# UBS FUND SERVICES (USA) LLC X-17A-5 (2020-02-28) — Broker-dealer annual report - Company: UBS FUND SERVICES (USA) LLC - Form: X-17A-5 - Filed: 2020-02-28 - Period: 2019-12-31 - Accession: 0001022465-20-000005 - CIK: 1022465 - File #: 8-49596 - Material weakness: No - Auditor: EY, Ernst & Young - Auditor location: Chicago, IL - Contact: Karen Hu - Phone: 3125256103 - Website: ubs.com - Signed by: Kathleen Horan (FINOP Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1022465/000102246520000005/2019SECfilingFS2.pdf --- {0}------------------------------------------------ ### FINANCIAL STATEMENTS AND S U PPLEMENTARY l N fORMA T IO N UBS Fund Services (USA) LLC Year Ended December 31, 2019 With Report of Independent Registered Public AccoU1nting Firm {1}------------------------------------------------ **UNll'EDSTATFS SECURITIESANDEXCHANGECO~ON Washington,D.C. 20549** 0MB APPROVAL 0MB Number: 323S-0123 Expires: August 31, 2020 Estimated average burden hours nse •....• 12.00 # **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill** | SEC FILE NUMBER | |-----------------| | | | &-49596 | **FACING PAGE** Infonnation Required of Brokers and Dealen Pursuant to Section 17 of the **Securities Exchange Act of 1934 and Rule 17a-S Thereunder** | | REPORT FOR THE PERIOD BEGINNING 01 /01/19 | AND ENDING 12/31/19 | ----------- | | |---------------------------------------------------------------------------------------------------|--------------------------------------------------------|---------------------|--------------------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: UBS Fund Services (USA) LLC | | | OFACIAL USE ONLY | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | ARM I.D. NO. | | | 1 O State House Square | | | | | | | (No. ancl Street) | | | | | Hartford | CT | 06103 | | | | (City) | (State) | (Zip Code) | | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO TIIlS REPORT | | | 201-352~20 | | | | | | (Area Code - Telephone Number) | | | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*
EY, Ernst & Young LLP | (Name - ifindiYidwzl. slate ftul. first. Rliddfe name) | | | | | 155 North Wacker Drive | Chicago | IL | 60606-1787 | | | (Address) | (City) | (State) | (Zip Code) | | *must be supported by a statement of facu and cirCMmstances relied on as the basis/or the exemption. See Section Z40.17a-J(e)(2)* **Potential persons who are ta respond to the collection of information contained in this form are not required to respond unlasstheformdlsplaysacunentlyvalidOMBconlrolnumber.** SEC 1410 (11-05} {2}------------------------------------------------ #### **OATH OR AJ'FIRMA TION** | I, Kathleen Horan | | , swear (or affirm) that, to the best of | | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|-----------------------------------------------------------------------------------------------------------------------------------|--| | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
, as
UBS Fund Services (USA) LLC | | | | | of February 28 | 20 20 | are true and correct. I further swear (or affirm) that | | | neither the company nor any partner, proprietor, principal offiliiCr or director has any proprietary interest in any account | | | | | classified solely as that of a customer, except as follows: | | | | | | | | | | ~ | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | FINOP Officer | | | | | Title | | | | | | | | | | IERNADEffE C. PEHRSON | | | | | NOTMYPUalCOF NEW .HfEi | | | report•• contains {check all applicable boxes):
This
0
(a) Facing Page. | | lliCanmllllon Explrll2117W | | | 0
(b) Statement of Financial Condition. | | | | | I{] (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement | | | | | of Comprehensive Income ( as defined in §210 .1-02 of Regulation S-X).
D (d) Statement of Changes in Financial Condition. | | | | | @ (e) Statement of Changes in Stock.holders' Equity or Partners' or Sole Proprietors' Capital. | | | | | D (t) Statement of Changes in Liabilities Subordinated to Oaims of Creditors. | | | | | (g) Computation of Net Capital. | | | | | (h) Computation for Determination of Reserve Requirements Pursuant to Ruic 15c3-3.
(i) Information Relating to the Possession or Control Requirements Under Rule l5c3-3.
~ | | | | | D (j) A Reconciliation, including appropriate explanation ofthe Computation of Net Capital Under Rule 15c3-l and the | | | | | Computation for Detennination of the Reserve Requirements Under Exhibit A of Rule 15c3~3. | | | | | D (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of | | | | | consolidation.
0 (l} An Oath or Affirmation. | | | | | @ (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 of confidential treatment of certain portions .of this filing, see section 2 40.17 a-5 (e)(3). | | | | | | | | | | | | | | {3}------------------------------------------------ # Financial Statements and Supplementary Information Year Ended December 3 1, 2019 # **Contents** | Report of lndependent Registered Public AccouHting Finn I | | |---------------------------------------------------------------------------------------------------------------------------------------------|--| | Financial Statements | | | Statement of Financial Condition 2 | | | Sta cement of Operations 3 | | | Statement of Changes in Members' Capital 4 | | | Statement of Cash Flows 5 | | | Notes to Financial Statements 6 | | | Supplementary Infonnation | | | Computation of Net Capital for Brokers and Dealers Pursuant to Rule
Schedule I -
15c3-l Under the Securities Exchange Act of 1934 10 | | | Detail of Non-Allowable Assets 11
Schedule II - | | | Computation for Determination of P AB Account and Reserve
Schedule III - | | | Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 Under the | | | Securities Exchange Act of 1934 and Information Relating to Possession or Control | | | Requirements for Brokers and Dealers Pursuant to Rule l 5c3-3 Under the | | | Securities Exchange Act of 1934
12 | | {4}------------------------------------------------ #### Report of Independent Registered Public Accounting Firm To the Member and Management of UBS Fund Services (USA) LLC #### **Opinion** on the Financial StatfJments We have audited the accompanying statement of financial condition of UBS Fund Services (USA) LLC (the Company) as of December 31 , 2019, the related statements of operations, changes in members' capital and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements·). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company at December 31, 2019, and the results of its operations and its cash flows for the year then ended in conformity with U.S. generally aocepted accounting principles. #### **Basis** for Opinion These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audit We are a public ~ccounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit 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 accompanying 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. Such information is the responsibility of the Company's management. Our audit procedures included determining whether the infonnation reconciles to the financial statements or the underlying accounting and other records, as applicable, and perfom,ing procedures to test the completeness and accuracy of the information. In forming our opinion on the information, we evaluated whether such information, including its form and content, is presented in conformity with Rule 17a•5 under the Securities Exchange Act of 1934. In our opinion, the infom,ation is fairly stated, in all material respects, in relation to the financial statements as a whole. ~,..£ • 4to *l.* L ~ We have served as the Company's auditor since at least 2000, but were unable to determine the specific year. {5}------------------------------------------------ ## Statement of Financial Condition December 31 , 2019 | Assets | | | |-------------------------------------------------------------------------------------------|----|------------------| | Cash | | 109,201 | | Prepaid expenses | | 45,842 | | Due from affiliate | | 32,972 | | FfNRA deposits | | 3,752 | | Total assets | \$ | 191,767 | | Liabilities and member's capital
Liabilities:
Accrued expenses
Total liabilities | \$ | 37,540
37,540 | | Member's capital | | 154,227 | | Total liabilities and member's capital | s | 19
1.767 | | | | | {6}------------------------------------------------ ### Statement of Operations ### Year Ended December 31 , 2019 | Revenues | | |----------------------------------------------------------|---------------------| | Allocated registered representatives revenue -
Realty | \$
2,479,84
1 | | Service fee income -
Realty | 100,000 | | Interest income | 24 | | Total revenues | 2,579,865 | | Expenses | | | Allocated registered representatives costs -
Realty | 2,479,841 | | Registration fees | 52,330 | | Professional fees | ,540
31 | | General and administrative expenses | 12,666 | | Total expenses | 2,576,377 | | Net income | \$
3 488 | {7}------------------------------------------------ ## Statement of Changes in Members' Capita] #### Year Ended Dec ember 31, 20 I 9 | | | Members'
Capital - Realt- | | Members'
Capital - ARI | | Total | |----------------------------------------------------|---|------------------------------|---|-----------------------------------------------------|---|-------------| | Balance at January 1, 2019 | S | 220,440 | s | 2,228 | s | 222,668 | | Net income | | 3,488 | | | | 3,488 | | Dividend paid | | (71,210) | | (719) | | (71,929) | | Member interest transferred due to merger (note I) | | 1,509 | | (1 ,509) | | | | Balance at December 31
, 2019 | | 154.227 | s | -
====S ==:::::::::::::::::====================1 | s | 5=4=.2=2=7= | {8}------------------------------------------------ ## Statement of Cash Flows Year Ended December 31 , 2019 | Operating activities | | | |-------------------------------------------------|----|---------------| | Net income | \$ | 3,488 | | Adjustments to reconcile net income to net cash | | | | used in operating activities: | | | | Changes in assets and liabilities: | | | | Prepaid expenses | | (3,456) | | Due from affiliate | | (32,972) | | FINRA deposits | | 827 | | Accrued expenses | | (6,542) | | Net cash used in operating activities | | (38,655) | | Financing activities | | | | Dividend paid | | (7
1,929) | | Cash used in financing activities | | (71,929) | | Net change in cash | | (1
10,584) | | Cash at beginning of year | | 219,785 | | Cash at end of year | S | 109,201 | | | | | {9}------------------------------------------------ ## Notes to Financial Statements Year Ended December 31 , 2019 ## **1. Organization and Nature of the Business** UBS Fund Services (USA) LLC (Fund Services) is organized as a Delaware limited liability company and is primarily engaged in the d1stribution of private investment offerings to institutional investors. Fund Services is a broker-dealer registered under the Securities and Exchange Act of 1934 and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA). UBS Realty Investors LLC (Realty), a Massachusetts limited liability company, holds a I 00% member interest in Fund Services as of D~ember 31, 2019, As of December 31 1 20181 Realty held a 99% member interest, ARJ Acquisition Corporation (ARI), a Massachusetts corporation, held the remaining 1% member interest. On December 31 , 2019, ARI merged into UBS Americas Inc., a Delaware incorporated company. The 1 % member interest was transferred to Realty as of December 31 , 2019 prior to the merger. Realty and UBS Americas Inc. are both indirect, wholly owned subsidiaries of UBS AG (UBS). Fund Services has transactions and relationships with Realty that materially affect its operating results and financial position (see Note 3). ## **2. Summary of Significant Accounting Policies** ## **Use of Estimates** The financial statements have been prepared in accordance with U.S. generally accepted accounting principles (US GAAP). The preparation of these financial statements requires management to make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. Actual results could differ from those estimates. ## **Cash** Cash includes an interest-bearing deposit account at a non-affiliated bank. ## **Revenue Recognition** Service fee income is recognized as revenue when services are performed. Allocated registered representatives revenue represents revenue allocated to Fund Services from Realty pursuant to an existing services and expense sharing agreement with Realty. The allocated revenue equals the allocated registered representative costs. See Note 3 for further detail. {10}------------------------------------------------ ## Notes to Financial Statements ( continued) ## **2. Summary of Significant Accounting Policies (continued)** The below table includes revenues wbich are impacted by financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) Topic 606 and it includes only those contracts with customers that are in scope of ASC Topic 606, *Revenue from Contracts with Customers.* ## *Disaggregation of Revenue from Contracts with Customers* | Service fee income -
Realty | \$
100,000 | |--------------------------------|---------------| | Total | \$
100,000 | ### **Income Taxes** Fund Services was bistoricaJly treated as a partnership for U.S. federal, state , and locaJ income tax purposes. As such, Fund Services did not provide for or pay any U.S. federal income taxes. All income, expense, gain, or loss of Fund Services flowed through to its members and was allocated in accordance with the LLC agreement and related tax law. Generally, the federal, state, and local income tax on such income was provided for and reported by each member. Fund Services did not have any filing requirements in any states that assess entity level taxes on partnerships. During 2019, as a result of the merger discussed in Note 1, Fund Services became a disregarded entity for U.S. federal, state and local income tax purposes as a wholly owned subsidiary of UBS Americas Inc. As such, Fund Services does not provide for or pay any U.S. federal or state income taxes. All income, expense, gain or loss of Fund Services flows through to the UBS Americas Inc. As of December 31 , 2019, Fund Services has determined that it has no material uncenain tax positions, interest, or penalties as defined in ASC Topic 740, and accordingly, Fund Services has concluded that no additional disclosures are required. ### **Accounting Developments** ### **Adopted in 2019** In February 20 l 6, the F ASB issued Accounting Standards Update (ASU) 20 I 6-02, *Leases.* **The** standard substantially changes how lessees must account for operating lease commitments, {11}------------------------------------------------ ## Notes to Financial Statements ( continued) ## 2. Summary of Significant Accounting Policie~ (continued) requiring a lease liability with a corresponding right-of-use asset to be recognized on the balance sheet, compared with the current off-balance sheet treatment of such leases. Fund Services adopted ASU 2016-02 as of January I, 2019. Upon adoption, the assets and liabilities of Fund Services were not impacted as Fund Services is not a lessee to any leases. ## **Pending Adoption** In June 2016, the FASB issued ASU 2016-13, *Flnancial Jnstntments* - *Credit Losses {Topic 326) Measurement of Credit l osses* 011 *Financial Instmments.* The amendment replac;:es existing incurred loss impairment guidance and introduces a new credit loss model; the Current Expected Credit Losses model (CECL), which requires earlier recognition of credit losses. The CECL model requires the measurement of all expected credit losses for fmancial assets carried at amortized cost based on historical experience, current conditions and reasonable and supportable forecasts over the full remaining expected life of the financial assets. Fund Services will adopt the amendment on January 1, 2020. Upon adoption, Fund Services will not be impacted as it does not hold any financial instruments. In December 2019, the FASB issued ASU 2019-12, providing guidance that simplifies the accounting for income taxes by eliminating certain exceptions to ASC 740 related to, among other things, the approach for intra-period tax allocation, the methodology for calculating income taxes in an interim period and the recognition of deferred tax liabilities for outside basis differences, and other codification improvements. In addition, ASU 2019-12 specifies that an entity is not required to allocate the consolidated. amount of current and deferred tax expense to a legal entity that is not subject to tax in its separate financial statements. However, an entity may elect to do so (on an entity-by-entity basis) for a legal entity that is both not subject to tax and disregarded by the taxing authority. ASU 20 I 9-12 is effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2020. Early adoption of the amendments is permitted. The Company is presently evaluating the effect of ASU 2019- 12, and expects no material impact to its financial statements. ## **3. Related-Party Transactions** Fund Services has entered into a Services Agreement (the Agreement) with Realty to provide certain administrative, operating, and other ~upport services to Realty as need.ed for the distribution of private investment offerings to im..stitutional investors for the greater of S l 00,000 or a fee based on quarterly deposits into sponsored funds. For the year ended December 31 , 2019, the \$100,000 of service fee income included in the accompanying statement of operations {12}------------------------------------------------ ## Notes to Financial Statements ( continued) ## 3. Related-Party Transactions (continued) was earned from ReaJty under the Agreement. As of December 31, 2019, \$32,972 of service fee income is included in the due from affiliate on the statement of financial condition. In addition, the registered representatives of Fund Services (Representatives) are supervised persons of Realty. Although the primary business activities of such individuals relate to the investment advisory activities of Realty, Realty and Fund Services have agreed that certain costs associated with these Representatives will be allocated to Fund Services. Realty bas also agreed to allocate revenues to Fund Services in an amount equal to these costs. The costs include facilities and other occupancy and information technology expenses, salary and employee benefit expenses, and other general and administrative expenses. ## **4. Professional Fees** During the year ended December 31, 2019, Fund Services recorded a reversal of \$6,000 related to accrued Anti-Money Laundering {AML) audit fees as a result of the change for AML audits to be perfonned internally by UBS internal audit. The amount recorded for the reversal is included within professional fees io the statement of operations. ## **5. Net Capital Requirements** Fund Services is a limited broker-dealer pursuant to Securities and Exchange Commission (SEC) Rule l 5c3-l{a){2)(vi). This rule requires the maintenance of minimum net capital of the greater of \$5,000 or 6 2/3% of aggregate indebtedness, as defined in the rule. As of December 3 I, 20 I 9, Fund Services' net capital, *as* defined, was \$71,661, which exceeded the minimum net capital required by S66,661. Dividend payments, equity withdrawals, and advances are subject to certain notification and other provisions of the net capital rules of the SEC and other regulatory bodies. ## **6. Subsequent Events** Fund Services is required by accounting literature (ASC 855, Subseque111 Events) to evaluate whether events occurring after the statement of financial condition date but before the date the statement of financial condition is issued require accounting as of the statement of financial condition date or disclosure in the financial statements. Fund Services has evaluated all subsequent events through the date of issuance of the financial statements and determined that no such events have occurred. {13}------------------------------------------------ Supplementary Information {14}------------------------------------------------ ## Schedule I # Computation of Net Capital for Brokers and Dealers Pursuant to Rule 15c3-l Under the Securities Exchange Act of 1934 ### December 31, 2019 | Member's capital
Less non-allowable assets (see schedule on fo11owing page) | \$
154,227
(82,566) | |--------------------------------------------------------------------------------|---------------------------| | Net capital | \$
71,661 | | Aggregate indebtedness | \$
37,540 | | Net capital requirement (greater of S5,000 or 6 2/3% of | | | aggregate indebtedness of S37,540) | \$
5,000 | | Excess net capital | \$
66,661 | There are no material differences between the above computation of net capital pursuant to Rule l 5c3-I and the corresponding computation included in the Fund Services' December 31 , 2019, unaudited Part IIA FOCUS Report, as filed on January 27, 2020. {15}------------------------------------------------ ## Schedule II # Detail of Non-Allowable Assets #### December 3 l, 2019 | Non-allowable assets: | | |-----------------------|--------------| | Prepaid expenses | \$
45,842 | | Due from affiliate | 32,972 | | FINRA deposits | 3,752 | | Total | \$
82,566 | {16}------------------------------------------------ ## Schedule Ill Computation for Determination of P AB Account and Reserve Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 Under the Securities Exchange Act of 1934 and Information Relating to Possession or Control Requirements for Brokers and Dealers Pursuant to Rule l 5c3-3 Under the Securities Exchange Act ofl934 December 31, 2019 The activities of Fund Services are limited to those prescribed in subparagraph (k:)(2)(i) of the Securities Exchange Act of I 934 Rule I 5c3-3, which provides exemption from such rule. {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) **UBS** One fllorth Wacker Drive Chicago IL 60606 Tel. +1-312-525 7100 www.ubs.com ## UBS F'litld Semces (USA) LLC ## Exemption Report December 31, 2019 UBS Fund Services (USA) LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C,F.R. §240. l 7a-5, "Reports to be made by certain brokers and dealers"). lbis Exemption Report was prepared as required by 17 C.F.R. § 240.l 7a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states tbe following: (1) The Company claimed an exemption from 17 C.F.R. § 240.15c3-3 under the provisions of 17 C.F .R. § 240.15c3-3 (k)(2Xi). (2) The Company met the identified exemption provisions in 17 C.F .R. § 240. l 5c3- 3(k) for the period from January 1, 2019 through Dt;cembu 31, 2019 without exception. UBS Fund Services (USA) LLC I, Kathleen Horan, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. By: w'-.}M\_M'/~· Title:: P February 28, 2020 {18}------------------------------------------------ ### **Report of Independent Registered Public Accounting Finn** The Management of UBS Fund Services (USA) LLC We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) UBS Fund Services (USA) LLC {the Company) identified the following provisions of 17 C.F.R. § 15c3-3(k) under which the Company claimed an exemption from 17 C.F.R. § 240.15c3-3 (k): (2)(i) (the "exemption provisions") and (2) the Company stated that it met the identified exemption provisions in 17 C.F.R. § 240.15c3-3 {k) throughout the most recent fiscal year ended December 31 , 2019 without exception. Management 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 the Company'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 paragra~h (k)(2)(i) of Rule 15c3-3 under the Securities Exchange Act of 1934. This report is intended solely for the information and use of management, the SEC, FINRA, other regulatory agencies that rely on Rule 17a-5 under the Securities Exchange Act of 1934 in their regulation of registered brokers and dealers, and other recipients specified by Rule 17a-5(d}(6) and is not intended to be and should not be used by anyone other than these specified parties. Chicago, Illinois February 28, 2020 {19}------------------------------------------------ #### **Report of Independent Registered Public Accounting Firm on Applying Agreed-Upon Procedures** To the Management of UBS Fund Services (USA) LLC: We have performed the procedures enumerated below, which were agreed to by management of UBS Fund Services (USA) LLC (the Company) and the Securities Investor Protection Corporation (SIPC), as set forth in the Series 600 Rules of SIPC, solely to assist the specified parties in evaluating the Company's schedule of assessments and payments is in accordance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the fiscal year ended December 31, 2019. The Company's management is responsible for the Company's compliance with those requirements. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures enumerated 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: 1. Compared the assessment payments made in accordance with the General Assessment Payment Form (Form SIPC-6) and applied to the General Assessment calculation on Form SIPC-7 with respective cash disbLrSement record. No findings were found as a result of applying the procedure. 2. Compared the amounts reported in the audited financial statements required by SEC Rule 17a-5 with the amounts reported in Form SIPC-7 for the fiscal year ended December 31, 2019. No findings were found as a result of applying the procedure. 3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers supporting the adjustments. No findings were found as a result of applying the procedure. 4. Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the schedules and working papers supporting the adjustments. No findings were found as a result of applying the procedure. 5. Compared the amount of any overpayment applied with the Form SJPC-7 on which it was computed. No findings were found as a result of applying the procedure. {20}------------------------------------------------ This agreed-upon procedures engagement was conducted 1n accordance with the interim attestation standards of the Public Company Accounting Oversight Board (United States) and the attestation standards established by the American Institute of Certified Public Accountants. We were not engaged to and did not conduct an examination or a review, the objective of which would be the expression of an opinion or conclusion, respectively, on whether UBS Fund Services (USA) LLC's schedule of assessments and payments is in accordance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the fiscal year ended December 31, 2018. Accordingly, we do not exp~ess such an opinion. Had we performed additional procedures, other matter.s might have come to our attention that would have been reported to you. This report is intended solely for the information and use of the specified parties listed above and is not intended to be and should not be used by anyone other than these specified parties. Chicago, Illinois February 28, 2020 {21}------------------------------------------------ | 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 | SIPC-7 | |----------------| | (36-REV 12/18) | For the fiscal year ended \_ 2\_0\_1\_9 \_\_\_ \_ (Read carefully the instructions in your Working Copy before completing this Form) #### TO BE FILED BY ALL SIPC **MEMBERS** WITH FISCAL YEAR ENDINGS 1. Name of Member, address, Designated Examining Authority, 1934 Act registrelion no. end month in which fiscal year ends for purposes of the audit requirement ol SEC Rule 17a-5: | | 149596 FINRA | 7
Note: If any of the information shown on the
mailing label requires Gorreclion, please e-mail
any corrections to form@sipc.org and so
indicate on the form tiled. | | | | | | |--------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|--|--|--| | | UBS Fund Services (USA) LLC
10 State House SQ FL 15 | Name and telephone number of person to | | | | | | | | I
Hartford, CT 06103-3600 | contact respecting this form . | | | | | | | | | _J
Karen Hu (312) 525-61
03 | | | | | | | 2, A. | General Assessment {item 2e from page 2) | sO | | | | | | | | | ( 149 | | | | | | | | B.
Less payment made with SIPC-6 filed (exclude Interest) | | | | | | | | | Date Paid | | | | | | | | | C.
Less prior overpayment applied | | | | | | | | | D.
Assessment balance due or (overpayment) | | | | | | | | E. Interest computed on late payment (see instruction E) for ___ deys et 20% per annum | | | | | | | | | | F. Total assessment balance and interest due (or overpayment carried forward) | \$ (149) | | | | | | | | G. PAYMENT:
✓ the bor.
ired □ ACH □
□ Funds
__________
Check malled to P.O. Bo
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
person by whom it is executed represent there by
that all inlormation contained herein is true, correct
and complete. | u BS Fund Services (USA) LLC | | | | | | | | | e) | | | | | | | Dated | --·
the~
20 20
FINOP, Officer
day of February | | | | | | | | | ' | (Tille) | | | | | | | | This form and the assessment payment is due 60 days aft er I he end of the fiscal year. Retain the Working Copy of this form
he latest :Z years in an easily accessible place.
tor a period of not less than 6 years, t | | | | | | | | | | | | | | | | | | | | | | | | | | ;:
~
LI.I
a:
!Cl | ffi Dates: | Postmarked | Received | Reviewed | | |------------------------------|------------------|-----------------------------------|----------|--------------------------|--------------------------| | | | > Calculations __
_ | | __
Documentation
_ | ___
Forward Copy
_ | | | c.:, Exceptions: | | | | | | | | en Disposition of exceptions
: | | | | | | | | | 1 | | {22}------------------------------------------------ #### **DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT** Amounts for the fiscal period Item No. 2a. Total revenue (FOCUS Line 12/Part IIA Line 9, Code 4030) 2b. Addilions: (1) Tola.I revenues from the securities business of subsidiaries (except foreign subsidiaries) and predecessors not included above. (2) Net loss from principal transactions in securities in trading aGcounls, (3) Net loss from principal transactions in commodities in trading accounts. **(4)** lnteresl 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, printing, regi3tralion lee3 nnd legel lees dl!ducted in determining nel profit from management of or participation in underwriting or distribution of securities. (7) Net loss from securities in investment accounts. Total additions 2c. Doduc1ions: (1) Revenues from the distribution of shares of a registered open end investment company or unit investment trust. from the sale of variable annuities, from the business of insurance, from investment advisory services rendered to registered investment companies or insurance company separate 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 **wilh** securities transactions. **(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 (ii) Treasury bills, bankers acceptances or co mmercial paper that mature nine months or less from is,suance date. (7) Direct expenses of printing advertising and legal fees incurred in connection **with** other revenue related to the securities business (revenue defined by Section 16{S)(L) of the Act). (8} Other revenue nol related either directly or indirectly to the securities business. (See Instruction C): Dollar for dollar reimbursement from parent (Deductions in excess of \$t00,000 require documentation) (9) (i) Total interest and dividend expense (FOCUS line 22/PART IIA Line 13, Code 4075 plus line **2b(4)** above) but not in ucess of total interest and dividend income. \$. \_\_\_\_\_\_\_\_\_\_ \_ (ii) 40% ol margin interest earned on customers securities accounts (40% of FOCUS line 5, Code 3960). \$. \_\_\_\_\_\_\_\_\_\_ \_ Enter the greater of line (i) or (ii) Total deductions 2d. SIPC Net Operating Revenues 2e. General Assessment @ .0015 be ginning \_1\_11\_f1.\_0\_1\_9 \_\_\_ \_ and ending **1213112019 Eliminate cents** \$2,579,865 2,579,841 2,579,841 (to page 1, line 2.A.) Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.