# KILEY PARTNERS, INC. X-17A-5 (2020-02-06) — Broker-dealer annual report

- Company: KILEY PARTNERS, INC.
- Form: X-17A-5
- Filed: 2020-02-06
- Period: 2019-12-31
- Accession: 0000937809-20-000001
- CIK: 937809
- File #: 8-48050
- Material weakness: No
- Auditor: Rubio CPA, PC
- Auditor location: Atlanta, GA
- Contact: Michael Kiley
- Phone: 561-630-3200
- Signed by: Michael Kiley (CEO)

Original filing: https://www.sec.gov/Archives/edgar/data/937809/000093780920000001/kp.pdf

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UNITEDSfATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549

## **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill**

OMS APPROVAL OMS Number: 3235-0123 Expires: August 31, 2020 Estimated average burden hours per response ... .. . '12.00

| SEC FILE NUMBER |
|-----------------|
| B-48050         |

FACING PAGE Informatio·n Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder

|                                                                                                                                       | REPORT FOR THE PERIOD BEGINNING 01/01/2019<br>AND ENDING 12/31/2 019 |                   |                                |
|---------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------|-------------------|--------------------------------|
|                                                                                                                                       | ----------------------<br>MM/DD/YY                                   |                   | MM/DD/YY                       |
|                                                                                                                                       | A. REGISTRANT IDENTIFICATION                                         |                   |                                |
| NAME OF .BROKER-DEALER: KILEY PARTNERS, INC.<br>ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)                     |                                                                      | OfFICIAL USE ONLY |                                |
|                                                                                                                                       |                                                                      |                   | FIRM J.D. NO.                  |
| 16 BEL GIORNO COURT                                                                                                                   |                                                                      |                   |                                |
| Henderson                                                                                                                             | {No. and Street)<br>NV                                               |                   | 89011                          |
| {City)                                                                                                                                | (State)                                                              |                   | (Zip Code)                     |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>MICHAEL KILEY                                              |                                                                      |                   | 561-630-3200                   |
|                                                                                                                                       | B.ACCOUNTANTIDENTDnCATION                                            |                   | (Area Code - Telephone Number) |
| INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*<br>RUBIO CPA, PC                                             | (Name - if individual, state last, first, middle name)               |                   |                                |
| 2727 Paces Ferry Rd SE, Suite 2-1680 ATLANTA                                                                                          |                                                                      | GA                | 30339                          |
| {Address)                                                                                                                             | (City)                                                               | (State)           | (Zip Code)                     |
| CHECK ONE:                                                                                                                            |                                                                      |                   |                                |
| l.f I<br>Certified Public Accountant<br>B<br>Public Accountant<br>Accountant not resident in United States or any of its possessions. |                                                                      |                   |                                |
|                                                                                                                                       | FOR OFFICIAL USE ONLY                                                |                   |                                |
|                                                                                                                                       |                                                                      |                   |                                |
|                                                                                                                                       |                                                                      |                   |                                |
| *Claims .for exemption from the requirement thai the annual report be covered by the opinion of an independent public accountant      |                                                                      |                   |                                |

*must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section240.17a-5(e)(2)* 

Potential persons who are to respond to the collection of information contained in this form are not required to re.spond unless the form dis pi ays a currently valid 0 MB control number.

SEC 141 0 (06·02)

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#### OATH OR AFFIRMATION

I, MICHAEIL KILEY , swear (or affirm) that, to the best of

my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of KILEY PARTNERS, INC. ------------~---------------------------------------------------------------------- 'as

of DECEMBER 31 zo19 are true and corr·ect. I further swear (or affirm) that

neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows:

Notary Public This report "'\* contains (check all applicable boxes): 0 (a) Facing Page. ,f (b) Statement of Financial Condition. (c) Statement of Income (Loss). {d) Statement of Changes in Financial Condition. (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors·· Capital. (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors. (g) Comput ation ofNet Capital. (h) Computation for Determination of Reserve Requirements Pursuant to Rule I5c3-3 . ../ (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3. 0 G) A Reconciliation, including appropriate explanation of the Computation ofNet Capital Under Rule 15c3-l and the Computation for Determination of the Reserve Requirements Under Exhibit A of Rule l5c3-3. 0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of consolidation. ~ (t) An Oath or Affirmation. 0 (m) A copy of the SIPC Supplemental Report. D (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. *\*\*For conditions ofconfidentialtreatment of certain portions ofthisfiling, see section 240.17a-5(e)(3).* 

State~ ofNevadc Cnunty of Clatk:

Signed aod BWml to (or &ftilmed) bebeme ou ~ /3 *LetJ:)O* Ll. *L\_* • J *v* ' .Jv *c.rnt:./ \_\_\_\_* . */* .: -· . (Notary Stamp) ' •

![](_page_1_Picture_9.jpeg)

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# **KILEY PARTNERS, INC.**

Financial Statements For the Year Ended December 31 , 2019 With Report of Independent Registered Public Accounting Firm

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# **RUBIO CPA, PC**  CERTIFIED PUBLIC ACCOUNTANTS

2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770 690-8995 Fax: 770 838-7123

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

To the Stockholder of Kiley Partners, Inc.

#### Opinion on the Financial Statements

We have aud ited the accompanying statement of financial condition of Kiley Partners, Inc. (the "Company") as of December 31 , 2019, the related statements of operations, changes in stockholder's equity, and cash flows for the year then ended and the related notes (collectively referred to as the " financ ial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31,2019, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted **in** the United States of America.

#### Basis for Opinion

These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on t he Company's financial statements based on our audit. We are a public accounting finn registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and a re required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable ru les 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. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financ ial reporting. As part of our audit we are required to obtain an understanding of internal control over financial rep01ting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion.

Our audit included perfonning procedures to assess the risks of material misstatement to the financia l statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included exam ining, on a test basis, evidence regard ing the amounts and disclosures in the financial statements. Our audit a lso 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 of our opinion.

#### Supplemental Information

The information contained in Schedules I, II and Ill has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determining whether the information in Schedules I, II and Ill reconciles to the financial statements or the underly ing accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the 

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information presented in the accompanying schedules. rn forming our opinion on the accompanying schedules, we evaluated whether the supplemental information, inc luding its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the aforementioned supplemental information is fairly stated, in all material respects, in relation to the financial statements as a who le.

We have served as the Company's auditor since 2002.

February 5, 2020 Atlat~ta, Georgia

~ePJ,Pc-

Rubio CPA, PC

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### **KILEY PARTNERS, INC. STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2019**

| Assets                                                                                                                                                                |                                                  |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------|
| Cash<br>Property and equipment, net of accumulated depreciation of \$48,778<br>Deposit with clearing broker<br>Due from clearing broke-r<br>Other assets              | \$<br>235,967<br>103<br>25,307<br>248,495<br>674 |
| Total Assets                                                                                                                                                          | \$<br>510,546                                    |
| Liabilities and Stockholder's Equity                                                                                                                                  |                                                  |
| Liabilities<br>Accounts payable and accrued expenses<br>Commission payable                                                                                            | \$<br>2,497<br>219                               |
| Total Liabilities                                                                                                                                                     | 2,716                                            |
| Stockholder's Equity<br>Common stock, no par value, 2,000 shares authorized,<br>1 00 shares issued and outstanding<br>Retained earnings<br>Total Stockholder's Equity | 507,830<br>507,830                               |
| Total Liabilities and Stockholder's Equity                                                                                                                            | \$<br>510 546                                    |

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### **KILEY PARTNERS, INC. STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31,2019**

| Revenues                                |               |
|-----------------------------------------|---------------|
| Commissions                             | 1,153,482     |
| Trading                                 | 7,653         |
| Interest                                | 2,191         |
| Total revenues                          | 1,163,326     |
| General and Administrative Expenses     |               |
| Commissions, compensation, and benefits | 316,958       |
| IT, data and communications             | 112,485       |
| Clearing costs                          | 38,544        |
| Occupacy and equipment                  | 7,103         |
| Advertising                             | 648           |
| Other                                   | 87,035        |
| Total expenses                          | 562,773       |
| Net Income                              | \$<br>600,553 |

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### **KILEY PARTNERS, INC. STATEMENT OF CHANGES IN STOCKHOLDER'S EQUITY FOR THE YEAR ENDED DECEMBER 31,2019**

| Balance, December 31 , 2018  | \$<br>337,217 |
|------------------------------|---------------|
| Net income                   | 600,553       |
| Distributions to stockholder | (429,940)     |
| Balance, December 31, 2019   | \$<br>507.830 |

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### **KILEY PARTNERS, INC. STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31,2019**

| Cash flows from operating activities:                                             |               |
|-----------------------------------------------------------------------------------|---------------|
| Net income                                                                        | \$<br>600,553 |
| Adjustments to reconcile net income to net cash provided by operating activities: |               |
| Depreciation                                                                      | 930           |
| Change in deposit with clearing broker                                            | (187)         |
| Change in due from clearing broker                                                | (1 ,832)      |
| Change in other assets                                                            | 5             |
| Change in accounts payable and accnued expenses                                   | (2,390)       |
| Change in commissions payable                                                     | (1 ,941)      |
| Net cash provided by operating activities                                         | 595,138       |
| Cash flows from financing activities:                                             |               |
| Distributions to stockholder                                                      | (429,940)     |
| Net cash used by financing activities                                             | (429,940)     |
| Net increase in cash                                                              | 165,198       |
| Cash balance:                                                                     |               |
| Beginning of year                                                                 | 70,769        |
| End of year                                                                       | \$<br>235,967 |

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### **KILEY PARTNERS, INC. NOTES TO FINANCIAL STATEMENTS December 31, 2019**

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

Organization and Description of Business: The Company is a registered broker dealer that began business in 1994. The Company is registered with the Securities and Exchange Commission, the Financial Industry Regulatory Authority and the securities commissions of appropriate states.

The Company's business is retail brokerage of marketable securities for customers located throughout the United States.

Cash: The Company maintains its demand deposit in a high credit quality financial institution. Balances at times may exceed federally insured limits.

Property and Equipment: Property and equipment are recorded at cost. Depreciation is provided by use of straight-line methods over the estimated useful lives of the respective assets. Maintenance and repairs are charged to expense as incurred:; major renewals and betterments are capitalized. When items of property or equipment are sold or retired, the related cost and accumulated depreciation are removed from the accounts and any gain or loss is included in the results of operations.

Income Taxes: The Company has elected to be taxed as an S corporation whereby the income or losses of the Company flow through to its stockholder and no income taxes are recorded in the accompanying financial statements.

Under the provisions of FASB Accounting Standards Codification 740-10, Accounting for Uncertainty in Income Taxes, the Company is required to evaluate each of its tax positions to determine if they are more likely than not to be sustained if the taxing authority examines the respective position. A tax position includes an entity's status, including its status as a pass-through entity, and the decision not to file a return. The Company has evaluated each of its tax positions and has determined that 1110 provision or liability for income taxes is necessary.

Estimates: Management uses estimates and assumptions in preparing financial statements in accordance with generally accepted accounting principles. Those estimates and assumptions affect the reported amounts of assets, liabilities, revenues and expenses. Actual results could vary from the estimates that were assumed in preparing the financial statements.

Securities Transactions: Customer's securities transactions and corresponding trading revenue are recognized on a trade date basis.

Revenue from Contracts with Customers: The Company buys and sells securities on behalf of its customers. Each time a customer enters into a buy or sell transaction, the Company charges a commission. Commissions and related clearing expenses are recorded on the trade date (the date that the Company fills the trade order by finding and contracting with a counterparty and confirms the trade with the customer). The Company believes that the performance obligation is satisfied on the trade date because that is when the underlying financial instrument or purchaser is identified, the pricing is agreed upon and the risks and rewards of ownership of the securities have been transferred to/from the customer.

Date of Management's Review: Subsequent events were evaluated through the date the financial statements were issued.

#### **NOTE B- NET CAPITAL**

The Company, as a registered broker dealer, 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.

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### **KILEY PARTNERS, INC. NOTES TO FINANCIAL STATEMENTS December 31, 2019**

#### **NOTE B- NET CAPITAL- continued**

At December 31 , 201·9, the Company had net capital of \$507,053 which was \$407,053 in excess of its required net capital of \$100,000, and its ratio of aggregate indebtedness to net capital was .005 to 1.0.

#### **NOTE C - RELATED PARTY TRANSACTIONS**

The Company operates from office premises owned by the Stockholder at no cost to the Company. The fair value of the premises provided is considered to be insignificant.

#### **NOTE D - FINANCIAL INSTRUMENTS WITH OFF-BALANCE SHEET CREDIT RISK**

As a securities broker, the Company is engaged in buying and selling securities for a diverse group of individuals and other entities. The Company's transactions are collateralized and are executed with and on behalf of its customers, including other brokers and dealers and other financial institutions.

The Company introduces all customer transactions in securities traded on U.S. securities markets to another firm on a fully disclosed basis. The agreement between the Company and its clearing broker provides that the Company is obligated to assume any exposure related to non-performance by customers or counter parties. The Company monitors clearance and settlement of all customer transactions on a daily basis.

The Company's exposure to credit risk associated with the non-performance of customers and counter parties in fulfilling their contractual obligations pursuant to these securities transactions can be directly impacted by volatile trading markets which may impair the customer's or counter party's ability to satisfy their obligations to the Company. In the event of non-performance, the Company may !be required to purchase or sell financial instruments at unfavorable market prices resulting in a loss to the Company. The Company does not anticipate non-performance by customers and counter parties in the above situations.

In the normal course of business, the Company's customer activities involve the execution, settlement, and financing of various customer securities transactions. These activities may expose the Company to off-balance-sheet-risk in the event the customer or other broker is unable to fulfill its contracted obligations and the Company has to purchase or sell the financial instrument underlying the contract at a loss.

### **NOTE E- RECEIVABLE FROM AND DEPOSIT WITH CLEARING BROKER**

The Company clears certain of its proprietary and customer transactions through another broker-dealer ("clearing broker") on a fully disclosed basis. In accordance with this agreement, the Company is required to maintain a deposit in cash or securities. The deposit is refundable if, and when, the Company ceases doing business with the clearing broker.

Amounts receivable from its clearing broker at December 31 , 2019 consists of funds on deposit in a trading account.

### **NOTE F- CONTINGENCIES**

The Company is subject to litigation in the normal course of business. The Company has no litigation in progress at December 31 , 2019.

### **NOTE G- CONCENTRATION**

During 2019, approximately 99% of the revenue was earned from two customers and their affiliates.

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### KILEY PARTNERS, INC.

### SCHEDULE I COMPUTATION OF NET CAPITAL PURSUANT TO RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION ACT OF 1934 AS OF DECEMBER 31,2019

| Net capital:                                                                                       |                   |
|----------------------------------------------------------------------------------------------------|-------------------|
| Total stockholder's equity                                                                         | \$<br>507,830     |
| Less non-allowable assets:<br>Property and equipment<br>Other assets<br>Total non-allowable assets | 103<br>674<br>777 |
| Net capital before haircuts                                                                        | 507,053           |
| Less haircuts                                                                                      |                   |
| Net capital                                                                                        | 507,053           |
| Minimum net capital required                                                                       | 100,000           |
| Excess net capital                                                                                 | \$<br>407,053     |
| Aggregate indebtedness                                                                             | \$<br>2 716       |
| Percentage of aggregate indebtedness to net capital                                                | 0.54%             |

### RECONCILIATION WITH COMPANY'S COMPUTATION OF NET CAPITAL INCLUDED IN PART IIA OF FORM X-17A-5 AS OF DECEMBER 31, 2019

There is no significant difference between net capital reported in Part I lA of Form X-17 A-5 as of December 31, 2019 and net capital as reported above.

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#### KILEY PARTNERS, INC.

### SCHEDULE II

### COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31, 2019

The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(ii) of the rule.

#### SCHEDULE Ill

### INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF DECEMBER 31 , 2019

The Company is exempt from the provisions of Rule 15c3-3 under the Securities Exchange Act of 1934, pursuant to paragraph (k)(2)(ii) of the rule.

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### **EXEMPTION REPORT SEA RULE 17a-5(d)(4)**

January 15, 2020

RUBIO CPA, PC 900 Circle 75 Parkway Suite 1100 Atlanta, Georgia 30339

To Whom it May Concern:

The below information is designed to meet the Exemption Report criteria pursuant to SEA Rule 17a-5(d)(4):

Kiley Partners, Inc. is a broker/dealer registered with the SEC and FINRA Pursuant to paragraph k(2)(ii) of SEC Rule 15c3-3, the Company is claiming an exemption from SEC Rule 15c3-3 for the fiscal year ended December 31 , 2019.

The Company has met the identified exemption provisions throughout the most recent fiscal year without exception.

The above statement is true and correct to the best of my and the Company's knowledge.

Signed:~

Name: Michael Kiley

Title: CEO

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![](_page_14_Picture_0.jpeg)

Building 2, Suite 1680 Atlanta. GA 30339 Office: 770 690-8995 Fax: 770 838-7123

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

To the Stockholder of Kiley Par1ners, Inc.

We have reviewed management's statements, included in d1e accompanying Broker Dealers Annual Exemption Repor1 in which (I) Kiley Partners, Inc. identified the following provisions of 17 C.F.R. § 15c3-3(k) under which Kiley Partners, Inc. claimed an exemption from 17 C. F. R. § 240. 15c3-3 : (k)(2)(i i) (the "exemption provisions"); and, (2) Kiley Partners, Inc. stated that Kiley Partners, Inc. met the identified exemption provisions throughout the most recent fiscal year without exception. Kiley Partners, Inc.'s 111anagement is responsible for compliance with the exemption provisions and its statements.

Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Kiley Partners, Inc.'s compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.

Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(2)(ii), of Rule 15c3-3 under the Securities Exchange Act of 1934.

February 5, 2020 Atlanta, GA

~Citl'v

Rubio CPA, PC

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# **RUBIO CPA, PC**  CERTIFIED PUBLIC ACCOUNTANTS 2727 Paces Ferry Road SE

Building 2, Suite 1680 Atlanta, GA 30339 Office: 770 690-8995 Fax: 770 838-7123

### **INDEPENDENT ACCOUNTANT'S REPORT ON APPLYING AGREED-UPON PROCEDURES RELATED TO AN ENTITY'S SIPC ASSESSMENT RECONCILIATION**

To the Stockholder of Kiley Partners, 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 and were agreed to by Kiley Prutners, Inc. and the SIPC, solely to assist you and SIPC in evaluating Kiley Partners, Inc.'s compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended December 31 , 2019. Kiley Partners, Inc.'s management . is responsible for its Form SIPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with standards established by the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this repmt. Consequently, we make no representation regarding the sufficiency 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 findings are as follows:

- I) Compared the listed assessment payments in Form S IPC-7 with respective cash disbursement records entries, noting no differences;
- 2) Compared the Total Revenue amount repo11ed on the Annual Audited Repo11 Form X-17 A-5 Part Ill for the year ended December 31 , 2019 with the Total Revenue amount reported in Form SIPC-7 for the year ended December 31 , 2019, noting no differences;
- 3) Compared any adjustments reported in Form SlPC-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.

We were not engaged to and did not conduct an examination or review, the objective of wh ich would be the expression of an opinion or conclusion, respectively, on Kiley Partners, Inc.'s compliance with the applicable instructions of the Form SI PC-7 for the year ended December 31 , 2019. Accordingly, we do not express such an opinion or conclusion. Had we performe·d additional procedures, other matters might have come to our attention that would have been reported to you.

This report is intended solely for the information and use of Kiley Partners, Inc. and the SIIPC and is not intended to be and should not be used by anyone other than these specified par1ies.

February 5, 2020 Atlanta, GA

~ *Cl'll/f?t-*

Rubio CPA, PC

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| SIPC-7         |  |
|----------------|--|
| (36-REV 12/18) |  |

SECURITIES INVESTOR PROTECTION CORPORATION P.O. Box 92185 Washington, D.C. 20090-2185 202-371-8300

General Assessment Reconciliation

![](_page_16_Picture_3.jpeg)

For the fiscal year ended -~~3 -~-----

(Read carefully the instructions in your Working Copy before completing this Form)

### TO BIE FILED BY AILL SIPC MEMBERS WIITH FISCAL YEAR ENDINGS

1. Name of Member, address, Designated Examining Authority , 1934 Act registration no. and month in wh ich fiscal year ends fo r purposes of the audit requ irement of SEC Rule 17a-5:

|       | lo4soso<br>KILEY PARTNERS, INC.<br>16 BEL GIORNO COURT<br>HENDERSON, NV 89011                                                             |    |   | Note: If any of the information shown on the<br>mailing label requires correction, please e-mail<br>any corrections to form@sipc.org and so<br>indicate on the form filed.<br>Name and telephone number of person to<br>contact respecting this form . |
|-------|-------------------------------------------------------------------------------------------------------------------------------------------|----|---|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|       | L                                                                                                                                         | _j |   | Rick Alvarez 770-263-7300                                                                                                                                                                                                                              |
| 2. A. | General Assessment (item 2e from page 2)                                                                                                  |    |   | \$1,694                                                                                                                                                                                                                                                |
| B.    | Less payment made with Sl PC-6 filed (exclude interest)<br>7/20/19                                                                        |    |   |                                                                                                                                                                                                                                                        |
|       | Date Paid                                                                                                                                 |    |   |                                                                                                                                                                                                                                                        |
|       | C. Less prior overpayment applied                                                                                                         |    |   |                                                                                                                                                                                                                                                        |
| D.    | Assessment balance due or (overpayment)                                                                                                   |    |   | 897                                                                                                                                                                                                                                                    |
| E.    | Interest computed on late payment (see instruction E) for ______ days at 20% per annum                                                    |    | 0 |                                                                                                                                                                                                                                                        |
|       | F. Total assessment balance and interest due (or overpayment carried forwa rd )                                                           |    |   |                                                                                                                                                                                                                                                        |
|       | G. PAYMENT:<br>the box<br>Check mailed to P.O. BoxD Funds Wired0<br>ACH[{]\$ __________________<br>897<br>Total (must be same as F above) |    | _ |                                                                                                                                                                                                                                                        |
|       | H. Overpayment carried forward                                                                                                            |    |   |                                                                                                                                                                                                                                                        |
|       |                                                                                                                                           |    |   |                                                                                                                                                                                                                                                        |

3. Subsidiaries (S) and predecessors (P) included in this form (give name and 1934 Act registration number):

| The SIPC member submitting this form and the<br>person by whom it is executed represent thereby<br>that all information contain ed herein is true, correct<br>and complete. | KILEY PARTNERS, INC.<br>f Corporation, Pannership or other organizallon)                                                     |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------|
| ~<br>day of January<br>Dated the 27                                                                                                                                         | (Authorized Signature)<br>CEO                                                                                                |
| ,20                                                                                                                                                                         | (Tille)                                                                                                                      |
| for a period of not less than 6 years, the latest 2 years in an easily accessible place.                                                                                    | This form and tllte assessment payment is due 60 days after the end of the fiscal year. Retain the Working Copy of this form |
|                                                                                                                                                                             |                                                                                                                              |

| a:: Dates:<br>w         |                            |          |                          |                      |
|-------------------------|----------------------------|----------|--------------------------|----------------------|
| 3:                      | Postmarked                 | Received | Reviewed                 |                      |
| w<br>><br>w             | Calculations ___ _         |          | __<br>Documentation<br>_ | ----<br>Forward Copy |
| a::<br>Exceptions:<br>u |                            |          |                          |                      |
| 0<br>Cl)                | Disposition of exceptions: |          |                          |                      |
|                         |                            |          | 1                        |                      |

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### **DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT**

Amounts for the fiscal period beginning ....;1.;..; /1.;..; /1..;. 9 \_\_\_ \_ and ending ..~.-'J2:.w...u. 1/..Li9i!..,\_ \_\_ \_

| Item No.<br>2a. Total revenue (FOCUS Line 12/Part iiA Line 9, Code 4030)                                                                                                                                                                                                                                                                                                                        | Eliminate cents<br>\$1.163,327 |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------|
| 2b. Additions :<br>(1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and<br>predecessors not included above.                                                                                                                                                                                                                                        |                                |
| (2) Net loss from principal transactions in securities in trading accounts.                                                                                                                                                                                                                                                                                                                     |                                |
| (3) Net loss from principal transactions in commodities in trading accounts.                                                                                                                                                                                                                                                                                                                    |                                |
| (4) Interest and dividend expense deducted in determining item 2a.                                                                                                                                                                                                                                                                                                                              |                                |
| (5) Net loss from management of or participation in the underwriting or distribution of securities.                                                                                                                                                                                                                                                                                             |                                |
| (6) Expenses other than advertising, pri nting, registration fees and legal fees deducted in determining net<br>profit from management of or participation in underwriting or distribution of securities.                                                                                                                                                                                       |                                |
| (7) Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                            |                                |
| Total additions                                                                                                                                                                                                                                                                                                                                                                                 | 0                              |
| 2c. Deductions:<br>(1) Revenues from the distribution of shares of a registered open end investment company or unit<br>investment trust, from the sale of variable annu ities, from the business of insurance, from investment<br>advisory services rendered to registered investment compan ies or insurance company separate<br>accounts, and from transactions in security futures products. |                                |
| (2) Revenues from commodity transactions.                                                                                                                                                                                                                                                                                                                                                       |                                |
| (3) Commissions, floor brokerage and clearance paid to other SIPC members in connection with<br>securities transactions.                                                                                                                                                                                                                                                                        | 34,301                         |
| (4) Reimbursements for postage in connection with proxy solicitation.                                                                                                                                                                                                                                                                                                                           |                                |
| (5) Net gain from securities in investment accounts .                                                                                                                                                                                                                                                                                                                                           |                                |
| (6) 100% of commissions and markups earned from transactions in {i) certificates of deposit and<br>(ii) Treasury bills, bankers acceptances or commercial paper that mature nine months or less<br>from issuance date.                                                                                                                                                                          |                                |
| (7) Direct expenses of printing advertising and legal fees incurred in connection with other revenue<br>related to the securities business (revenue defined by Section 16{9)(L) of the Act).                                                                                                                                                                                                    |                                |
| {8) Other revenue not related either directly or indirectly to the secu rities business.<br>{See Instruction C):                                                                                                                                                                                                                                                                                |                                |
| {Deductions in excess of \$100,000 require documentation)                                                                                                                                                                                                                                                                                                                                       |                                |
| {9) {i) Total interest and dividend expense (FOCUS Line 22/PART IIA Line 13,<br>Code 4075 plus line 2b(4) above) but not in excess<br>__________<br>of total interest and dividend income.<br>\$.<br>_                                                                                                                                                                                          |                                |
| ________<br>(ii) 40% of margin interest eamed on customers securities<br>\$<br>_<br>accounts (40% of FOCUS line 5, Code 3960).                                                                                                                                                                                                                                                                  |                                |
| Enter the greater of line (i) or (ii)                                                                                                                                                                                                                                                                                                                                                           | 0                              |
| Total deductions                                                                                                                                                                                                                                                                                                                                                                                | 34,301                         |
| 2d. SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                                                 | \$1,129,026                    |
| 2e. General Assessment@ .0015                                                                                                                                                                                                                                                                                                                                                                   | \$ 1,694                       |
|                                                                                                                                                                                                                                                                                                                                                                                                 | (to page 1, line 2.A.)         |


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