# TRIPLETREE, LLC X-17A-5 (2025-02-14) — Broker-dealer annual report

- Company: TRIPLETREE, LLC
- Form: X-17A-5
- Filed: 2025-02-14
- Period: 2024-12-31
- Accession: 0001034830-25-000001
- CIK: 1034830
- File #: 8-50015
- Type: Broker-dealer
- Material weakness: No
- Auditor: Keiter
- Auditor location: Glen Allen, VA
- Contact: Gabrielle Halprin
- Phone: 5045337377
- Email: gabrielle.halprin@capitalone.com
- Website: capitalone.com
- Signed by: Gabrielle Halprin (Chief Financial Operations Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1034830/000103483025000001/TT2024PUBLICFS.pdf

---

{0}------------------------------------------------

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

0MB APPROVAL 0MB Number 3235-0123 Expires Nov 30, 2026 Estimated average burden hours per response 12

| ANNUAL REPORTS |
|----------------|
| FORM X-17A-5   |
| PART Ill       |

SEC FILE NUMBER 8-50015

**FACING PAGE** 

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

| FILING FOR THE PERIOD BEGINNING                                                                                                      | __<br>___<br>0_1_/0_1_/2_4                                 | AND ENDING                              | ___<br>__<br>_<br>1_2_/3_1_/2_4             |  |  |  |
|--------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|-----------------------------------------|---------------------------------------------|--|--|--|
|                                                                                                                                      | MM/DD/VY                                                   |                                         | MM/DD/VY                                    |  |  |  |
| A. REGISTRANT IDENTIFICATION                                                                                                         |                                                            |                                         |                                             |  |  |  |
| Triple Tree, LLC<br>NAME OF FIRM:                                                                                                    |                                                            |                                         |                                             |  |  |  |
| TYPE OF REGISTRANT (check all applicable boxes):<br>[!] Broker-dealer<br>D Check here 1f respondent Is also an OTC denvat1ves dealer | D Security-based swap dealer                               | D MaJor security-based swap part1c1pant |                                             |  |  |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                                  |                                                            |                                         |                                             |  |  |  |
| 8200 Normandale Lake Blvd., 7th Floor                                                                                                |                                                            |                                         |                                             |  |  |  |
|                                                                                                                                      | (No and Street)                                            |                                         |                                             |  |  |  |
| Minneapolis                                                                                                                          | MN                                                         |                                         | 55437                                       |  |  |  |
| (City)                                                                                                                               | (State)                                                    |                                         | (Ztp Code)                                  |  |  |  |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                         |                                                            |                                         |                                             |  |  |  |
| Gabrielle Halprin                                                                                                                    | (504) 533-7377                                             |                                         | gabrielle.halprin@capitalone.com            |  |  |  |
| (Name)                                                                                                                               | (Area Code -Telephone Number)                              | (Email Address)                         |                                             |  |  |  |
|                                                                                                                                      | B. ACCOUNTANT IDENTIFICATION                               |                                         |                                             |  |  |  |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*                                                            |                                                            |                                         |                                             |  |  |  |
| Keiter                                                                                                                               |                                                            |                                         |                                             |  |  |  |
|                                                                                                                                      | (Name - 1f 1nd1v1dual, state last, first, and middle name) |                                         |                                             |  |  |  |
|                                                                                                                                      | Glen Allen                                                 | VA                                      | 23060                                       |  |  |  |
| 4401 Dominion Blvd.                                                                                                                  | (City)                                                     | (State)                                 | (Ztp Code)                                  |  |  |  |
| (Address)<br>10/22/2003                                                                                                              |                                                            | 80                                      |                                             |  |  |  |
| rte of Reg,strntooe w,th PCAOB )(,f apphcable)                                                                                       |                                                            |                                         | (PCAOB Reg,strntooo Nombe,, ,f apphcable) I |  |  |  |
|                                                                                                                                      | FOR OFFICIAL USE ONLY                                      |                                         |                                             |  |  |  |
|                                                                                                                                      |                                                            |                                         |                                             |  |  |  |
| * Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public               |                                                            |                                         |                                             |  |  |  |

CFR 240 17a-5(e)(1)(11), 1f applicable.

**Persons who are to respond to the collect1on of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** 

{1}------------------------------------------------

#### **OATH OR AFFIRMATION**

| I, Gabrielle Halprin                       | . swear (or affirm) that, to the best of my knowledge and belief, the |       |
|--------------------------------------------|-----------------------------------------------------------------------|-------|
| financial report pertaining to the firm of | TripleTree, LLC                                                       | as of |

December 31 , 2~ is true and correct. I further swear (or affirm) that neither the company nor any partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer.

![](_page_1_Picture_3.jpeg)

Title: Chief Fi 5 -=.!-'-'='--'-'"F'-=1=.:...-=.c..::..:..::=..=:..:.=-=.:..:.=.=.... \_\_ ~f-'-'-..,.....-=

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

- Iii (a) Statement of financial condition.
- Iii (b) Notes to consolidated statement of financial condition.
- D (c) Statement of income (loss) or, if there is other comprehensive income in the period(sj presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- D (d) Statement of cash flows.
- D (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- D (f) Statement of changes in liabilities subordinated to claims of creditors.
- D (g) Notes to consolidated financial statements.
- D (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-l, as applicable.
- D (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- D (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- D (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable.
- D (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- D (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- D (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable.
- D (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-l, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist.
- D (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- Iii (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- D (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- Iii (t) Independent public accountant's report based on an examination of the statement of financial condition.
- D (u) Independent public accountant's report based on an examination of the financial report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- D (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable.
- D (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.l 7a-12(k). D (z) Other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_
- 
- \*\*To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e}{3) or 17 CFR 240.18a-7(d)(2), as applicable.

{2}------------------------------------------------

**TRIPLETREE, LLC**  (A Wholly Owned Subsidiary of Capital One, N.A.)

FINANCIAL REPORT

Year Ended December 31, 2024

With Report of Independent Registered Public Accounting Firm

SEC ID 8 - 50015

Filed pursuant to Rule 17a-5(e)(3) as a PUBLIC DOCUMENT.

{3}------------------------------------------------

(A Wholly Owned Subsidiary of Capital One, NA.)

## **Table of Contents**

| Report oflndependent Registered Pub he Accountmg Fmn               | 1      |
|--------------------------------------------------------------------|--------|
| Fmancial Statement:                                                |        |
| Statement of Financial Condition  .<br>Notes to Fmancial Statement | 2<br>3 |

{4}------------------------------------------------

![](_page_4_Picture_0.jpeg)

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

To the Board of Directors of Triple Tree, LLC

#### **Opinion on the Financial Statement**

We have audited the accompanying statement of financial condition of TripleTree, LLC (the "Company") as of December 31, 2024, and the related notes (collectively referred to as the "financial statement"). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2024 in conformity with accounting principles generally accepted in the United States of America.

#### **Basis for Opinion**

This financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statement 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 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 statement is 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 statement, 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 statement. 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 statement. We believe that our audit provides a reasonable basis for our opinion.

We have served as the Company's auditor since 2021 .

Glen Allen, Virginia February 5, 2025

> ) **Certified Public Accountants** & **Consultants**  4401 Dominion Boulevard Glen Allen, VA 23060 T:804.747.0000 F:804.747.3632

www.keitercpa.com

{5}------------------------------------------------

(A Wholly Owned Subsidiaiy of Capital One, NA )

## Statement of Fmancial Condit10n December 31, 2024

| Assets:                                    |                               |
|--------------------------------------------|-------------------------------|
| Cash  .                                    | \$<br>200,826,759             |
| Accounts receivable  .                     | 581,344                       |
| .  .<br>Other receivables<br>.<br><br><br> | 70,779                        |
| Prepaid expenses                           | 498,435                       |
| Deferred tax asset<br><br>.                | 824,531                       |
| Total assets  .                            | \$===20=2=,8=0="1,=84=8       |
| Liabilities:                               |                               |
| Accrued expenses<br><br><br>.              | \$<br>280,296                 |
| Accrued compensation expenses<br>. .<br>   | 48,250,985                    |
| Deferred revenue  .                        | 650,000                       |
| Due to affiliates                          | 15,672,899                    |
| Total liabilities  .                       | 64,854,180                    |
| Total men1ber's equity  .                  | 137,947,668                   |
| Total IiabiJities and member's equity      | \$==2=0~2b.,8~0 l~,8~4;,,;;,8 |

See accompanymg Notes to Fmanctal Statement.

{6}------------------------------------------------

(A Wholly Owned Subsidiary of Capital One, N.A.)

## Notes to Fmancial Statement

## **Note 1-0rganization**

TripleTree, LLC (the "Company") 1s a Minnesota hmited habihty company, wholly owned by Capital One, Nat10nal Associat10n ("CONA'') Pursuant to the Company's articles of orgamzat10n, the Company will exist for a thnty-year penod exptrmg January 13, 2027. The Company 1s primarily engaged m mvestment banking and advisory services The Company's customers are located throughout the Umted States. Investment bankmg services are occas10nally provided to compames outside of the Urnted States. The Company 1s registered with the Securities and Exchange Commiss10n as a broker-dealer and is a member of the Fmancial Industry Regulatory Authonty, Inc. ("FINRA").

## **Note 2-Summary of Significant Accounting Policies**

## **Basis of Accounting**

The financial statement of the Company 1s prepared m accordance with U.S. generally accepted accounting prmc1ples ("U S GAAP")

## **Use of Estimates**

The preparation of financial statements m conformity with U.S. GAAP reqmres management to make estimates and assumpt10ns that affect the amounts reported in the financial statements and accompanying notes While management makes its best Judgment, actual results could differ from those estimates

## **Cash on Deposit with Parent Company**

The Company conside1s all highly liqmd investments with a stated maturity of three months or less when purchased to be cash eqmvalents. Cash mcludes amounts held at CONA, its parent company, totaling \$5,947,565 at December 31, 2024. CONA 1s a maJor fmancial mstrtution and rs msured up to \$250,000 by the Federnl Deposit Insurance Corporation.

## **Accounts Receivable**

Accounts receivable are non-mterest-beanng uncollaterahzed obhgat10ns receivable m accordance with the terms agreed upon with each chent. The Company follows ASU No 2016-13, Fmancial Instruments-Credit Losses (Topic 326): *Measurement of Credit Losses on Fmancial Instruments*  This gmdance reqmres use of the current expected credit loss model that is based on expected losses (net of expected recoveries), rather than mcmTed losses, to detennme the Company's allowance for credit losses on financial assets measured at amortized cost, certain net mvestments in leases and certam off-balance sheet arrangements.

{7}------------------------------------------------

(A Wholly Owned Subsidiary of Capital One, N.A )

## Notes to Financial Statement

The Company has no matenal histoncal credit losses. There are no cunent mdicat10ns of matenal non-receipt from counterpartles The Company projects no probability of matenal future losses related to these balances. Management has detenmned that these receivables have mimmal credit risk, and therefore, no allowance was deemed necessary as of December 31, 2024

## **Income Taxes**

The Company is included in Capital One Fmancial Carp's ("Capital One") consolidated federal mcome tax return, but files separate state mcome tax returns. Capital One allocates federal mcome tax expense to the Company usmg a separate return basis The Company is reimbursed by Capital One for federal mcome tax losses, 1f applicable. Amounts owed to or due from Capital One for federal mcome taxes are reported as a component of due to or from affiliates in the accompanymg statement of financial condition. Taxes payable amounts included m due to affiliates totaled \$14,290,743 at December 31, 2024, of which \$5,898,649 relates to years pnor to 2024

Deferred tax assets and hab1hties are based on differences between the financial reporting and tax basis of assets and hab1ht1es and are measured usmg the enacted tax rates and laws that will be m effect when the differences are expected to reverse

The Company has evaluated the effect of accounting guidance surrounding uncertam mcome tax posit10ns and concluded that the Company has no sigmficant financial statement exposure to uncertam mcome tax positions as of December 31, 2024

## **Recently Adopted Accounting Guidance**

In November 2023, the FASB issued ASU 2023-07· Improvements to Reportable Segment Disclosures This ASU, which amends Topic 820· Segment Rep01ting, improves disclosure reqmrements for reportable segments and enhances disclosures for compames with smgle reportable segments The Company has a smgle rep01table segment based on the nature of its services and regulat01y environment under which it operates The nature of the business and the accountmg policies of the segment are the same as descnbed throughout Notes **1** and 2. The Company's Chief Operatmg Decision Maker ("CODM") 1s its Executive Team The CODM assesses the segment's performance and allocates resources based on net mcome and total assets Total assets per the segment 1s the same 111 all material respects as those reported on the statement of financial condition. The Company adopted the standard on Januaiy 1, 2024. The adoption did not have a matenal 1mpact on the Company's financial statements.

### **New Accounting Pronouncements**

In December 2023, the FASB issued ASU 2023-09· Income Taxes (Topic 740): Improvements to Income Tax Disclosures, which modifies the rules on mcome tax disclosures to reqmre

{8}------------------------------------------------

(A Wholly Owned Subsidiary of Capital One, N.A.)

## Notes to Financial Statement

disaggregated mformation about a repotimg entity's effective tax rate reconc1hat10n as well as information on income taxes paid. The gmdance is effective for the Company in 2025. The Company 1s cunently evaluatmg the potential impact of adoptmg this new gmdance.

## **Note 3-Income Taxes**

Under its Comphance Assurance Program, the Internal Revenue Service ts m the process of aud1tmg Capital One's 2024, 2023 and 2022 federal mcome tax returns. The outcome of the audit is not expected to have a matenal nnpact on the financial results of the Company.

## **Note 4-Related Party Transactions**

Vanous admm1strattve expenses are paid on behalf of the Company by CONA, under a Maste1 Services Agreement between the Company, CONA and various affiliates. These admmistrative expenses are reimbursed by the Company to CONA on a monthly basts. As of December 31, 2024, the Company has rennbursements payable of \$1,382,156 mcluded m due to affiliates in the accompanymg statement of financial condition. In addition, the Company pays a management fee to CONA on an mternally calculated allocation of overhead cost.

The Company sponsors an mcentive plan for qualified employees A portion of individual employee's mcent1ve compensation may be awarded in the form of restncted share umts (the "Units") of Capital One and is payable to employees according to a vesting schedule. The expense associated with the vesting of the Units 1s reimbursed by the Company to Capital One on a quarterly basis

The Company has an agreement with Capital One Securities, Inc ("COS") and KippsDeSanto & Company ("KOC"), affiliated broker-dealers, whereby associates of each broker-dealer may provide vanous admmistrative services to the other affiliates The Company rennburses the affiliated broker-dealeis for the services 1t receives on a monthly basts, net of any amounts due to the Company for services provided.

The Company currently occupies office space leased by Capital One, the expense for which is allocated as part of the Master Services Agreement Management has reviewed the Master Services Agreement and concluded that tlus contract does not contam any leases under the scope of ASU 2016-02 - Leases (Topic 842)

## **Note 5-Commitments and Contingencies**

From time to time, the Company 1s mvolved m ht1gat10n that 1t considers to be mc1dental to its business The Company 1s not presently involved m any legal proceedmgs which management

{9}------------------------------------------------

(A Wholly Owned Subsidiary of Capital One, N.A.)

## Notes to Financial Statement

expects md1vidually or m the aggregate to have a material adverse effect on its financial cond1t1on or results of operat10ns.

The Company has contracts with its vendors fo1 various services. Mirnmum commitments under these contracts as of December 31, 2024 amounts to \$161,218 for 2025

As of December 31, 2024, the Company has commitments to contmuing employees totalmg \$12,000,000 related to the eqmty purchase agreement whereby the Company was acqmred by CONA on November 24, 2021 These commitments are due at certam milestones through 2025

## **Note 6-Concentration**

Approximately 75% of accounts receivable are due from 3 clients as of December 31, 2024.

## **Note 7-Net Capital**

The Company is subject to the Securities and Exchange Comm1ss1on Uniform Net Capital Rule I 5c3-1, which reqmres the maintenance of mm1mum net capital and reqmres that the ratio of aggregate mdebtedness to net capital, both as defined, shall not exceed 15 to **1** At December 31, 2024, the Company had net capital of \$134,825,014 which was \$130,501,400 m excess of the required mm1mum net capital of \$4,323,614. The Company's net capital ratio was 0.48 to 1.

The Company has no obligation under SEC Rule 15c3-3 to prepare the Computation for Determination of Reserve Reqmrements Pursuant to Rule 15c3-3.

## **Note 8--Subsequent Events**

In accordance with U.S GAAP, the Company evaluates subsequent events that have occurred after the statement of financial cond1t10n date but before the financial statements are ISsued There are two types of subsequent events· (1) recognized, or those that provide additional evidence about cond1t10ns that existed at the date of the statement of financial cond1t10n, includmg estimates mherent m the process of preparing financial statements, and (2) nomecognized, 01 those that provide evidence about conditions that did not exist at the date of the statement of financial condit10n but arose after that date. The Company evaluated subsequent events through Febrnary 5, 2025, the date the financial statements were issued.

Based on the evaluation, the Company did not identify any recognized or nomecognized subsequent events that would have reqmred adjustment to the financial statements.


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