# MONUMENT GROUP, INC. X-17A-5 (2025-11-25) — Broker-dealer annual report - Company: MONUMENT GROUP, INC. - Form: X-17A-5 - Filed: 2025-11-25 - Period: 2025-09-30 - Accession: 0000922783-25-000002 - CIK: 922783 - File #: 8-47248 - Type: Broker-dealer - Material weakness: No - Auditor: Larry Liberfarb, PC - Auditor location: Norwood, MA - Contact: Patrick MacCurtain - Phone: 6174234700 - Email: info@liberfarb.com - Website: liberfarb.com - Signed by: Michale Miller (President) Original filing: https://www.sec.gov/Archives/edgar/data/922783/000092278325000002/audit1.pdf --- {0}------------------------------------------------ # 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: Nov. 30, 2026 Estimated average burden hours per response: 12 SEC FILE NUMBER 8-47248 FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | F
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ee | 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. {1}------------------------------------------------ #### OATH OR AFFIRMATION MICHAEL MILLER | | | | | (
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as | ²⁰²⁵ is true and correct.^I further swear (or affirm) that neither the company nor any as partner, that of officer, a customer. director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely Motary Public ppenger Title: PRESIDENT cel Ale This filing\*\* contains (check all applicable boxes): - (a) Statement of financial condition. - (b) Notes to consolidated statement of financial condition. - Π (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-Х). (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. - ப - - (j) 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. - (1) 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 net capital or tangible net worth under ¹⁷ CFR 240.15c3-1, ¹⁷ CFR 240.18a-1, or ¹⁷ CFR 240.18a-2, as applicable, and the reserve requirements under ¹⁷ CFR 240.15c3-3 or ¹⁷ CFR 240.18a-4, as applicable, if material differences exist, or ^a statement that no material differences exist. - ப (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - Π (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. - ㅁ - - E - ☐ (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. (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 report or financial statements under ¹⁷ CFR 240.17a-5, ¹⁷ CFR 240.18a-7, or ¹⁷ CFR 240.17a-12, as applicable. - Π (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. - 미 (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. - Π (x) Supplemental reports on applying agreed-upon procedures, in accordance with ¹⁷ CFR 240.15c3-1e or ¹⁷ CFR 240.17a-12, as applicable. - (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or ^a statement that no material inadequacies exist, under ¹⁷ CFR 240.17a-12(k). (z) Other: - ^\*\*Toapplicable. 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 {2}------------------------------------------------ MONUMENT GROUP, INC. FINANCIAL STATEMENTS SEPTEMBER 30, 2025 {3}------------------------------------------------ # 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 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, 2025, the related statements of operations, changes in stockholders' 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 Monument Group, Inc. as of September 30, 2025, 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 responsibility financial statements are the responsibility of Monument Group, Inc.'s management. Our is to express an opinion on Monument Group, Inc.'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 РСАОВ. 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 (Schedule I) and computation for determination of reserve and information relating to possession and control requirements for broker dealers under Rule 15c3-3 of the Securities and Exchange Commission (Schedule II) has been subjected to audit procedures performed in conjunction with the audit of Monument Group, Inc.'s financial statements. The supplemental information is the responsibility of Monument Group, Inc.'s management. Our audit procedures included determining whether the supplemental information reconciles to the {4}------------------------------------------------ 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 computation of aggregate indebtedness and net capital pursuant to SEC Rule 15c3-1 and computation for determination of reserve and information relating to possession anp control requirements for broker dealers under Rule 15c3-3 of the Securities and Exchange Commission is fairly stated, in all material respects, in relation to the financial statements as a whole. Da,iberfarb We have served as Monument Group, Inc.'s auditor since 2009. Norwood, Massachusetts November 14, 2025 {5}------------------------------------------------ # STATEMENT OF FINANCIAL CONDITION #### SEPTEMBER 30, 2025 # ASSETS | h
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\$ | The acco ccompanyinving notes are an^r integral part of these financial statements. {7}------------------------------------------------ # STATEMENT OF CHANGES IN STOCKHOLDERS' EQUITY # FOR THE YEAR ENDED SEPTEMBER 30, 2025 | | | Additiona | | | |-------------------------------|-----------------|----------------------|------------------------|--------------| | | Common
Stock | Paid - In
Capital | Accumulated
Deficit | Total | | 2024
Balance at October 1. | ਚਰੇ | \$ 3,024,480 | \$ (2,046,118) | 978,437
S | | Net loss | | | (268,071) | (268,071) | | Shareholder contributions | | 253,364 | | 253,364 | | Balance at September 30, 2025 | | \$ 3,277,844 | \$ (2,314,189) | \$ 963,730 | The accompanying notes are an integral part of these financial statements. {8}------------------------------------------------ # MONUMENT GROUP, INC. STATEMENT OF CASH FLOWS FOR THE YEAR ENDED SEPTEMBER 30, 2025 | Cash flows from operating activities: | | |----------------------------------------------------------|-----------------| | Net loss | es
(268,071) | | Adjustments to reconcile net loss | | | to net cash provided by operating activities: | | | (Increase) Decrease in operating assets | | | Placement and consulting fees receivable | 2,476,602 | | Other assets | (2,753) | | Increase (Decrease) in operating liabilities | | | Accounts payable, accrued expenses and other liabilities | (2,464,219) | | Total adjustments | 9,630 | | Net cash used by operating activities | (258,441) | | Cash flows from investing activities | | | None | | | | | | Cash flows provided by financing activities | | | Increase in additional paid-in capital | 253,364 | | Increase in cash | (5,077) | | Cash at beginning of the period | 883,841 | | Cash at end of the period | ಲ್ಲಿ
878,764 | | Supplemental disclosures of cash flow information: | | | Cash paid during the year for: | | | Interest | ಕಾ | | Income taxes | ಿತ
10.051 | | | | The accompanying notes are an integral part of these financial statements. {9}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS #### SEPTEMBER 30, 2025 # 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 The Company complies with ASC Topic 606 Revenue from Contracts with Customers (ASC Topic 606). The revenue recognition guidance requires that an entity recognize revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods and services. The guidance requires an entity to follow a five-step model to (a) identify the contract(s) with a customer (b) identify the performance obligations in the contract, (c) determine the transaction price (d) allocate the transaction price to the performance obligation in the contract, and (e) recognize revenue when (or as) the entity satisfies a performance obligation. The Company engages with some clients to perform consulting services in making private placements. Revenue from these services is earned in accordance with contract provisions, usually upon the completion of the engagement. Revenue from retainer fees are earned in the early stage of private placement engagements to cover the Company's overhead. These fees are non refundable, and are earned whether or not a success fee is ever achieved. The performance obligation related to retainers are considered separate and distinct from those related to success fees, and are therefore recorded as those retainer performance obligations are met. Certain private placement contracts include provisions for trails to be earned on the continued investment by investors on an annual basis. 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. {10}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS, CONTINUED #### SEPTEMBER 30, 2025 # NOTE 2 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued) 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 income. 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-PLACEMENT AND CONSULTING FEES RECEIVABLE Placement and consulting fees 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, 2024 management feels that all receivables are collectable. The Company has contractually extended certain customers with payment terms. At September 30, 2025 receivables are expected to be collected as follows: | September 30. | | | |---------------|---------------|--| | 2026 | \$ 10,419,129 | | | 2027 | 4,219,592 | | | 2028 | 1.449.845 | | | 2029 | | | | | 16.088.566 | | {11}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS, CONTINUED #### SEPTEMBER 30, 2025 # NOTE 4 - 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 realit risk regarding its cash balances. # NOTE 5 - RELATED PARTY TRANSACTIONS The Company paid \$24,025,064 in commissions to a related company, Monument Group, LP (M.G., LP). Since the Company has common ownership with M.G., IP, operating results cold vary significantly from those that would be obtained if the entities were autonomouss The Company owed \$16,008,124 to this related entity at September 30, 2025. At September 30, 2025 commissions are expected to be paid as follows: | | September 30. | | | |------|-----------------|--|--| | 2026 | \$ 10,367,034 | | | | 2027 | 4,198,494 | | | | 2028 | 1,442,596 | | | | 2029 | 0 | | | | | S
16,008,124 | | | #### NOTE 6-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 \$878,674 which was \$187,628 in excess of its required net capital of \$691,136. The Company's net capital ratio was 11.80 to 1. {12}------------------------------------------------ # NOTES TO FINANCIAL STATEMENTS, CONTINUED #### SEPTEMBER 30, 2025 # NOTE 7-SEGMENT REPORTING The Company is engaged in a single line of business as a securities broker-dealer, which is comprised of several classes of services, including securities placement fees, both primary and secondary, and consulting. The accounting policies for fees are the same as those described in the summary of significant accounting policies. The chief operating decision maker assesses performance for the agency fee segment and decides how to allocate resources based on net income that is reported on the statement of operations. The measurement of segment assets is reported on the balance sheet as total assets. The chief operating decision maker uses net income to evaluate income generated from segment assets (return on assets) in deciding whether to reinvest profits into the agency fee segment or into other parts of the entity. The chief operating decision maker also uses net income in competitive analysis by benchmarking competitors. The Company derives revenue worldwide. The company's chief operating decision maker is the president. #### NOTE 8 - SUBSEQUENT EVENTS Management has evaluated subsequent events through November [], 2025, the date on which the financial statements were available to be issued. There were no subsequent events that require adjustment or disclosure in the financial statements. {13}------------------------------------------------ # SUPPLEMENTARY SCHEDULES #### SEPTEMBER 30, 2025 {14}------------------------------------------------ #### SCHEDULE I # MONUMENT GROUP, INC. # COMPUTATION OF AGGREGATE INDEBTEDNESS AND NET CAPITAL PURSUANT TO RULE 15c3-1 # SEPTEMBER 30, 2025 | AGGREGATE INDEBTEDNESS: | | | | | |-----------------------------------------------------------|------|------------|------|-------------| | Accounts payable and accrued expenses | ಕ್ಕಾ | 10,367,033 | | | | NET CAPITAL: | | | | | | Common stock | | | S | 75 | | Additional paid-in capital | | | | 3,277,844 | | Accumulated deficit | | | | (2,314,189) | | | | | | 963,730 | | | | | | | | ADJUSTMENTS TO NET CAPITAL: | | | | | | Placement and consulting fees receivable (net) | | | | (80,442) | | Other assets | | | | (4,524) | | Haircuts | | | | | | Net capital, as defined | | | ಕಾ | 878,764 | | NET CAPITAL REQUIREMENT | | | S | 691,136 | | NET CAPITAL IN EXCESS OF REQUREMENT | | | ಲಾ | 187,628 | | RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL | | | | 11.80 | | Reconciliation with Company's computation of net capital: | | | | | | Net capital as reported in Company's Part IIA (unaudited) | | | | | | Focus Report | | | S | 878,764 | | Net audit adjustments | | | | | | Increase in non-allowables and haircuts | | | | | | Net capital per above | | | ಕ್ಕಾ | 878,764 | | | | | | | #### NOTE: There are no material differences between the above computation of net capital and the corresponding computation as submitted by the Company with the unaudited For X-17A-5 as of September 30, 2025 {15}------------------------------------------------ #### 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, 2025 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. {16}------------------------------------------------ # REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES To the Board of Directors Monument Group, Inc. We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC-7) for the year ended September 30, 2025. Management of Monument Group, Inc. (the Company) is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7. Management of the Company has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting you and SIPC in evaluating the Company's compliance with the applicable instructions on Form SIPC-7 for the year ended September 30, 2025. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropries for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficier of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our associated findings are as follows: - 1) Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries, noting no differences; - 2) Compared the Total Revenue amounts reported on the Annual Audited Report Form X-17A-5 Part III for the year ended September 30, 2025 with the Total Revenue amount reported in Form SIPC-7 for the year ended September 30, 2025, noting no differences; - 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers, noting no differences; - 4) Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments, noting no differences; and - 5) Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed, noting no differences. We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). We were not engaged to and did not conduct an examination or a review engagement, the objective of which would be the expression of an opinion or conclusion, respectively, on the Company's Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended September 30, 2025. {17}------------------------------------------------ # 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 F-Mail: Info@I iherfarb.com # REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Members 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 17 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, Inc.'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, Inc.'s compliance with the provisions of Footnote 74. 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. Norwood, Massachuset November 14, 202 {18}------------------------------------------------ # EXEMPTION REPORT REQUIREMENT FOR BROKER/DEALERS UNDER RULE 17a-5 OF THE SECURITIES EXCHANGE ACT OF 1934 #### SEPTEMBER 30, 2025 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. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R §240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following: (1) The Company does not claim an exception under paragraph (k) of 17 C.F.R. § 240.15c3-3, and (2) The Company is filing the 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: (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. Signature President Title Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.