594 |         | — |    | 78,594 |
| Total assets at fair value | \$                | 5,203 | \$      | 78,594 | \$      | — | \$ | 83,797 |

During the reporting period, there were no assets or liabilities measured at fair value that were Level 3 and there were no material assets or liabilities measured at fair value on a nonrecurring basis.There were no transfers between levels.

#### **Fair Value of Financial Instruments**

In general, the Company's financial assets and liabilities are carried at fair value or at amounts which, because of their short-term nature and based on market interest rates available to the Company at December 31, 2021, approximate fair value.

### **6. Net Capital Provisions and Regulatory Requirements**

As a registered broker dealer, the Company is subject to the SEC's uniform net capital rule (Rule 15c3-1).

The Company computes its net capital requirements under the alternative method provided for in Rule 15c3-1, which requires the Company to maintain net capital equal to 2% of combined aggregate customer-related debit items, as defined (or \$250, if greater).

At December 31, 2021, theCompany had net capital of \$14,334, which was \$14,084in excess ofthe amount required to be maintained. Advances to affiliates, dividend payments and other equity withdrawals are subject to certain notification and other provisions of the net capital rule of the SEC and other regulatory bodies.

The Company has no possession or control obligations under SEA Rule 15c3-3(b) or reserve deposit obligations under SEA Rule 15c3-3(e) as the Company acts as a limited purpose broker dealer primarily serving as a distributor and underwriter. During the reporting period, the Company (i) 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; (ii) did not carry accounts of or for customers; and (iii) did not carry PAB accounts (as defined in Rule 15c3-3).

### **7. Related-Party Transactions**

The Company provides various services to other affiliates and is compensated for these services pursuant to various agreements with the affiliates to which the services are provided. The most significant activity includes providing distribution services for associated mutual funds sold through an affiliated field force and outside distributors. Distribution fees include point-of-sale fees (such as front-load mutual fund fees) and asset-based fees that are generally based on a contractualrateas a percentage of the fair value of assets (such as 12b-1 fees).

CMIA has agreed to provide sponsor support to the Company for any services provided and liabilities incurred in its capacity as a principal underwriter and distributor of the Columbia Funds.

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Receivables due from affiliates on the statement of financial condition, as of December 31, 2021, primarily relates to a receivable for marketing and administrative support for \$1,500.

Payables due to affiliates on the statement of financial condition as of December 31, 2021, primarily relates to 12b-1 fees of \$24,247, fees for use of affiliates' wholesaling and marketing capabilities of \$9,910, transfer agent fees of \$6,831, administration support payable to the Parent of \$1,017and marketing support of \$2,870.

### **8. Commitments and Contingencies**

In the normal course of business, the Company may indemnify and guarantee certain service providers against potential losses in connection with their acting as service providers to the Company. The maximum potential amount of future payments the Company could be required to make under these indemnifications cannot be estimated, however, the Company believes that it is unlikely it will have to make material payments under these arrangements and has not recorded a contingent liability in the financial statements for any indemnifications.

### **9. Subsequent Events**

As of February 25, 2022, which is the date the financial statements were available to be issued, the Company has evaluated events or transactions that may have occurred after the balance sheet date for potential recognition or disclosure. No events or transactions were identified requiring further recognition or disclosure.


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