# WINKLEVOSS INSURANCE AGENCY, LLC X-17A-5 (2019-08-29) — Broker-dealer annual report - Company: WINKLEVOSS INSURANCE AGENCY, LLC - Form: X-17A-5 - Filed: 2019-08-29 - Period: 2019-06-30 - Accession: 0000949905-19-000001 - CIK: 949905 - File #: 8-48544 - Material weakness: No - Auditor: Lilling & Company LLP - Auditor location: Port Washington, NY - Contact: Michael Vasile - Phone: 2038615569 - Signed by: Howard Winklevoss (Manager, Chief Compliance) Original filing: https://www.sec.gov/Archives/edgar/data/949905/000094990519000001/wia_crd39081_06302019.pdf --- {0}------------------------------------------------ ## WINKLEVOSS INSURANCE AGENCY, LLC *FINANCIAL STA TEMENTS AND OTllER INFORMATION* *JUNE 30, 2019* {1}------------------------------------------------ UNIH !DSTATl!:S SECUIUTll<:SAND RXCIIANGJ<: COMMISSION W11shington, l>.C. 20549 | | OMB APPROVAL | | |--------------------------|---------------------------|--| | OMB Number: | 3235-0123 | | | Expires: | August 31, 2020 | | | Estimated average burden | | | | | hours oar resoonse 12.00 | | ## **ANNUAL AUDITED REPORT FORM X-17A-5 PART** Ill SEC FILE NUMBER 8--48544 #### FACING PAGE Information Required of Brokers and Dealers Pursuant to Section J 7 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder | REPORT FOR THE PERIOD
HGINNING~ | /91/20 18 | AND ENDING 06/30/2019 - | --- | |-------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|------------------------------|--------------------------------| | | MM/DD/YY | | -
MMfDD/YY | | | A. REGISTRANT IDENTIFICATION | | | | NAME or BROKER-DEALER: Winklevoss Insurance Agency, LLC
ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (L>o not use P.O. Box No.) | | -------
OFFICIAL USE ONLY | | | | | | FIRM l.D. NO. | | Two Greenwich Office Park | | | | | | (No. and Street) | | | | Greenwich | CT | | 06831 | | (City) | (State) | | (Zip Code) | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Mlcllaol VasHo 203-861·5569 | B. ACCOUNTANT IDENTTFICA'I10N | | (Arc• Code - Telephone Number) | | INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained in this Report*
Lilling & Company LLP | | | | | | (Name - if indivld11a/, slule last, Jirst, mlrldli: mun.:) | | | | 2 Seaview Blvd, Suite 200 | Port Washington | NY | 11050 | | (Address) | -~-
(City) | -~-~-~-
(State) | (Zip Code) | | CHECK ONB:
I.JI
a
certified Public Accountant
Public Accountant | | | | | Accountant not resident in United States or any of its possessions. | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | •Cf *aims for exemption from tire l'eq11irement* //101 *the annual repol'I be covered* by *the opinion of an independent public accountant* 11111s1 *be suppol'ted by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.* J *7a-5(e}(2)* > Potential person s who are to respond to the collectlon of Information contained In this form arc not required to respond unless thc form displays a c:urrentlyvalld OMB control number. SEC 1410 (11-05) {2}------------------------------------------------ #### OATH OR AFFIRMATION | 1. Howard Winklevoss | | | , swear (or affirm) that, to the best of | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------|---------------------------|--------------------------------------------------------| | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
Winklevoss Insurance Agency, LLC
~~~~~~~~~~~~~~~~ | ~~~~~~~~~~~~ | | ~~~~~~~
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, as | | of June 30 | 2019 | | ore true and con·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. | | | | | | | | | | | | | | | | | Manager, Chief Compliance | | | •,
/4~1 I I | | Title | | | Ndt8fy Pub lic
This report•• contains (check all applicable b~eH?MM SSION EXPIRF.S q/ 6~ IZL>LiJ
0 (a) Facing Page.
0 (b) Statement of Financial Condition.
0 (c) Statement oflncome (Loss) or, if there is other comprehensive income in the pcriod(s) presented, a Statement
of Comprehensive lucome (as defined 111 §210.
(d) Statement of Changes in Financial Condition.
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(e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
v
(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
§ (g) Computation of Net Capital.
(h) Computallon for Determination of Reserve Requirements Pursuant to Ruic I Sc3-3.
(i) Information Relating to the Possession or Control Requirements Under Rule I 5c3 -3.
0 U) A Reconciliation, including appropriate explanation of the Computation ofNct Capital Under Ruic I Sc3· I and the
Computation for Determination of the Rc~crve Requirements Under Exhibit A of Rule I Sc3·3.
O (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of
consolidation.
§
(I) An Oath or Affirmat ion.
J
(m) A copy of the SIPC Supplc1m:ntal Report. | NOYAllV PVILfC
STATE OF OONNEC'TifJl.T. | 1 ·02 of Regulation S-X). | | | (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. | | | | | **For co11di1io11s of co11jide111ial treat111e11t of cerlai11 porltons of this jili11g. see .tection UO. I 7a-5(e}(3). | | | | {3}------------------------------------------------ # **Lilling & Company** LLP Certified Public Accountants #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors Winklevoss Insurance Agency, LLC Greenwich, Connecticut #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Winklevoss Insurance Agency, LLC as of June 30, 2019, the related statements of operations, changes 1n member's equity, and cash flows, for the year ended June 30, 2019, 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 Winklevoss Insurance Agency, LLC as of June 30. 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 Winklevoss Insurance Agency, LLC's management. Our respons1b1lity is to express an opinion *on* Wmklevoss Insurance Agency, LLC'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 Wmklevoss Insurance Agency, LLC m 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. #### Supplemental Information The Schedule I, Computation of Net Capital Under Rule 15c-3-1 ofthe Securities and Exchange Commission, has been subjected to audit procedures performed in conjunction with the audit of Winklevoss Insurance Agency, LLC's financial statements. The supplemental information is the respons1biltty of Winklevoss Insurance Agency, LLC'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 17a-5. In our opinion, the Schedule I, Computation of Net Capital Under Rule 1 Sc-3-1 of the Securities and Exchange Commission. 1s fairly stated, in all matenal respects. in relation to the financial statements as a whole. Lilhng & Company LLP We have served as Winklevoss Insurance Agency, LLC's auditor since 2009 Port Washington, New York *August 26, 2019* Two Scavicw Boulevard. Port Washington, Y I I 050 • (5 16) 829- 1099 • Fax (516) 829-1065 {4}------------------------------------------------ ## WINKLEVOSS INSURANCE AGENCY, LLC ## *STATEMENT OF FINANCIAL CONDITJON JUNE JO, 2019* #### *ASSETS* | Cash | \$
1,923,366 | |---------------------|-----------------| | Accounts receivable | 529,248 | | Prepaid expenses | 1,286 | | | \$
2,453,900 | ## *LIABILJTIES AND MEMBER 'S EQUITY* #### *Liabilities* | Management fees payable, related party | \$
45,186 | |----------------------------------------|-----------------| | Taxes payable, related party | 104,000 | | Accrued expenses | 174,570 | | | 323,756 | | Member's equity | 2,130,144 | | | 2,453,900
\$ | | | | {5}------------------------------------------------ ## WTNKLEVOSS INSURANCE AGENCY, LLC #### *STATt.'MENT OF OPERATIONS* YEAR *ENDED JUNE* JO, *2019* #### *REVENUES* | Commission income | s 2.866,609 | |--------------------------|-------------| | EXPENSES | | | Commission expense | 654.801 | | Professional Fees | 222.893 | | Salaries and Benefits | 115.074 | | . ettlement Expense | 249.027 | | Rent and Occupancy | 20.371 | | Other Operating Expenses | 110,502 | | | 1,372,668: | | Income before taxes | 1,493,941 | | State Income Taxes | 104,000 | | NET INCOME | s 1,389,941 | {6}------------------------------------------------ ## WINKLRVOSS INSURA CE AGENCY, LLC ## *STATEMENTOF CASll FLOWS YEAR ENDED JUNE 30, 2019* | Caslt flows from operating activities | | |-------------------------------------------------|-----------------| | cl income | s 1,389,941 | | Adjustments to reconcile net income to net cash | | | provided by operating activities: | | | Changes in assets and liabilities: | | | /\ccounts receivable | (38,907) | | Prepaid expenses | 1,584 | | Management fees payable, related party | ( 1,736) | | Taxes payable, related party | 104,000 | | /\ccrucd expenses | (I 04,494) | | Total adjustments | (39,553) | | Net cash provided by operating activities | 1,350,388 | | Cash flows from fina11ci11g activities | | | Distributions to parent | (I .200,000) | | Net cash used in financing activities | (I ,200,000) | | NET CHANGE IN CASI/ | 150,388 | | BEGINNING
CASTI - | 1,772,978 | | CASll-
END | \$
1,923,366 | | | | | Supplemental disclosures of cash flow information: | | |----------------------------------------------------|----| | Cash paid during the year for: | | | Interest expense | \$ | | Income taxes | \$ | | | | {7}------------------------------------------------ ## WINKLfl VOSS INSURANCE AGENCY, LLC ## *STATEMENT OF CllANGES IN MEMBER'S EQUITY* Yl:../1R *ENDED JUNE 30, 2019* | beginning
Balance - | \$ 1,940,203 | |-------------------------|--------------| | Net income | 1,389,941 | | Distributions to Parent | ( 1,200,000) | | end
Balance - | \$ 2,130,144 | {8}------------------------------------------------ ## WINKLEVOS lNSURANCE AGENCY, LLC ## NOTES TO */"INANCIAL* STATEMENTS *JUNE 30, 2019* ### 1. ORGANIZATION AND l"ATURK OF BU I rESS ## Organization Winklcvoss Insurance Agency, LLC (the "Company") is a Delaware limited liability company and is a limited broker-dealer registered with the Financial Industry Regulatory Authority (FTNRA) and the Securities Exchange Commission. The Company is a licensed insurance agency in the business of advising corporations, banks and other persons in the private placement of variable life insurance products and securities. The Company, as a non-clearing broker, docs not handle customers' funds or securities. There were no liabilities subordinated to claims of general creditors during the year ended June 30, 2019. The Company is wholly owned by Winklcvoss LLC, a limited liability company which in tum is wholly owned by Winklevoss Consultants Inc .. an S Corporation. #### 2. SUMMARY OF JG IFICANT ACCOUNTING POLICIES #### Basis of Presentation The accompanying financial statements have been prepared on the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America. #### Revenue Recognition Effective July I, 2018, the Company adopted ASC Topic 606, Revenue from Contracts with Customers ("·ASC Topic 606"). The new 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 in exchange for those goods or services. The guidance requires an entity to follow a five step model to (a) identify the contraet(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 obligations in the contract, and (e) recognize revenue when (or as) the entity satisfies a performance obligation. The Company adopted the guidance using the modified retrospective method for all contracts, which requires a cumulative effect adjustment upon adoption. The Company concluded that there was no material impact to the recognition and measurement of its contracts with its customers upon adoption, and therefore, no adjustment to beginning equity as of July 1, 2018 was required. The Company's principal source of revenue is commissions earned from the sale of variable life and variable annuity insurance products ('·insurance products''). The Company has a single performance obligation to sell the variable life and variable annuity products defined {9}------------------------------------------------ ## WINKLEVOSS I SURANCE AGENCY, LLC ## *NOTES TO FINANCIAL STATEMENTS JUNE 30, 2019* in each contract. The pcrfonnance obligation is satisfied al the time of the ~ale of each individual insurance product, but the amount to be received for selling commissions is uncertain, as it is dependent on the value of the underlying separate account values at future points in time as well as the length of time the investor holds the insurance policy, both of which are highly susceptible lo factors outside the Company's influence. The Company docs not believe that it can overcome this constraint until the value of the underlying separate account values and the investor activities arc known, which is generally on a monthly or quarterly basis. The Company"s revenue is primarily received from two client contracts. one with three policy holders and associated life insurance policies and the other consisting of approximately I 00 underlying accounts for annuity insurance policies. #### Accounts Receivable Accounts receivable is recorded at amounts billed and presented on the statement of financial condition net of allowance for douhtfol accounts, if applicable. The allowance is dctennincd by a variety of factors, including the age of the receivables, current economic conditions. historical losses and other information management obtains regarding the financial condition of its clients. The policy for determining the past due status of receivables is based on how recently payments have been received. Receivables arc charged off when they are deemed uncollcctiblc, which may arise when the client is deemed unable to pay the amounts owed to the Company. At June 30, 2019, the Company determined that an allowance for doubtful accounts was nut required. The accounts receivable of \$529 ,248 at June 30, 20 I 9 is due from two clients. #### Income Taxes The Company operates as a limited liability company and as such is treated as a disregarded entity for income tax purposes. J\11 taxahlc income and expenses arc reported by the single owner-member company, Winklcvoss LLC (which then reports its combined taxable income/loss to its corporate parent, Winklevoss Consultants Inc.). Therefore, no provision for federal income taxes is required. The Company is subject to the State of Connecticut Pass-Through Entity Tax which the Company recognizes as if it filed on a separate return basis and the amount of the current tax or benefit calculated is either remitted to or received from the Parent. The amount of current and deferred taxes payable or refundable is recogni:tcd as of the date of the financial statements, utilizing currently enacted tax laws and rates. Deferred tax expenses or benefits arc recognized in the financial statements for the changes in deferred tax liabilities or assets between years if applicable. The Company has accrued \$I 04,000 of state income taxes for the year ended June 30, 2019. which is included in State Income {10}------------------------------------------------ ## WINKLEVOSS INSURANCE AGENC Y, LLC ## *NOTES TO FINANCIAL S TATEMJ:.'NTS JUNE 30, 2019* Taxes in the tatement of Operations. The Company recogni1cs the effect of tax positions only when they arc more likely than not to be sustained. Management has determined that the Company had no uncertain tax positions that would require recognition or disclosure. The Company operates in the Unjted States and in state and local jurisdictions, and the previous three years remain subject to examination by tax authori tics. There arc presently no ongoing income tax examinations. #### Concentration of Risk The Company's revenue is earned primarily from two clients. One client accounted for approximately 68% of total revenue and another client was approximately 31 % of total revenue. #### Cash Cash consists of cash in banksJ held at one financial institution and at times may exceed federally insured limits. The maximum insurable limit on cash deposits is \$250,000. Cash in excess of the insurable limit was \$1,673,366 as of June 30, 2019. The Company reduces its exposure to credit risk by depositing its cash with high credit-quality financial institutions. Management believes that the credit risk of the uninsured portion is remote. #### Estimates Management of the Company uses estimates and assurnpti.ons in preparing financial statements in accordance with accounting principles generally accepted in the United States of America. Those estimates and assumptions affect the reported amounts of assets and liabilities, the disclosure of contingent assets and liabilities, and the reported revenues and expenses. Actual results could vary from the estimates management uses. #### 3. REL/\ TED PARTY TRANSACTIONS The Company is party to a management agreement with Winklcvoss LLC. The agreement states that sig,illficant management infrastructure. and operating expenses are to be provided by WinkJcvoss LLC and billed to the Company as a quarterly management f cc. Allocation of the shared expenses inc\.1rrcd by Winklevoss LLC to the Company is based on management estimates or the utility derived by each or the respective companies using primarily employee work hours and gross revenues allocation factors. Management believes this fomrnla reasonably rcOccts the allocation of operating expenses between the Company and Winklcvoss LLC. J\t June 30, 2019. the management fees payable, related party balance was \$45, 186 as presented in the Statement of Financial Condition and is due on demand without interest. {11}------------------------------------------------ ## WINKLEVOSS INSURANCE AGE C Y, LLC ## *NOTES TO FINANCIAL STA TEME1VTS JUNE 30, 2019* Dming the year ended June 30, 2019, the company incun-cd \$185,579 of expenses under the management agreement, which is included in the following categories in the Statement of Operations: | \$1
15,074 | |---------------| | 20.371 | | 50,134 | | \$18
-79 | | | #### 4. LEGAL MATTERS In the ordinary course or business, the Company is subject to litigation relating to its activities as a broker-dealer including civil actions and arbitration. In July 2017, an independent registered representative ftled an arbitration claim against the Company. The Company recorded a settlement expense of \$100,000 for the year ended June 30, 2018 for the anticipaucd cost to resolve this matter. The arbitration panel issued a decision on 'ovcmbcr 2. 2018 which called for a payment of \$349,027 by the Company to the claimant. Accordingly, the Company recorded a settlement expense of \$249,027 for the year ended June 30. 2019. The decision also called for ongoing quarterly payments to the claimant of a percentage of a certain, limited book of business. These amounts arc included in commission expense on the Statement of Operations. ## S. COMPUTATION FOR DETERMINATIO OF RESKRVE REQUIREMENTS FOR BROKER AND DEALER PUR UA T TO RULE 1Sc3-3 The Company is exempt from the provisions of Ruic 15c3-3 under the Securities Exchange Act of 1934, in that the Company's activities arc limited to those set forth in the conditions for exemption appearing in paragraph (k) (1) of the Rule. #### 6. NET CAPITAL REQUIREMENT The Company is subje<.:t to the Securities and Exchange Commission Uniform ct Capital Ruic (Ruic l 5c-3-1 ), which requires the maintenance or minimmn net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1 (and that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1). At June 30, 2019. the Company had net capital of \$2, 128,858, which was \$2.107.273 in excess of its required net capital of \$21 ,585. The Company had a percentage of aggregate jndcbtcdncss to net capital of 15.2% as of June 30, 2019. {12}------------------------------------------------ ## WINKLEVOSS INSURANCE AGENCY, LLC ## *NOTES TO FINA CJAL STATEMENTS JUNE 30, 2019* ### 7. SUBSEQUENT EV~ NTS The Company has performed an evaluation of events that have occurred subsequent to June 30, 2019, and through /\.ugust 26. 2019, the date of the filing or this report. There have been no material subsequent events that occurred during such period that would require disclosure in this report or would be required to be recognized in the financial statements as of June 30, 2019. {13}------------------------------------------------ *Supplementary Informatio11 Pursuant to Rule 17a-5 o/the Securities Exchange Act of 1934* As *of June 30, 2019* {14}------------------------------------------------ ## WJNKLEVOSS I SURANCE AGE CY, LLC ## *COMPUTATION OF NET CAPITAL UNDl!.'R RULE 15c-3-J OF THE SECURITIES AND t.XCTIANGE COMMISSION JUNE 30, 2019* ## *NET CAPITAL* | Member's equity | \$ 2,130,144 | |---------------------------------------------------------------------------------------------------------------------------------------------------|------------------| | Deductions and/or charges: | | | Non-allowable assets | 1,286 | | Net capital before haircuts on securities positions | 2,128,858 | | Haircuts and undue concentration | | | NET CAPITAL | \$ 2,128,858 | | AGGREGATE INDEBTEDNESS | £
323,756 | | MINIMUM DOLLAR NET CAPT/AL REQUIREMENT | \$
5,000 | | MINIMUM NET CAPTIAL REQUIRED (6 213 % of A.I.) | \$
2
1,585 | | h.XCESS OF NET C'APITAL OVER MINIMUM | | | REQUIREMENTS | \$ 2,107,273 | | PERCt.'"NTAGE OF AGGREGATE INDEBTEDNESS | | | TO NET CAPITAL | 15.2% | | Below arc the following diff ercnces between the above computation and the Company's
unaudited Form X-17 A-5 for the year ended June 30, 2019. | | | | | | Net capital per the unaudited Form X-171\-5 | \$ 2,232,858 | | DcL:rcase in net capital due to adjusting journal entries: | | Taxes payable. related party Net capital per above computation (104,000) \$ 2, 128,858 {15}------------------------------------------------ ## **Lilling & Company LLP** Ccrti lied Public Accountants #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ~~ ~~~~~~~~~~~ To the Board of Directors Winklevoss Insurance Agency, LLC Greenwich, Connecticut We have reviewed management's statements. included in the accompanying Exemption Report, in which (1) W1nklevoss Insurance Agency, LLC identified the following provisions of 17 C.F.R. §15c3-3(k) under which Winklevoss Insurance Agency, LLC claimed an exemption from 17 C.F.R. §240.15c3-3:(k)(1). (exemption provisions) and (2) Winklevoss Insurance Agency, LLC stated that Winklevoss Insurance Agency, LLC met the 1dent1fied exemption provisions throughout the most recent fiscal year without exception. Winklevoss Insurance Agency, LLC's management 1s 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 1nqumes and other required procedures to obtain evidence about Winklevoss Insurance Agency, LLC'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)(1 ), of Rule 15c3-3 under the Securities Exchange Act of 1934. CERTIFIED PUBLJC ACCOUNTANTS *Port Washington, Ne w York August 26, 2019* {16}------------------------------------------------ Exemption Report Year Ended June 30, 2019 To the best of our knowledge and belief, - I. Winklevoss Insurance Agency, LLC is exempt under the provisions of paragraph (k) (I) of SEC Rule I 5c3-3: - 2. Winklevoss Insurance Agency, LLC met the identified exemption provisions in paragraph (k)( I) of ScC Ruic I 5c3-3 throughout the most recent fiscal year without exception. Howard Winklcvoss Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.