# MONUMENT GROUP, INC. X-17A-5 (2023-12-20) — Broker-dealer annual report

- Company: MONUMENT GROUP, INC.
- Form: X-17A-5
- Filed: 2023-12-20
- Period: 2023-09-30
- Accession: 0000922783-23-000004
- CIK: 922783
- File #: 8-47248
- Type: Broker-dealer
- Material weakness: No
- Auditor: Larry D. Liberfarb, P.C.
- Auditor location: Norwood, MA
- Contact: Patrick MacCurtain
- Phone: 617-423-4700
- Email: info@liberfarb.com
- Website: liberfarb.com
- Signed by: Patrick MacCurtain (Partner, COO)

Original filing: https://www.sec.gov/Archives/edgar/data/922783/000092278323000004/formx17a.pdf

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

### **ANNUAL REPORTS FORM X-17A-5 PART** Ill

0MB APPROVAL 0MB Number: 3235-0123 Expires: Oct. 31, 2023 Estimated average burden hours per response: 12

SEC FILE NUMBER

**FACING PAGE** 

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

| FILING FOR THE PERIOD BEGINNING                                                                                    | 10/01<br>/22                                               |                        | AND ENDING 09/30/23 |                                              |  |
|--------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|------------------------|---------------------|----------------------------------------------|--|
|                                                                                                                    | ---------<br>MM/DD/ Y Y                                    |                        |                     | ----------<br>MM/DD/VY                       |  |
|                                                                                                                    | A. REGISTRANT IDENTIFICATION                               |                        |                     |                                              |  |
| NAME OF FIRM: MONUMENT                                                                                             | GROUP,<br>INC.                                             |                        |                     |                                              |  |
| TYPE OF REGISTRANT (check all applicable<br>IZl Broker-dealer<br>D Security-based<br>D Check here if respondent is | boxes):<br>swap dealer<br>also an OTC derivatives dealer   | D Major security-based |                     | swap participant                             |  |
| ADDRESS OF PRINCIPAL PLACE OF                                                                                      | BUSINESS: (Do not use a P.O. box                           | no.)                   |                     |                                              |  |
| 500 BOYLSTON<br>STREET                                                                                             |                                                            |                        |                     |                                              |  |
|                                                                                                                    | (No. and Street)                                           |                        |                     |                                              |  |
| BOSTON                                                                                                             | MA                                                         |                        |                     | 02116                                        |  |
| (City)                                                                                                             |                                                            | (State)                |                     | (Zip Code)                                   |  |
| PERSON TO CONTACT WITH REGARD                                                                                      | TO THIS FILING                                             |                        |                     |                                              |  |
| MICHAEL<br>MILLER                                                                                                  | 617-423-4<br>700                                           |                        |                     | MIKE(ci2MONUMENTGROUP.COM                    |  |
| (Name)                                                                                                             | (Area Code - Telephone Number)                             |                        | (Email Address)     |                                              |  |
|                                                                                                                    | 8. ACCOUNTANT IDENTIFICATION                               |                        |                     |                                              |  |
| INDEPENDENT PUBLIC ACCOUNTANT                                                                                      | whose reports are contained in this                        |                        | filing*             |                                              |  |
| LARRY<br>D. LIBERFARB,<br>PC                                                                                       |                                                            |                        |                     |                                              |  |
|                                                                                                                    | (Name - if individual, state last, first, and middle name) |                        |                     |                                              |  |
| 11 VANDERBILT<br>AVENUE#                                                                                           | 220<br>NORWOOD                                             |                        | MA                  | 02062                                        |  |
| (Address)                                                                                                          | (City)                                                     |                        | (State)             | (Zip Code)                                   |  |
| l"<br>1/10/2006                                                                                                    |                                                            |                        | 2560                |                                              |  |
| of Reg;;tcatloo w;th PCAOB )(ff applicable)                                                                        |                                                            |                        |                     | (PCAOB Reg;,tratloo N,m bee, ;f appUcable) I |  |
|                                                                                                                    | FOR OFFICIAL USE ONLY                                      |                        |                     |                                              |  |
| * Claims<br>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 <sup>17</sup> CFR 240.l?a-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.** 

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#### **OATH OR AFFIRMATION**

**I, MICHAEL MILLER** swear (or affirm) that, to the best of my knowledge and belief, the financial report pertaining to the firm of **MONUMENT GROUP, INC.** as of

**SEPTEMBER** 30 2 023 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.

Signature:~ ('. <sup>~</sup> Title:

**PRESIDENT** 

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

- **0** (a) Statement offinancial condition.
- 0 (b) Notes to consolidated statement of financial condition.
- **<sup>0</sup>**(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).
- **0** (d) Statement of cash flows .
- **<sup>0</sup>**(e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- **D** (f) Statement of changes in liabilities subordinated to claims of creditors.
- **D** (g) Notes to consolidated financial statements.
- <sup>0</sup>(h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-l, as applicable.
- □ (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.
- **<sup>D</sup>**(k) Computation for determination ofsecurity-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.
- **<sup>D</sup>**(I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- **<sup>0</sup>**(m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- **<sup>D</sup>**(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.
- **<sup>0</sup>**(o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under <sup>17</sup> CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- **<sup>D</sup>**(p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- **<sup>0</sup>**(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.
- **<sup>D</sup>**(r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- **<sup>0</sup>**(s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- **<sup>D</sup>**(t) Independent public accountant's report based on an examination of the statement of financial condition.
- **<sup>0</sup>**(u) Independent public accountant's report based on an examination of the financial report or financial statements under <sup>17</sup> CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- **<sup>D</sup>**(v) Independent public accountant's report based on an examination of certain statements in the compliance report under <sup>17</sup> CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- **<sup>0</sup>(w)** Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or <sup>17</sup> CFR 240.18a-7, as applicable.
- **<sup>D</sup>(x)** Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable.
- **<sup>D</sup>**(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)(2), as applicable.

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MONUMENT GROUP, INC. FINANCIAL STATEMENTS SEPTEMBER 30, 2023

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### LARRY D. LIBERFARB, P.C.

CERTIFIED PUBLIC ACCOUNTANTS AND FINANCIAL ADVISORS

11 Vanderbilt Avenue, Suite 220, Norwood, Massachusetts 02062 Tel. (781) 255-8800 Fax (781) 255-9217 E-Mail: Info@Liberfarb.com

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Board of Directors of Monument Group, Inc.

#### **Opinion on the Financial Statements**

We have audited the accompanying statement of financial condition of Monument Group, Inc. as of September 30, 2023, the related statements of operations, changes in shareholders' equity, and cash flows for the year then ended, 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 Monument Group, Inc. as of September 30, 2023, and the results of its operations and its cash flows for the year then end~d in conformity with accounting principles generally accepted in the United States of America.

#### **Basis for Opinion**

These financial statements are the responsibility of Monument Group, lnc.'s management. Our responsibility is to express an opinion on Monument Group, lnc.'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 Monument Group, Inc. in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

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 computation of aggregate indebtedness and net capital pursuant to SEC Rule 15c3-1 and computation for determination of reserve and information relating to possession and control requirements for broker dealers under Rule 15c3-3 have been subjected to audit procedures performed in conjunction with the audit of Monument Group, lnc.'s financial statements. The supplemental information is the responsibility of Monument Group, lnc.'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. §240.1 ?a-5. In our opinion, the computation of aggregate

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indebtedness and net capital pursuant to SEC Rule 15c3-1 and computation for determination of reserve and information relating to possession and control requirements for broker dealers under Rule 15c3-3 is fairly stated, in all material respects, in relation to the financial statements as a whole.

We have served as Monument Group, lnc. 's auditor since 2009.

Norwood, Massachusetts December 19, 2023

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#### **STATEMENT OF FINANCIAL CONDITION**

#### **SEPTEMBER 30, 2023**

#### **ASSETS**

| Cash                                                           | \$<br>358,402    |
|----------------------------------------------------------------|------------------|
| Placement<br>and consulting<br>fees receivable                 | 15,222,490       |
| Other assets                                                   | 836              |
|                                                                | \$<br>15,581,728 |
|                                                                |                  |
| LIABILITIES<br>AND<br>STOCKHOLDERS'<br>EQUITY                  |                  |
| Liabilities:                                                   |                  |
| Accounts payable,<br>accrued expenses<br>and other liabilities | \$<br>15,146,377 |
| Stockholders'<br>equity:                                       |                  |
| Common stock,<br>.01 par value,<br>authorized 7,500<br>shares  |                  |
| 7,500 shares<br>issued and<br>outstanding                      | 75               |
| Additional<br>paid-in capital                                  | 2,271,111        |
| Accumulated<br>deficit                                         | (1,835,835)      |
| Total stockholders'<br>equity                                  | 435,351          |
|                                                                | \$<br>15,581,728 |
|                                                                |                  |

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#### **STATEMENT OF OPERATIONS**

#### **FOR THE YEAR ENDED SEPTEMBER 30, 2023**

| Revenues:                 |                  |
|---------------------------|------------------|
| Private placement<br>fees | \$<br>26,197,477 |
| Investment income         | 7,729            |
|                           | 26,205,206       |
|                           |                  |
| Expenses:                 |                  |
| Commissions               | 26,209,997       |
| Other expenses            | 218,854          |
|                           | 26,428,851       |
|                           |                  |
|                           |                  |

Net loss

\$ (223,645)

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# **STATEMENT OF CHANGES IN STOCKHOLDERS' EQUITY FOR THE YEAR ENDED SEPTEMBER 30, 2023**

|                                                                                                   | Co<br>S | m<br>m<br>on<br>k<br>to<br>c | A<br>d<br>d<br>i<br>io<br>l<br>t<br>na<br>Pa<br>i<br>d-<br>In<br>Ca<br>i<br>l<br>ta<br>p | A<br>la<br>d<br>te<br>cc<br>um<br>u<br>D<br>f<br>ic<br>i<br>t<br>e |    | To<br>l<br>ta                         |
|---------------------------------------------------------------------------------------------------|---------|------------------------------|------------------------------------------------------------------------------------------|--------------------------------------------------------------------|----|---------------------------------------|
| B<br>la<br>O<br>be<br>1,<br>2<br>0<br>2<br>t<br>2<br>to<br>a<br>nc<br>e<br>a<br>c<br>r            | \$      | 5<br>7                       | \$<br>2,<br>0<br>1<br>3,<br>3<br>8<br>8                                                  | \$<br>(<br>1,<br>1<br>6<br>2,<br>1<br>9<br>0<br>)                  | \$ | 4<br>0<br>1<br>2<br>3<br>7<br>,       |
| N<br>lo<br>t<br>e<br>ss                                                                           |         | -                            | -                                                                                        | (<br>2<br>2<br>3,<br>6<br>4<br>5<br>)                              |    | (<br>2<br>2<br>3,<br>4<br>5<br>6<br>) |
| S<br>ha<br>ho<br>l<br>de<br>i<br>bu<br>io<br>tr<br>t<br>re<br>r c<br>on<br>ns                     |         | -                            | 2<br>5<br>7,<br>7<br>2<br>3                                                              | -                                                                  | -  | 2<br>5<br>7,<br>7<br>2<br>3           |
| B<br>la<br>Se<br>be<br>3<br>0,<br>t<br>2<br>0<br>2<br>3<br>te<br>a<br>nc<br>e<br>a<br>p<br>m<br>r | \$      | 7<br>5                       | \$<br>2,<br>2<br>7<br>1,<br>1<br>1<br>1                                                  | \$<br>{<br>1,<br>8<br>3<br>5,<br>8<br>3<br>5<br>)                  | \$ | 4<br>3<br>5,<br>3<br>5<br>1           |

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### **MONUMENT GROUP, INC. STATEMENT OF CASH FLOWS FOR THE YEAR ENDED SEPTEMBER 30, 2023**

| Cash flows from operating activities:                       |                 |
|-------------------------------------------------------------|-----------------|
| Net loss                                                    | \$<br>(223,645) |
| Adjustments to reconcile net loss                           |                 |
| to net cash provided by operating activities:               |                 |
| (Increase) Decrease in operating assets                     |                 |
| Placement and consulting fees receivable                    | (15,162,497)    |
| Other assets                                                | 112             |
| Increase (Decrease) in operating liabilities                |                 |
| Accounts payable, accrued expenses<br>and other liabilities | 15,146,377      |
| Total adjustments                                           | (16,008)        |
| Net cash used by operating activities                       | (239,653)       |
| Cash flows from investing activities                        |                 |
| None                                                        |                 |
|                                                             |                 |
| Cash flows provided by financing<br>activities              |                 |
| Increase in additional paid-in capital                      | 257,723         |
|                                                             |                 |
| Increase in cash                                            | 18,070          |
| Cash at beginning of the period                             | 340,332         |
| Cash at end of the period                                   | \$<br>358,402   |
| Supplemental disclosures of cash flow<br>information:       |                 |
| Cash paid during the year for:                              |                 |
| Interest                                                    | \$              |
| Income taxes                                                | \$<br>10,926    |
|                                                             |                 |

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#### **NOTES TO FINANCIAL STATEMENTS**

#### **SEPTEMBER 30, 2023**

### **NOTE 1-ORGANIZATION AND NATURE OF THE BUSINESS**

The Company began operations July 15, 1994. The Company is a broker-dealer registered with the Securities and Exchange Commission (SEC), and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA). The Company is engaged principally in the placement of private securities with institutional investors.

### **NOTE 2 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**

#### Revenue From Contracts With Customers

Revenue from contracts with customers are composed of private placement fees. Such fees are recognized at the point in time when the Company's performance under the terms of the contractual agreement is completed, which is typically at the closing of the transaction. Reimbursed expenses related to these transactions are recorded as revenue and are included in private placement fees. In certain instances, the Company will receive amounts in advance of the deal's closing. In these instances, revenue is recognized over time in which the performance obligations are simultaneously provided by the Company and consumed by the customer. At September 30, 2023, there were no advances to the Company.

#### Accounts Receivable

Accounts receivable are stated at the amount management expects to collect. Management provides for probable uncollectable amounts through a charge to earnings and a credit to an allowance based on the assessment of the current status of individual accounts. At September 30, 2023 management feels that all receivables are collectable.

#### Cash and Cash Equivalents

For purposes of the statement of cash flows, the Company considers all highly liquid debt instruments purchased with a maturity of three months or less to be cash equivalents.

#### Income Taxes

The Company and its stockholders have elected to be treated as an S Corporation under the provisions of the Internal Revenue Code. Accordingly, in lieu of federal and state corporate income taxes, the stockholders are taxed on their proportionate share of the Company's taxable mcome.

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#### **NOTES TO FINANCIAL STATEMENTS, CONTINUED**

#### **SEPTEMBER 30, 2023**

#### **NOTE 2 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)**

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.

#### **NOTE 3 - CONCENTRATION OF CREDIT RISK**

During the year, the Company, maintained cash accounts at various financial institutions in bank deposits which at times exceeded the federally-insured limit of \$250,000. The Company has not experienced any losses on such accounts and believes it is not exposed to any significant credit risk regarding its cash balances.

#### **NOTE 4 - RELATED PARTY TRANSACTIONS**

The Company paid \$25,091,249 in commissions to a related company, Monument Group, LP (M.G., LP). Since the Company has common ownership with M.G., LP, operating results could vary significantly from those that would be obtained if the entities were autonomous. The Company owed \$15,146,377 to this related entity at September 30, 2023.

#### **NOTE 5 -NET CAPITAL**

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (Rule 15c3-1), which requires the maintenance of minimum net capital, and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. The Company had net capital of \$358,402 which was deficient by \$282,930 of its required net capital of \$641,332. The Company's net capital ratio was 26.84 to 1.

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#### **NOTES TO FINANCIAL STATEMENTS, CONTINUED**

#### **SEPTEMBER 30, 2023**

#### **NOTE 6** - **SUBSEQUENT EVENTS**

Management has evaluated subsequent events through December 19, 2023, the date on which the financial statements were available to be issued. As mentioned in Note 5, the Company had a deficiency in net capital. Accordingly, notification has been made to regulators, as required by regulations. Furthermore, on December 18, 2023 shareholders deposited \$500,000 of additional paid-in capital. As of the date the financial statements are available for release, the Company is in compliance with net capital (Rule15c3-1).

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## MONUMENT GROUP, INC. SUPPLEMENTARY SCHEDULES SEPTEMBER 30, 2023

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#### **SCHEDULE I**

#### **MONUMENT GROUP, INC.**

#### **COMPUTATION OF AGGREGATE INDEBTEDNESS AND NET CAPITAL PURSUANT TO RULE 15c3-1**

#### **SEPTEMBER 30, 2023**

| AGGREGATE INDEBTEDNESS:                                   |              |              |
|-----------------------------------------------------------|--------------|--------------|
| Accounts payable and accrued expenses                     | \$ 9,619,983 |              |
| NET CAP IT AL:                                            |              |              |
| Common stock                                              | \$           | 75           |
| Additional paid-in capital                                |              | 2,271,111    |
| Accumulated deficit                                       |              | (1,835,835)  |
|                                                           |              | 435,351      |
| ADillSTMENTS TO NET CAPITAL:                              |              |              |
| Placement and consulting fees receivable (net)            |              | (76,113)     |
| Other assets                                              |              | (836)        |
| Haircuts                                                  |              |              |
| Net capital, as defined                                   | \$           | 358,402      |
| NET CAPITAL REQUIREMENT                                   | \$           | 641,332      |
| NET CAPITAL DEFICIENCY                                    |              | \$ (282,930) |
| RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL            |              | 26.84 to 1   |
| Reconciliation with Company's computation of net capital: |              |              |
| Net capital as reported in Company's Part IIA (unaudited) |              |              |
| Focus Report                                              | \$           | 358,402      |
| Net audit adjustments                                     |              | 19,908       |
| Increase in non-allowables and haircuts                   |              | (19,908)     |
| Net capital per above                                     | \$           | 358,402      |
|                                                           |              |              |

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#### **SCHEDULE** II

#### **MONUMENT GROUP, INC.**

### **COMPUTATION FOR DETERMINATION OF RESERVE AND INFORMATION RELATED TO POSSESSION OR CONTROL REQUIREMENTS FOR BROKER/DEALERS UNDER RULE 15c3-3 OF THE SECURITIES EXCHANGE ACT OF 1934**

#### **SEPTEMBER 30, 2023**

Monument Group, Inc. is exempt from the reserve requirements of Rule 15c3-3 as its transactions are limited, such that they do not handle customer funds or securities, accordingly, the computation for determination of reserve requirements pursuant to Rule 15c3-3 and information relating to the possession or control requirement pursuant to Rule 15c3-3 are not applicable.

{15}------------------------------------------------

### LARRY D. LIBERFARB, P.C.

CERTIFIED PUBLIC ACCOUNTANTS AND FINANCIAL ADVISORS

11 Vanderbilt Avenue, Suite 220, Norwood, Massachusetts 02062 Tel. (781) 255-8800 Fax (781) 255-9217 E-Mail: Info@Liberfarb.com

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Board of Directors of Monument Group, Inc.

We have reviewed management's statement, included in the accompanying Exemption Report, in which (1) Monument Group, Inc. identified that it was filing the exemption report solely to be in compliance with <sup>17</sup>C.F.R. 240.17a-5 (d)(1) and (4). Monument Group, Inc. does not claim an exemption under paragraph (k) of 17 C.F.R. 240. 15c3-3, and is 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 receiving transaction-based compensation for identifying private placements for clients, (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 or 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) throughout the most recent fiscal year without exception. Monument Group, lnc.'s management is responsible for compliance with Footnote 74 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 Monument Group, lnc.'s compliance with the exemption provision. 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 upon the Company's business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C. F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions.

{16}------------------------------------------------

#### **EXEMPTION REPORT REQUIREMENT FOR BROKER/DEALERS UNDER RULE 17a-5 OF THE SECURITIES EXCHANGE ACT OF 1934**

#### **SEPTEMBER 30, 2023**

Monument Group, Inc. (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.l 7a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by <sup>17</sup> C.F.R §240.l 7a-5(d)(l) and (4).

To the best of its knowledge and belief, the Company states the following:

(1) The Company does not claim an exception under paragraph (k) of 1 7 C.F.R § 240.15c3-3, and

(2) The Company is filing the Exemption Report relying on Footnote <sup>74</sup>of the SEC release No. 34-70073 adopting amendments to <sup>17</sup>C.F.R §240. l 7a-5 because the Company limits its business activities exclusively to: (1) receiving transaction-based compensation for identifying private placements for clients, (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 insurer 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) throughout the most recent fiscal year without exception.

I, Michael Miller swear ( or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct.

*}1i~fcl~* 

Signature

President Title


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