# FEF DISTRIBUTORS, LLC X-17A-5 (2022-02-28) — Broker-dealer annual report

- Company: FEF DISTRIBUTORS, LLC
- Form: X-17A-5
- Filed: 2022-02-28
- Period: 2021-12-31
- Accession: 0001075919-22-000003
- CIK: 1075919
- File #: 8-51483
- Type: Broker-dealer
- Material weakness: No
- Auditor: Ernst & Young LLP
- Auditor location: New York, NY
- Contact: Chun Fong
- Phone: 2126983451
- Email: chun.fong@firsteagle.com
- Website: firsteagle.com
- Signed by: Chun Fong (Chief Financial Officer)

Original filing: https://www.sec.gov/Archives/edgar/data/1075919/000107591922000003/FEFDFS2021SOFC.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 31,2021

This report is deemed CONFIDENTIAL in accordance with Rule l7a-5(e)(3) under the Securities Exchange Act of 1934.

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

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# ANNIAI DEDODTS

|                                 |                                                            | ANNUAL REPORTS                                                                                                           |            | SEC FILE NUMBER          |            |
|---------------------------------|------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------|------------|--------------------------|------------|
|                                 |                                                            | FORM X-17A-5                                                                                                             |            | 8-51483                  |            |
|                                 |                                                            | PART III                                                                                                                 |            |                          |            |
|                                 |                                                            |                                                                                                                          |            |                          |            |
|                                 |                                                            | FACING PAGE<br>Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 |            |                          |            |
| FILING FOR THE PERIOD BEGINNING |                                                            | 01/01/21                                                                                                                 | AND ENDING | 12/31/21                 |            |
|                                 |                                                            | MM/DD/YY                                                                                                                 |            | MM/DD/YY                 |            |
|                                 |                                                            | A. REGISTRANT IDENTIFICATION                                                                                             |            |                          |            |
|                                 |                                                            |                                                                                                                          |            |                          |            |
|                                 | NAME OF FIRM: FEF Distributors, LLC                        |                                                                                                                          |            |                          |            |
|                                 | TYPE OF REGISTRANT (check all applicable boxes):           |                                                                                                                          |            |                          |            |
|                                 |                                                            | 18 Broker-dealer                                                                                                         |            |                          |            |
|                                 | Check here if respondent is also an OTC derivatives dealer |                                                                                                                          |            |                          |            |
|                                 |                                                            | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.)                                                      |            |                          |            |
| 1345 Avenue of the Americas     |                                                            |                                                                                                                          |            |                          |            |
|                                 |                                                            | (No. and Street)                                                                                                         |            |                          |            |
|                                 | New York                                                   | NY                                                                                                                       |            |                          | 10105      |
|                                 | (City)                                                     | (State)                                                                                                                  |            |                          | (Zip Code) |
|                                 | PERSON TO CONTACT WITH REGARD TO THIS FILING               |                                                                                                                          |            |                          |            |
| Chun Fong                       |                                                            | 212-698-3451                                                                                                             |            | Chun.Fong@firsteagle.com |            |
| (Name)                          |                                                            | (Area Code - Telephone Number)                                                                                           |            | (Email Address)          |            |
|                                 |                                                            | B. ACCOUNTANT IDENTIFICATION                                                                                             |            |                          |            |
|                                 |                                                            | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*                                                |            |                          |            |
| Ernst & Young LLP               |                                                            |                                                                                                                          |            |                          |            |
|                                 |                                                            | (Name - if individual, state last, first, and middle name)                                                               |            |                          |            |
|                                 |                                                            |                                                                                                                          |            |                          |            |

| Ernst & Young LLP                                | (Name - if individual, state last, first, and middle name) |         |                                            |
|--------------------------------------------------|------------------------------------------------------------|---------|--------------------------------------------|
| One Manhattan West                               | New York                                                   | NY      | 10001-8604                                 |
| (Address)                                        | (City)                                                     | (State) | (Zip Code)                                 |
| 10/20/2003                                       |                                                            | 42      |                                            |
| (Date of Registration with PCAOB)(if applicable) |                                                            |         | (PCAOB Registration Number, if applicable) |
|                                                  | FOR OFFICIAL USE ONLY                                      |         |                                            |
|                                                  |                                                            |         |                                            |

displays a currently valid OMB control number.

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#### OATH OR AFFIRMATION

| Chun Fong                                                                                       |                                                                                                                                                                                           |                                                                                                                   |                      | swear (or affirm) that, to the best of my knowledge and belief, the                                                                 |
|-------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------|----------------------|-------------------------------------------------------------------------------------------------------------------------------------|
| financial report pertaining to the firm of                                                      |                                                                                                                                                                                           | FEF Distributors, LLC                                                                                             |                      | . as of                                                                                                                             |
| December 31                                                                                     |                                                                                                                                                                                           |                                                                                                                   |                      | 2 021 , 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.<br>Notary Public<br>1 10 eiling 2 cantaine chack all any ligable havaali | STATES CONSTITUTION AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AND AN<br>Summinu | Innunumit<br>NO. 01TR6336937.<br>QUALIFIED IN<br>·NEW YORK COUNTY<br>COMM. EXP.<br>02-16-2024<br>PUBLIY<br>OF NEW | Signature:<br>Title: | Chief Financial Officer                                                                                                             |

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

- [ (a) Statement of financial condition.
- [ (b) Notes to consolidated statement of financial condition.
- [] (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X).
- O (d) Statement of cash flows.

- [] (e) Statement of changes in stockholders' or partners' or sole proprietor's equity.
- [ (f) Statement of changes in liabilities subordinated to claims of creditors.
- [ (g) Notes to consolidated financial statements.
- [ (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable.
- [ (i) Computation of tangible net worth under 17 CFR 240.18a-2.
- [] [j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3.
- [ (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.
- [ (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3.
- [ (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3.
- [ (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.
- | | | Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-2, 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.
- [ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition.
- (g) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable.
- [ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- [ (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable.
- [ (t) Independent public accountant's report based on an examination of the statement of financial condition.
- [ (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- □ (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.
- [ (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.
- 12 (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.17a-12, as applicable.
- [ (y) Report describing any material inadequacies found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k).
- [ (z) Other:
- \*\* To request confidential treatment of chis fiing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18a-7(d)(2), as applicable.

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![](_page_3_Picture_0.jpeg)

Ernsl & Young LLP One Manhattan West New York. NY 10001'4604 Tel: +1212 773 3000

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

To the Member and the Directon of FEF Distributors, LLC:

We have performed the procedures included in Rule l7a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities lnvestor Prctection Corporation (SIPC) Series 600 Rules, which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC-7) for the year ended December 31, 2021. Management ofFEF Distributors, LLC (Compaly) is responsible for its Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7.

Management of the Company has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting you and SIPC in evaluating the Company's compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2021. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs ofall users of this report and as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufliciency ofthe procedures described below either for the purpose for which this report has been requested or for any other purpose.

The procedures we performed and our findings are as follows:

1. Compared the assessment payments made in accordance with the General Assessment Payment Form (Form SIPC-6) and applied to the General Assessment calculation on Form SIPC-7 with respective cash disbursement record entries and disbursement listed in the Company's bank statement.

No findings were found as a result ofapplying the procedure.

2. Compared the amounts reported in the audited flnancial statements required by SEC Rule l7a-5 with the amounts reported in Form SIPC-7 for the fiscal year ended December 31, 2021.

No findings were found as a result ofapplying the procedure

3. Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers supporting the adjustments.

Not applicable as there were no adjustments reported in Fonn SIPC-7

4. Recalculated the arithmetical accuracy ofthe calculations reflected in Form SIPC-7 and in the schedules and working papers supporting the adjustments.

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No findings were found as a result ofapplying the procedure.

We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). An agreed-upon procedures engagement involves the practitioner performing specific procedures that the engaging party has agreed to and acknowledged to be appropriate for the purpose of the engagement and reporting on findings based on the procedures performed. We were not engaged to, and did not conduct an examination or a review engagement, the objective of which would be the expression of an opinion or conclusion, respectively, on the Company's Form SIPC-7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31,2021. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you.

We are required to be indepandent ofthe Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement.

This report is intended solely for the information and use ofthe specified parties listed above and is not intended to be, and should not be, used by anyone other thar these specified parties.

S,r.r\*.,t+ f'-"7rt ?

February 28,2022

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

SECURITIES INVESTOR PROTECTION CORPORATION Mail Code: 8967 P.O. Box 7247 Philadelphia, PA 19170-0001

## General Assessment Reconciliation

SIPC-7 (36-REV 12/18)

For the fiscal year ended 12/31/2021

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

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

1. Name of Member, address, Designated Examining Authority, 1934 Act registration no. and month in which fiscal year ends for
purposes of the audit requirement of SEC Rule 17

| Salessa of the game regarement of SEA MAIO 118-7<br>51483 FINRA DEC<br>FEFDISTRIBUTORS LLC<br>1345 AVENUE 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.<br>Name and telephone number of person to<br>contact respecting this form.<br>Chun Fong (212) 698-3451 |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 2. A. General Assessment (item 2e from page 2)                                                                                                                                                                                                                                   |                 | 1,231                                                                                                                                                                                                                                                                             |
| B. Less payment made with SIPC-6 filed (exclude interest)<br>07/28/21                                                                                                                                                                                                            |                 | 598                                                                                                                                                                                                                                                                               |
| Date Paid                                                                                                                                                                                                                                                                        |                 |                                                                                                                                                                                                                                                                                   |
| C. Less prior overpayment applied                                                                                                                                                                                                                                                |                 | 633                                                                                                                                                                                                                                                                               |
| D. Assessment balance due or (overpayment)                                                                                                                                                                                                                                       |                 |                                                                                                                                                                                                                                                                                   |
| E. Interest computed on late payment (see instruction E) for _________________________________________________________________________________________________________________                                                                                                   |                 | 633                                                                                                                                                                                                                                                                               |
| F. Total assessment balance and interest due (or overpayment carried forward)                                                                                                                                                                                                    |                 |                                                                                                                                                                                                                                                                                   |
| G. PAYMENT: V the box<br>Check mailed to P.O. Box    Funds Wired  V<br>Total (must be same as F above)                                                                                                                                                                           | ACH             | 633                                                                                                                                                                                                                                                                               |
| H. Overpayment carried forward                                                                                                                                                                                                                                                   | કા              |                                                                                                                                                                                                                                                                                   |
| 3. Subsidiaries (S) and predecessors (P) included in this form (give name and 1934 Act registration number):<br>N/A<br>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 |                 | FEF DISTRIBUTORS, LLC                                                                                                                                                                                                                                                             |
| and complete.                                                                                                                                                                                                                                                                    |                 | (Name of Gorgoration, Partnership or other organization)                                                                                                                                                                                                                          |
| Dated the 28 day of FEBRUARY 2022                                                                                                                                                                                                                                                |                 | (Authorized Signature)<br>CFO                                                                                                                                                                                                                                                     |
| This form and the assessment payment is due 60 days after the end of the fiscal year. Refain the Working Copy of this form<br>for a period of not less than 6 years, the latest 2 years in an easily accessible place.                                                           |                 | (Tue)                                                                                                                                                                                                                                                                             |
| Postmarked Postmarked<br>Received                                                                                                                                                                                                                                                | Reviewed        |                                                                                                                                                                                                                                                                                   |
|                                                                                                                                                                                                                                                                                  | Documentation _ | Forward Copy --                                                                                                                                                                                                                                                                   |
|                                                                                                                                                                                                                                                                                  |                 |                                                                                                                                                                                                                                                                                   |
|                                                                                                                                                                                                                                                                                  |                 |                                                                                                                                                                                                                                                                                   |

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## DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT

|                                                                                                                                                                                                                                                                                                                                                                                               | Amounts for the liscal period<br>1/1/2021<br>beginning<br>and ending _12/31/2021 |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|
|                                                                                                                                                                                                                                                                                                                                                                                               | Eliminate cents                                                                  |
| Item No.<br>2a. Total revenue (FOCUS Line 12/Part IIA Line 9, Code 4030)                                                                                                                                                                                                                                                                                                                      | 87,347,297<br>S                                                                  |
| 2b. Additions:<br>(1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and<br>predecessors not included above.                                                                                                                                                                                                                                       |                                                                                  |
| (2) Net loss from principal transactions in securities in trading accounts.                                                                                                                                                                                                                                                                                                                   |                                                                                  |
| (3) Net loss from principal transactions in commodities in trading accounts.                                                                                                                                                                                                                                                                                                                  |                                                                                  |
| (4) Interest and dividend expense deducted in determining item 2a.                                                                                                                                                                                                                                                                                                                            |                                                                                  |
| (5) Net loss from management of or participation in the underwriting or distribution of securities.                                                                                                                                                                                                                                                                                           |                                                                                  |
| (6) Expenses other than advertising, printing, registration fees deducted in determining net<br>profit from management of or participation in underwriting or distribution of securities.                                                                                                                                                                                                     | 817,915                                                                          |
| (7) Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                          |                                                                                  |
| Total additions                                                                                                                                                                                                                                                                                                                                                                               | 817,915                                                                          |
| 2c. Deductions:<br>(1) 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>accounts, and from transactions in security futures products. | 87,344,744                                                                       |
| (2) Revenues from commodity transactions.                                                                                                                                                                                                                                                                                                                                                     |                                                                                  |
| (3) Commissions, floor brokerage and clearance paid to other SIPC members in connection with<br>securities transactions.                                                                                                                                                                                                                                                                      |                                                                                  |
| (4) Reimbursements for postage in connection with proxy solicitation.                                                                                                                                                                                                                                                                                                                         |                                                                                  |
| (5) Net gain from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                          |                                                                                  |
| (6) 100% of commissions and markups earned from transactions in (i) certificates of deposit and<br>(ii) Treasury bills, bankers acceptances or commercial paper that mature nine months of less<br>from issuance date.                                                                                                                                                                        |                                                                                  |
| (7) Direct expenses of printing advertising and legal fees incurred in connection with other revenue<br>related to the securities business (revenue defined by Section 16(9)(L) of the Act).                                                                                                                                                                                                  |                                                                                  |
| (8) Other revenue not related either directly or indirectly to the securities business.<br>(See Instruction C):                                                                                                                                                                                                                                                                               |                                                                                  |
| (Deductions in excess of \$100,000 require documentation)                                                                                                                                                                                                                                                                                                                                     |                                                                                  |
| (9) (i) Total interest and dividend expense (FOCUS Line 22/PART IIA Line 13,<br>Code 4075 plus line 2b(4) above) but not in excess<br>of total interest and dividend income.                                                                                                                                                                                                                  |                                                                                  |
| (ii) 40% of margin interest earned on customers securities<br>accounts (40% of FOCUS line 5, Code 3960).                                                                                                                                                                                                                                                                                      |                                                                                  |
| Enter the greater of line (i) or (ii)                                                                                                                                                                                                                                                                                                                                                         |                                                                                  |
| Total deductions                                                                                                                                                                                                                                                                                                                                                                              | 87,344,744                                                                       |
| 2d. SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                                               | 820,468                                                                          |
| 2e. General Assessment @ .0015                                                                                                                                                                                                                                                                                                                                                                | 1,231                                                                            |
|                                                                                                                                                                                                                                                                                                                                                                                               | (to page 1, line 2.A.)                                                           |


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