# FEF DISTRIBUTORS, LLC X-17A-5 (2020-02-28) — Broker-dealer annual report

- Company: FEF DISTRIBUTORS, LLC
- Form: X-17A-5
- Filed: 2020-02-28
- Period: 2019-12-31
- Accession: 0001075919-20-000005
- CIK: 1075919
- File #: 8-51483
- Material weakness: No
- Auditor: Ernst & Young LLP
- Auditor location: New York, NY
- Contact: Sylvia Park
- Phone: 212-373-5452
- Signed by: Chun Fong (CFO)

Original filing: https://www.sec.gov/Archives/edgar/data/1075919/000107591920000005/FEFDFS201915c33vF2.pdf

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# **FEF Distributors, LLC**

Securities Investor Protection Corporation Form SIPC-7

Report of Independent Registered Public Accounting Firm on Applying Agreed-Upon Procedures

Year Ended December 31, 2019

This report is deemed CONFIDENTIAL in accordance with Rule 17a-5(e)(3) under the Securities Exchange Act of 1934.

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UNITEDSTATES SECURITI ES AND EXCHANGE COMM ISSION Washington, D.C. 20549

OMB APPROVAL OMB Number: 3235-0123 Expires: August3l,2020 Estimated average burden hours perresponse.. . . . . 12.00

## ANNUAL AUDITED REPORT FORM X-l7A-5 PART III

| SEC FILE NUMBER |
|-----------------|

8- 51483

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 BEGINNING                                                                                                             | 01t01t19                                               | AND ENDING | 12t31119                                         |  |
|---------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------|------------|--------------------------------------------------|--|
|                                                                                                                                             | MM/DDiYY                                               |            | MM/DD/YY                                         |  |
|                                                                                                                                             | A. REGISTRANT IDENTIFICATION                           |            |                                                  |  |
| NAME OF BROKER-DEALER: FEF Distributors, LLC                                                                                                |                                                        |            | OFFICIAL USE ONLY                                |  |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P'O. Box No')                                                                           |                                                        |            | FIRM I.D. NO                                     |  |
| 1345 Avenue of the Americas                                                                                                                 |                                                        |            |                                                  |  |
|                                                                                                                                             | (No. and Street)                                       |            |                                                  |  |
| New York                                                                                                                                    | NY                                                     |            | 10105                                            |  |
| (City)                                                                                                                                      | (State)                                                |            | (Zip Code)                                       |  |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>Chun Fong                                                        |                                                        |            | (212) 698-3451<br>(Area Code - Telephone Number) |  |
|                                                                                                                                             | B. ACCOUNTANT IDENTIFICATION                           |            |                                                  |  |
| INDEpENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*<br>Ernst & Young LLP                                               | (Name - if individual, stale last, first, middle name) |            |                                                  |  |
|                                                                                                                                             | New York                                               | NY         | 10036                                            |  |
| 5 Times Square<br>(Address)                                                                                                                 | (City;                                                 | (State)    | (Zip Code)                                       |  |
| CHECK ONE:<br>{<br>Certifi ed Public Accountant<br>Public Accountant<br>Accountant not resident in United States or any of its possessions' | FOR OFFICIAL USE                                       | ONLY       |                                                  |  |
|                                                                                                                                             |                                                        |            |                                                  |  |

\*Claimsfor exemptionfrom the requirement that the annual reporl be covered by the opinion ofan independent public accountanl mustbesupportedbyastalementoffactsandcircumstancesreliedonasthebasisfortheexemption. SeeSection240.lTa-S(e)(2)

> Potentlal persons who are to respond to the collection ol informatlon contalned in this lorm are not required to respond unlesstheform dlsplays a currentlyvalid OMB control number.

sEC 1410 (1 1-05)

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#### OATH OR AFFIRMATION

| l. Chun Fong<br>, swear (or affirm) that, to the best of                                                                                                                                                                                                                                                                                           |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|--|--------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|--|--|--|--|
| my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of<br>FEF Distributors, LLC                                                                                                                                                                                                           |                                                                                                                   | ,as                                                                                                                                                 |  |                                                                                            |                                                                                    |  |  |  |  |
| o1 December 31                                                                                                                                                                                                                                                                                                                                     | 20 19                                                                                                             | , 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:                                                                                                                                                                                                                                                                                        |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
| ShteofNewYork )                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
| ComtyofNewYort< )                                                                                                                                                                                                                                                                                                                                  |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
| Swom to before me tris 20dr day ofFehuary,2020                                                                                                                                                                                                                                                                                                     |                                                                                                                   | Chief Financial Officer                                                                                                                             |  |                                                                                            |                                                                                    |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   | Title                                                                                                                                               |  |                                                                                            |                                                                                    |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
| Public<br>This report ** contains (check all applicable boxes)<br>El tul' Facing Page.<br>!<br>(b) Statement of Financial Condition.                                                                                                                                                                                                               |                                                                                                                   | TIFFANY N NILSON<br>NOTARY PUBLIC, STATE OF NEW<br>Registration No. 01 N16095373<br>Qualified in Kings CountY<br>Commission Expires Oclober 14'2023 |  |                                                                                            |                                                                                    |  |  |  |  |
| n                                                                                                                                                                                                                                                                                                                                                  | (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
| of Comprehensive lncome (as defined in \$210.1-02 of Regulation S-X).<br>(d) Statement of Changes in Financial Condition.<br>E<br>(e) Statement of Changes in Stockholders'Equity or Partners'or Sole Proprietors'Capital.<br>!<br>(fl Statement of Changes in Liabilities Subordinated to Claims of Creditors.<br>(g) Computation of Net Capital. |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            | (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3. |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  | E<br>(i) Information Relating to the Possession or Control Requirements Under Rule l5c3-3. |                                                                                    |  |  |  |  |
| tr<br>Computation for Determination of the Reserve Requirements Under Exhibit A of Rule l5c3-3.                                                                                                                                                                                                                                                    |                                                                                                                   | () A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule l5c3-l and the                                  |  |                                                                                            |                                                                                    |  |  |  |  |
|                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   | E ttl A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of                               |  |                                                                                            |                                                                                    |  |  |  |  |
| consol idation.                                                                                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
| (l) An Oath or Affirmation.<br>Z<br>(m) A copy of the SIPC Supplemental Report.                                                                                                                                                                                                                                                                    |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |
| IZI                                                                                                                                                                                                                                                                                                                                                |                                                                                                                   | (n) Areportdescribinganymaterialinadequaciesfoundtoexistorfoundtohaveexistedsincethedateofthepreviousaudit                                          |  |                                                                                            |                                                                                    |  |  |  |  |
| **For conditions ofconfidential lrealment ofcertain portions ofthisfiling, see seclion 2a0.17a-5(e)(3).                                                                                                                                                                                                                                            |                                                                                                                   |                                                                                                                                                     |  |                                                                                            |                                                                                    |  |  |  |  |

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![](_page_3_Picture_0.jpeg)

5 Times Square New York, NY 10035-6530 Tel'. +1212 773 3000 Fax'. +7 212773 5350 ey.com

#### Report of Independent Registered Public Accounting Firm on Applying Agreed-Upon Procedures

To the Member and the Directors of FEF Distributors, LLC

We have performed the procedures enumerated below, which were agreed to by the Member, the Directors, and management of FEF Distributors, 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:

l. 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 disbursement record entries and disbursement listed in the Company's bank statement.

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 l7a-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 adjustments were reported in Form SIPC-7, step not applicable

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.

This agreed-upon procedures engagement was conducted in 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 FEF Distributors, LLC's schedule of assessments and payments is in accordance

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with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the fiscal year ended December 31,2019- Accordingly, we do not express such an opinion. Had we performed additional procedures, other maffers 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.

/,\*.r/,TL/r

New York, NY

February 28,2020

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

SECURITIES INVESTOR PROTECTION CORPORATION P .0. Box 92185 Washington, D.C. 20090-2185 202-371-8300 General e ncili ion

For the fiscal year ended **12/31/2019**

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

#### **TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS**

1. Name of Member, address, purposes ol the audit requirement Examining Authority, 1934 Act registration no. and month in which fiscal year ends for SEC Rule 1 ?a-5:

|       | �••••**"620"****"****''"*''**All FOR AADC 100<br>51483<br>FINAA<br>DEC<br>FEF DISTRIBUTORS LLC<br>1345AVENUE OF THE AMERICAS FL 48<br>NEW YORK, NY 10105-4399              |                     | Note: If any of the information shown on the<br>mailing label requires correction, please e-mail<br>any corrections to form@sipc.org and so<br>indicate on the form filed. |                                                                                       |  |
|-------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------|--|
|       |                                                                                                                                                                            |                     |                                                                                                                                                                            | Name and telephone number of person to<br>contact respecting this form.               |  |
|       | L                                                                                                                                                                          | _J                  |                                                                                                                                                                            |                                                                                       |  |
|       |                                                                                                                                                                            |                     |                                                                                                                                                                            |                                                                                       |  |
| 2.    | A. General Assessment (item 2e from page 2)                                                                                                                                |                     |                                                                                                                                                                            |                                                                                       |  |
| B.    | Less payment made with SIPC-6 filed (exclude interest)                                                                                                                     |                     |                                                                                                                                                                            |                                                                                       |  |
| C.    | Date Paid<br>Less prior overpayment applied                                                                                                                                |                     |                                                                                                                                                                            |                                                                                       |  |
|       | D.<br>Assessment balance due or (overpayment)                                                                                                                              |                     |                                                                                                                                                                            |                                                                                       |  |
| E.    |                                                                                                                                                                            |                     |                                                                                                                                                                            |                                                                                       |  |
| F.    | Interest computed on late payment (see instruction E) lor _______ days at 20% per annum<br>Total assessment balance and interest due (or overpayment carried forward)      |                     |                                                                                                                                                                            |                                                                                       |  |
|       | G.<br>J the box<br>PAYMENT:<br>Check mailed to P.O. Box D<br>Funds Wired<br>Total (must be same as F above)                                                                | ACH lJ              |                                                                                                                                                                            |                                                                                       |  |
|       | H.<br>Overpayment carried forward                                                                                                                                          |                     |                                                                                                                                                                            |                                                                                       |  |
|       | 3. Subsidiaries (S) and predecessors (P) included in this form (give name and 1934 Act registration number):                                                               |                     |                                                                                                                                                                            |                                                                                       |  |
|       | The SIPC member submitting this form and the<br>person by whom it is executed represent thereby<br>that all information contained herein is true, correct<br>and complete. |                     |                                                                                                                                                                            |                                                                                       |  |
| Dated | day                                                                                                                                                                        |                     |                                                                                                                                                                            |                                                                                       |  |
| for a | This form and the assessment<br>ol not less than 6 years, the latest 2 years in an                                                                                         | accessible          |                                                                                                                                                                            | is due 60 days after the end of the liscal year. Retain the Working Copy of this form |  |
|       | Dates:                                                                                                                                                                     |                     |                                                                                                                                                                            |                                                                                       |  |
|       | Received                                                                                                                                                                   |                     |                                                                                                                                                                            |                                                                                       |  |
|       | Calculations ___ _                                                                                                                                                         | Documentation ___ _ |                                                                                                                                                                            | Forward Copy ___ _                                                                    |  |

Disposition ol exceptions:

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### **DETERMIN ION OF "SIPC N OPER ING REVENUES" AND GENERAL ASSESSMENT**

Amounts for the fiscal period beginning 1/1/2019 and ending 12/31/2019

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


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