# CAMPBELL FINANCIAL SERVICES, LLC X-17A-5 (2021-03-03) — Broker-dealer annual report - Company: CAMPBELL FINANCIAL SERVICES, LLC - Form: X-17A-5 - Filed: 2021-03-03 - Period: 2020-12-31 - Accession: 0001037719-21-000002 - CIK: 1037719 - File #: 8-50119 - Material weakness: No - Auditor: Sanville and Company - Auditor location: Abington, PA - Contact: Jaymee McAndrew - Phone: 4104132653 - Signed by: Gabriel Morris (Chief Financial Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1037719/000103771921000002/2020AnnualReport0001037719-1.pdf --- {0}------------------------------------------------ **UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549** | ANNUAL AUDITED REPORT | |-----------------------| | FORM X-17A-5 | | PARTIII | | 0MB APPROVAL | | | | | |--------------------------|--|--------------------------|--|--| | 0MB Number: | | 3235-0123 | | | | Expires: | | October 31, 2023 | | | | Estimated average burden | | | | | | | | hours perresponse 12.00 | | | | | SEC FILE NUMBER | | |---------|-----------------|--| | 8-50119 | | | **FACING PAGE** **Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder** | REPORT FOR THE PERIOD BEGI | -----------
ING 01/01/2020 | | A DE DING 12/31/2020 | | |--------------------------------------------------------------------------|--------------------------------------------------------|-----------------------|----------------------------------|--| | | M MID D /Y Y | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | AME OF BROKER-DEALER: Campbell Financial Service, LLC | | | OFFICIAL USE ONLY | | | ADDRESS OF PRI CIPAL PLACE OF BUSINESS: (Do not use P.O. Box
o.) | | | FIRM I. D. NO. | | | 2850 Quarry Lake Drive | | | | | | | (No. and Street) | | | | | Baltimore | MD | | 21209 | | | (City) | (Sta te) | | (Zip Code) | | | AME A D TELEPHONE NUMBER OF PERSO | TO CO TACT I | REGARD TO THIS REPORT | | | | Gabriel Morris | | | 410-413-2600 | | | | | | (Area Code - Telephone
umber) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | I DEPENDE T PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | Sanville & Company | (Name - if individual, sla/e las/, firs/, middle name) | | | | | 1514 Old York Road | Abington | PA | 19001 | | | (Addre s) | (City) | ( rate) | (Zip Code) | | | | | | | | | CHECKO E:
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certified Public Accountant | | | | | | Public Accountant | | | | | | Accountant not resident in United Stales or any of its possessions. | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | | | | | | | *\*Claims for exemption ji-0111 the requirement that the annual report be covered by the opinion ofan independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.J 7a-5(e)(2)* > **Potential persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid 0MB control number.** {1}------------------------------------------------ ## **OATH OR AFFIRMATION** | ___
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I, _G_a_b_r_ie_l_M_o_r_ri_s
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my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of | | ____________ , swear (or affirm) that, to the best of | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|-----------------------------------------------------------------------------------------------------------------------------------| | --------
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Campbell Financial Service, LLC | | ---
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of December 31 | -
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, as
are true and correct. I further swear (or affirm) that | | | | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account | | classified solely as that of a customer, except as follows: | | | | | | | | | | | | | | | | | | | | | | | | NOTARY PUBLIC | | | | HARFORD COUNTY
MARYLAND | | Signature | | My Commission Expires 12-16-2021 | | Chief Financial Officer | | | | Title | | | | | | | | | | | | | | This report** contains (check all applicable boxes):
0 (a) Facing Page. | | | | [2l (b) Statement of Financial Condition. | | | | | | 1Z] (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 §21 O. l-02 of Regulation S-X).
✓ (d) Statement of Changes in Financial Condition. | | | | [2] (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. | | | | D (t) Statement of Changes in Liabi | | lities Subordinated to Claims of Creditors. | | (g) Computation of Net Capital. | | | | (h) Computation for Determination of Reserve Requirements Pursuant to Rule l 5c3-3.
(i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.
~~ | | | | | | 0 (j) A Reconciliation, including appropriate explanation of the Computation ofNet Capital Under Rule l 5c3-I and the | | Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 1 Sc3-3. | | | | | | 0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of | | consolidation.
(!) An Oath or Affirmation. | | | | (m) A copy of the SIPC Supplemental Report.
~ | | | | | | □ (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. | | 0
(o) Exemption Report | | | | ** For conditions of confidential treatment of certain portions of this filing, see section 240. I 7a-5(e)(3). | | | | | | | | | | | | | | | {2}------------------------------------------------ ![](_page_2_Picture_0.jpeg) # **D Campbell Financial Services, LLC** **ANNUAL REPORT** DECEMBER 31, 2020 {3}------------------------------------------------ #### **TABLE OF CONTENTS** #### **FOR THE YEAR ENDED DECEMBER 31 , 2020** | | PAGES | |----------------------------------------------------------------------------------------------------------------------------------------------|-------| | Report of Independent Registered Public Accounting Firm | | | Financial Statements | | | Statement of Financial Condition | 2 | | Statement of Operations | 3 | | Statement of Changes in Member's Capital | 4 | | Statement of Cash Flows | 5 | | Notes to Financial Statements | 6-8 | | Supplemental Information | | | Computation of Net Capital Under Rule 15c3-1 of the
Securities and Exchange Commission | 9 | | Computation of Reserve Requirements Under Rule 15c3-3 and
Information Relating lo Possession or Control Requirements
Under Rule 15c3-3 | 10 | | Report of Independent Registered Public Accounting Firm regarding Exemption Report | 11 | | Exemption Report Pursuant to Rule 17a-5 of the Securities and Exchange Commission | 12 | {4}------------------------------------------------ ROBERT F. SANVIL LE. CPA MICHAl:L T. BARAN0W\$KY, CPA JOH N P. TOWNSEND, CPA **Sanville & Company** CERTIFIED PUBLIC ACCOUNTANTS 1514 OLD YORK ROAD ABINGTON, PA 19001 (2 15) 884-8460 • (2 15) 884-8686 FAX > 100 WALL STREET, 8th FLOOR NEW YORK, NY 10005 (212) 709-9512 #### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of Campbell Financial Services, LLC ## **Opinion on the Financial Statements** We have audited the accompanying statement offinancial condition of Campbell Financial Services, LLC (the "Company") as of December 31, 2020, the related statements of operations, changes in member's capital and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the "financial statements"), In our opinion, the financial statements present fairly, in all material respects, the fi nancial position of the Company as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in conformity with accounting pri nciples generally accepted in the United States of America. #### **Basis for Opinion** These financial statements are the responsibility of the Company's ma nagement. Our responsibility is to express an opinion on the Company's financial statements based on ou r audit. We are a public accounti ng 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 sta ndards require that we plan and perform the audit to obtain reasonable assurance about whether the fina ncial statements are free of material misstatement, whether due to error or fraud. Our audit included perfo rming procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedu res that respond to those risks. Such proced ures included examining, on a test basis, evidence regarding the amou nts and disclosures in the financia l 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 supplementary information contained in the Computation of Net Capital Under Rule 15c3-1, the Computation of Reserve Requirements Under Rule 15c3-3 (exemption) and Information Relating to the Possession or Control Requirements Under Rule 15c3-3, all under the Rules of the Securities and Exchange Commission have been subjected to audit procedures performed in conjunction with the audit of the Company's financ ial statements. The supplemental information is the responsibility of the Company's manageme nt. 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 Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission, Computation of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission and Information Relating to Possession or Control Requirements Under Rule 15c3-3 of the Securities and Excha nge Commission are fa irly stated, in all material respects, in relation to the financial statements as a whole. We have served as Campbell Financial Services, LLC's auditor since 2017 Abington, Pennsylvania February 17, 2021 MEMBERS OF AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS PENNSYLVANIA INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS {5}------------------------------------------------ #### **STATEMENT OF FINANCIAL CONDITION** #### **DECEMBER 31, 2020** ## **ASSETS** | Cash
Prepaid expenses | \$
320,154
40023 | |------------------------------------------------------|------------------------| | Total assets | \$
360.177 | | LIABILITIES
Accounts payable and accrued expenses | \$
13,000 | | Total liabilities | 13,000 | | MEMBER'S CAPITAL
Member's capital | 347177 | | Total liabilities and member's capital | \$
360,177 | {6}------------------------------------------------ #### **STATEMENT OF OPERATIONS** #### **FOR THE YEAR ENDED DECEMBER 31 , 2020** # **REVENUE** | Marketing service fees | \$
434,400 | |---------------------------------|-------------------| | Total revenue | 434400 | | EXPENSES | | | Office services fee | 19,441 | | Salaries and other compensation | 212,308 | | Rent | 10,200 | | Regulatory fees and expenses | 43,379 | | Professional fees | 14,378 | | Other expenses | 4602 | | Total expenses | 304 308 | | NET INCOME | j
\$
3Q,Q92 | {7}------------------------------------------------ **STATEMENT OF CHANGES IN MEMBER'S CAPITAL** **FOR THE YEAR ENDED DECEMBER 31 , 2020** | Member's Capital at January 1, 2020 | \$
217,085 | |-------------------------------------------|-------------------| | Net income | 130,092 | | , 2020
Member's Capital at December 31 | \$
347,1
77 | {8}------------------------------------------------ #### STATEMENT OF CASH FLOWS **FOR THE YEAR ENDED DECEMBER 31 , 2020** | Cash flows from operating activities | | |---------------------------------------------------------------------------------------|---------------| | Net income | 130,092
\$ | | Changes in assets and liabilities:
Decrease in prepaid expenses | 5 600 | | Net cash from operating activities | 135,692 | | Net increase in cash | 135,692 | | Cash -
beginning of year | 184462 | | Cash -
end of year | 320.154
\$ | | Supplemental Disclosure of Cash Flow Information
Property and Privilege taxes paid | \$
3,1QQ | | Distributions declared but not paid | 0
\$ | | Interest | 0
\$ | | Income Taxes | 0
\$ | {9}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** #### FOR THE **YEAR ENDED DECEMBER 31 , 2020** ## Note 1. ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES A. General Description of the Company Campbell Financial Services, LLC (the Company), a wholly owned subsidiary of Campbell & Company LP (CCLP), is a broker-dealer registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulatory Authority (FINRA). The Company engages in the marketing and selling of products sponsored by Campbell affiliates and the wholesaling of mutual funds. The Company is registered and licensed as a broker-dealer in all U.S. states and territories, with the exception of Guam. B. Method of Reporting The Company's financial statements are presented in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP). The Financial Accounting Standards Board (FASB) Accounting Standards Codification (the Codification), is the single source of U.S. GAAP. C. Use of Estimates The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities al the dale of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates, and such differences may be material to the financial statements. D. Revenue Recognition Under ASC 606 marketing service fees are recognized when earned, based on the terms of the underlying agreement. E. Income Taxes The Company is considered a disregarded entity under the Internal Revenue Code. The Company's taxable income ''flows-through" to CCLP and is subject to CCLP's U.S. federal and state taxation status. The preparation and filing of U.S. federal and state tax returns are performed byCCLP under a consolidated tax filing . Accordingly, the Company does not provide for income tax expense or income tax liability on its net income. The Company does not owe any taxes to its affiliates. The Company applies the provisions of Codification Topic 7 40, Income Taxes , which prescribe the minimum recognition threshold a tax position must meet in connection with accounting for uncertainties in income tax positions taken or expected to be taken by an entity before being measured and recognized in the financial statements. This accounting standard requires the evaluation of tax positions taken or expected to be taken in the course of preparing the Company's financial statements to determine whether the tax positions are "more-likelythan-not" of being sustained by the applicable tax authority. Tax positions with respect to tax at the Company level not deemed to meet the "more-likely-than-not'' threshold would be recorded as an expense in the current year. The Company has elected an accounting policy to classify interest and penalties, if any, as interest expense. The Company has concluded that there is no tax expense or interest expense related to uncertainties in income tax positions for the year ended December 31, 2020. The 2017 through 2020 tax years generally remain subject to examination by U.S. federal and most state tax authorities. {10}------------------------------------------------ **NOTES TO FINANCIAL STATEMENTS (CONTINUED)** #### **FOR THE YEAR ENDED DECEMBER 31 , 2020** ## Note 2. RELATED PARTY TRANSACTIONS The Company has entered into an agreement with CCLP to promote the sales of units of affiliated commodity pools to investors of such commodity pools, and to continuously service such units. As part of this agreement, the Company receives a monthly marketing services fee from CCLP, which represents the entire portion of its revenue. For the year ended December 31 , 2020, the Company earned \$434,400 related to the marketing service fees from CCLP. The Company has entered into a Services and Operations Agreement with CCLP pursuant to which Affiliate Services (as defined in the Services and Operations Agreement), such as management, administration, office space and other services, will be provided by CCLP to the Company and the Company will be charged by CCLP the reasonable value of the services rendered. The allocation for these expenses in 2020 is broken down as follows: office services \$19,416, rent \$10,200, salaries \$212,308, and accounting services \$1 ,500. Charges for such Affiliate Services are reflected in the applicable expense caption in the Company's statement of operations. The Company is responsible for certain direct expenses such as annual audit, legal and regulatory fees. The marketing service fees received from CCLP and the expenses paid to CCLP related to the Services and Operations Agreement would not necessarily be the same if these arrangements were conducted with an unrelated party. ## Note 3. INDEMNIFICATIONS In the normal course of business, the Company enters into contracts and agreements that contain a variety of representations and warranties and which provide general indemnifications. The Company's maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Company that have not yet occurred. The Company expects the risk of any future obligation under these indemnifications to be remote. ## Note 4. CONCENTRATION OF CREDIT RISK The Company maintains its cash in bank deposit accounts, which at times, may exceed federally insured limits. The Company has not experienced any losses in such accounts and believes it is not exposed to any significant credit risks related to cash. #### Note 5. NET CAPITAL REQUIREMENTS Pursuant to the net capital provisions of Rule 15c3-1 of the Securities Exchange Act of 1934, the Company is required to maintain minimum net capital and is required to maintain a ratio of aggregate indebtedness to net capital (both as defined under such provisions), not to exceed 15 to 1. At December 31, 2020, the Company had net capital of \$307,154, which was \$302,154 in excess of its required net capital of \$5,000. The Company's ratio of aggregate indebtedness to net capital was 0.042 to 1. ## Note 6. DISTRIBUTIONS The Company did not pay any distributions to CCLP in 2020. {11}------------------------------------------------ ## **NOTES TO FINANCIAL STATEMENTS (CONTINUED)** **FOR THE YEAR ENDED DECEMBER 31 , 2020** ## Note 7. SUBSEQUENT EVENTS The financial statements were approved by management and available for issuance on February x, 2021. Subsequent events have been evaluated through this date. {12}------------------------------------------------ #### SUPPLEMENTAL **INFORMATION** December 31, 2020 {13}------------------------------------------------ ## **COMPUTATION OF NET CAPITAL UNDER RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION** #### **DECEMBER 31 , 2020** | Total member's capital | \$
347,177 | |--------------------------------------------------------------------------------------|---------------| | Deduct items not allowable for net capital
Non-allowable assets | (40,023) | | Net capital | \$
307.154 | | Minimum net capital required-
6 2/3% of aggregate indebtedness
(Note 1, below) | \$
5,000 | | Minimum regulatory dollar net capital requirement | \$
5.000 | | Net capital shown above | \$
307,154 | | Minimum net capital requirement | 5 000 | | Excess net capital | \$
302.154 | | Net capital less greater of 10% of aggregate indebtedness or | | | 120% of minimum net capital required | \$
301.154 | | Total aggregate indebtedness (Note 1, below) | \$
13,000 | | Percentage of aggregate indebtedness lo net capital | 4.23% | Statement Pursuant lo Paragraph (d) of Rule 17a-5: The computation of net capital and required net capital stated above, agrees with the Campbell Financial Services, LLC computation of net capital and required net capital from the December 31, 2020 Unaudited Financial and Operational Combined Uniform Single Report (FOCUS Report), Part IIA. Note 1 - Computation of Aggregate Indebtedness Total aggregate indebtedness at December 31 , 2020 is as follows: Total Liabilities \$ 13,000 {14}------------------------------------------------ **COMPUTATION OF RESERVE REQUIREMENTS UNDER RULE 15c3-3 AND INFORMATION RELATING TO POSSESSION OR CONTROL REQUIREMENTS UNDER RULE 15c3-3** **FOR THE YEAR ENDED DECEMBER 31 , 2020** The firm has no possession or control obligations under SEA Rule 15c3-3(b) or reserve deposit obligations under SEA Rule 15c3- 3(e) because the Company limits its business activities exclusively to selling securities of one issuer or associated issuers, selling limited partnerships in primary distributions, selling managed futures mutual funds, and private placement of securities. We do not accept customer funds or securities and will not have possession of any customer funds or securities in connection with our activities. {15}------------------------------------------------ #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM REGARDING EXEMPTION REPORT AND ## EXEMPTION REPORT PURSUANT TO RULE 17A-5 OF THE SECURITIES AND EXCHANGE COMMISSION For the Year Ended December 31, 2020 {16}------------------------------------------------ ROBERT F. SANVILLE, CPA M I HAEL T. BARA OW KY, CPA JOMN P. TOWNSEND, CPA *Sanvi((e & Company* CERTIFIED PUBLIC ACCOUNTANTS 1514 OLD YORKROAD ABINGTO , PA 19001 (215) 884-8460 • (215) 884-8686 FAX > I 00 WALL STREET 81h FLOOR NEW YORK, NY 10005 (2 12) 709-95 12 MEMBERS OF AMERICAN 1. STITl.rrE OF CERTIFIED PUBLIC ACCOUNT ANTS PEN '5YLV ANJA IN5TITUTE OF CERT!FIE0 PUBLIC A OUNTA TS ## **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** To the Member of Campbell Financial Services, LLC We have reviewed management's statements, included in the accompanying Exemption Report in which (1) Campbell Financial Services, LLC (the "Company") stated that: - 1. The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3; - 2. The Company is filing an Exemption Report relying on Footnote 74 of the SEC Release o. 34-70073 adopting amendments to 17 C.F.R. § 240. J 7a-5 because the Company limits its business activities exclusively to selling securities of one issuer or associated issuers. Selling limited partnerships in primary distributions, selling managed futures mutual funds, and private placement securities throughout the most recent fiscal year; and - 3. The Company (1) did not directly or indirectly receive, hold, or otheiwise owe funds or securities for or to customers other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b )(2) of Rul l 5c2-4; (2) did not carry accounts of or for customers; and (3) did not carry proprietary accounts of broker-dealers (as defined in 17 C.F.R. § 240.15c3-3) throughout the most recent fiscal year without exception. The Company's management is responsible for 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 and that the Company's other business activities were limited to selling securities of one issuer or associated issuers, selling limited partnerships in primary distributions, selling managed futures mutual funds, and private placement securities and (1) did not directly or indirectly receive, bold, or otheiwise owe funds or securities for or to customers (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of 17 C.F.R. § 240.15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription-way basis where the funds are payable to th issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry proprietary accounts of broker-dealers (as defined in 17 C.F.R. § 240.15c3-3) throughout the most recent fiscal year without exception. 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 17 C.F.R. § 240. l 7a-5. J~.(~ Abington, Pennsylvania February 17, 2021 {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) # Campbell Financial Services, LLC's Exemption Report Campbell Financial Services, 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"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to selling securities of one issuer or associated issuers, selling limited partnerships in primary distributions, selling managed futures mutual funds, and private placement of securities. We do not accept customer funds or securities and will not have possession of any customer funds or securities in connection with our activities. In January 2021 , CFS submitted a Membership Agreement Change Request to FINRA requesting that the firm's membership agreement be updated to reflect CFS under the "Non-Covered Firm" provision pursuant to footnote 74 to SEC Release 34-70073 and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. That request was granted. Campbell Financial Services, LLC I, Gabriel Morris and Thomas Lloyd, affirm that, to my best knowledge and belief, the Exemption Report is true and correct. Gabriel Morris Chief Financial Officer T~oyd President February 16, 2021 2850 Quarry Lake Drive, Suite 100 Ba ltimore, Maryland 21209 Phone {410) 413-2600- Toll Free 1-800-698-7235- Fax (410) 413-2700 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.