# PERRYMAN SECURITIES, INC. X-17A-5 (2021-11-24) — Broker-dealer annual report - Company: PERRYMAN SECURITIES, INC. - Form: X-17A-5 - Filed: 2021-11-24 - Period: 2021-09-30 - Accession: 0001146152-21-000001 - CIK: 1146152 - File #: 8-53546 - Type: Broker-dealer - Material weakness: No - Auditor: Sanville & Company - Auditor location: Abington, PA - Contact: William D. Perryman - Phone: 972-770-4800 - Signed by: William D. Perryman (President) Original filing: https://www.sec.gov/Archives/edgar/data/1146152/000114615221000001/psiaudit1.pdf --- {0}------------------------------------------------ #### **PERRYMAN SECURITIES, INC.** #### REPORT PURSUANT TO RULE 17a-5{d) FOR THE YEAR ENDED September 30, 2021 {1}------------------------------------------------ | UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C.
20549 | | | 3235*0123
OMB Number
October 31, 2023
Expires
Estimated average burden
hours oer resDonse
12.00 | | | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------|------------------------|-------------------------------------------------------------------------------------------------------------------|--|--| | ANNUAL
REPORT
AUDITED | | | SEC FILE NUMBER | | | | | FORM
X-17A-5
III
PART | | 8-53546 | | | | FACING PAGE
of
Information Required
Brokers and
Dealers Pursuant to Section 17
of
the
Securities Exchange
Act of 1934 and
Rule 17a-5
Thereunder | | | | | | | REPORT FOR THE PERIOD BEGINNING | 10/01720
MM/DD/YY | AND ENDING
MM/DD/YY | (19/30/71 | | | | | A.
REGISTRANT IDENTIFICATION | | | | | | NAME OF BROKER-DEALER: | | | OFFICIAL USE ONLY | | | | Perryman Securities, Inc. | | | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS:(Do
not use P.O. Box No.) | | | FIRM ID. NO. | | | | 12221 Merit Drive, Suite 1660 | | | | | | | | (No. and Street) | | | | | | Dallas | Texas | | 75251 | | | | (City) | (State) | | (Zip Code) | | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT | | | | | | | William D. Perryman | | | 972-770-4800 | | | | | | | (Area Code-
Telephone No.) | | | | | B.
ACCOUNTANT IDENTIFICATION | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | | 1514 oid
&
York Road
Sanville
Company | (Name-
if Individual, state last, first, middle name)
Abington | PA | 19001 | | | | (Address) | (City) | (State) | (Zip Code) | | | | CHECK OhE:
xl
Certified Public Accountant
Public Accountant
J | Accountant not resident in United States or any of its possessions. | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | **OMB APPROVAL** *\*Claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See section 240.17a-5(e)(2)* Potential persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. {2}------------------------------------------------ ## **OATH OR AFFIRMATION** **I, William D. Perryman statements and supporting schedules pertaining to the firm of Perryman Securities. Inc. 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: swear (or affirm) that, to the best of my knowledge and belief the accompanying financial as of September 30 2021,** ![](_page_2_Picture_2.jpeg) - **(m) A copy of the SIPC Supplemental Report.** - **(n) A report describing any Material Inadequacies found to exist or found to have existed since the date of the previous Audit.** - **3 (o) Report of Independent Registered Public Accounting Firm on Management's Exemption Report.** **"For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3),** {3}------------------------------------------------ # PERRYMAN SECURITIES,INC. ### CONTENTS | | | | | PAGE | | |-------------------------|----------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---|---------------|--| | | | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | | 1
-
2 | | | | STATEMENT OF FINANCIAL CONDITION | | | 3 | | | | STATEMENT OF OPERATIONS | | | 4 | | | | STATEMENT OF CHANGES IN | STOCKHOLDER'S
EQUITY | | 5 | | | STATEMENT OF CASH FLOWS | | | 6 | | | | | NOTES TO FINANCIAL STATEMENTS | | | 7
- 9 | | | | SUPPLEMENTARY INFORMATION | | | | | | | Schedule I: | Computation of Net Capital Under Rule 15c3-1
of the Securities and Exchange Commission | | -
11
12 | | | | Schedule II & III: | Computation for Determination of Reserve Requirements and Information
Relating to Possession or Control Requirements Under Rule 15c3-3 of the
Securities and Exchange Commission | | 13 | | | | ON MANAGEMENTS EXEMPTION REPORT | REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM | | 14 -
16 | | {4}------------------------------------------------ ROBERT F.SANV1LLE,CPA MICHAEL T. BARANOWSKY, CPA JOHN P. TOWNSEND, CPA NATHANIEL S. HARTGRAVES, CPA 1514 OLD YORK ROAD ABINGTON, PA 19001 (215) 884-8460 •(215) 884-8686 FAX CERTIFIED PUBLIC ACCOUNTANTS *SanviCCe & Company* GOVERNANCE OF AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS PENNSYLVANIA INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS 100 WALL STREET 8 ' h FLOOR NEW YORK, NY 10005 (212) 709-9512 #### **Report of Independent Registered Public Accounting Firm** To the Shareholder and Board of Directors of Perryman Securities, Inc. #### **Opinion on the Financial Statement** We have audited the accompanying statement of financial condition of Perryman Securities, Inc. (the Company) as of September 30, 2021, and the related notes (collectively, the financial statement). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of September 30, 2021, in conformity with accounting principles generally accepted in the United States of America. #### **Basis for Opinion** This financial statement is the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audit we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion. #### **Supplemental Information** The Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission and the Computation for Determination of Reserve Requirements and Information Relating to the Possession or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission have been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, {5}------------------------------------------------ as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission and the Computation for Determination of Reserve Requirements and Information Relating to the Possession or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission are fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as the Company's auditor since 2020. Abington, PA November 18, 2021 {6}------------------------------------------------ ### PERRYMAN SECURITIES. INC. Statement of Financial Condition September 30.2021 #### ASSETS | Cash | \$ | 1,399 | |--------------------------------|----|---------| | Due from broker | | | | Securities owned at fair value | | 323,200 | | Commission receivable | | 42,436 | | Income taxes receivable | | 8.715 | | | S | 375.750 | # LIABILITIES AND STOCKHOLDER'S EQUITY | Liabilities | | |---------------------------------------------------------|---------------| | Accounts payable and accrued expenses | 57,911
\$ | | Commissions payable | 2.841 | | | 60.752 | | Stockholder's
equity | | | Common stock, 1,000,000
shares authorized with \$.10 | | | par value,10,000
shares issued and outstanding | 1,000 | | Retained earnings | 313.998 | | Total stockholder's
equity | 314,998 | | | \$
375.750 | {7}------------------------------------------------ ### PERRYMAN SECURITIES.INC. Statement of Operations For the Year Ended September 30.2021 | Revenues | | |-------------------------------------------------------------|---------------| | Commissions | \$
168,311 | | Distribution
fees | 405,437 | | Unrealized
gain
on investment
account | 80,788 | | Dividend
income | 2,192 | | Realized
loss
on investment
account | (1,1911 | | | 655.537 | | Expenses | | | Commissions | 87,118 | | Salaries
and
employment
costs | 83,774 | | Regulatory
fees
and
expenses | 10,711 | | Management fees | 390,786 | | Other
expenses | 6,205 | | | 578.594 | | Income (loss) before income taxes | 76,943 | | Provision
(benefit)
for
federal
income
taxes | | | Current | (2,650) | | Deferred | 16.965 | | | 14,315 | | | | | Net
Income | | {8}------------------------------------------------ ## PERRYMAN SECURITIES.INC. Statement of Changes in Stockholder's Equity For the Year Ended September 30.2021 | | Shares | Common
Stock | Retained
Earnings | Total | |--------------------------------------|--------|-----------------|----------------------|---------------| | Balances at
September 30,2020 | 10,000 | 1,000
\$ | \$ 251,370 | 252,370
\$ | | Net Income | | | 62.628 | 62.628 | | Balances at
September 30,
2021 | 10.000 | 1.000
£ | £ 313.998 | £ 314 998 | {9}------------------------------------------------ ### PERRYMAN SECURITIES. INC. Statement of Cash Flows For the Year Ended September 30.2021 | Cash
from
activities
flows
operating | | |-----------------------------------------------------------------------|--------------| | Net
income | \$
62,628 | | Adjustments
to reconcile
income
(loss)
net
to net cash | | | provided (used)
by
operating
activities: | | | (gain)
Unrealized
on investment
account | (80,788) | | Realized
loss
on investment
account | 1,191 | | on investment
Dividends
account | (2,192) | | Change
in
assets and
liabilities: | | | in
due
Decrease
from
brokers | 3,439 | | commission
Decrease
in
receivable | 33,955 | | Increase
in
securities
owned | (3,371) | | in
income
Increase
taxes receivable | (3,834) | | Increase
in
accounts payable and accrued
expenses | 16,898 | | Decrease
in
commission
payable | (22.272) | | Net
cash
(used)
provided
by
operating
activities | 5.654 | | Cash flows from investing activities | | | Net
cash
provided
(used)
by
investing
activities | | | Cash
flows
from
financing
activities | | | Net
(used)
cash
provided
by
financing
activities | | | Net
increase
in
cash | 5,654 | | Cash
at beginning of year | (4.255) | | Cash
at end of
year | | | Supplemental
schedule
of
cash
flow
information | | | Cash
paid
during
for
the year | | | Interest | | | Income
taxes | | {10}------------------------------------------------ ### PERRYMAN SECURITIES. INC. Notes to Financial Statements September 30.2021 # Note 1 - Summary of Significant Accounting Policies Penyman Securities, Inc. (the "Company") is a broker-dealer in securities registered with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority ("FINRA"). The Company is considered exempt under (SEC) Rule 15c3-3, (the Customer Protection Rule) by limiting business to the distribution of mutual funds and/or variable life insurance or annuities. The Company's customers are located throughout the United States. Marketable securities owned are carried at quoted market value. The increase or decrease in net unrealized appreciation or depreciation of securities is credited or charged to operations. ## Distribution Fees - Mutual Funds, Insurance and Annuity Products The Company earns revenue for selling affiliated and unaffiliated mutual funds, fixed variable annuities and insurance products. The performance obligation is satisfied at the time of each individual sale. A portion of the revenue is based on a fixed rate applied, as a percentage, to, amounts invested at the time of sale. The remaining revenue is recognized over the time the client owns the investment or holds the contract and is generally earned based on a fixed rate applied, as a percentage, to the net asset value of the fund, or the value of insurance policy or annuity contract. The ongoing revenue is not recognized at the time of sale because it is variably constrained due to factors outside the Company's control including maiket volatility and client behavior (such as how long client hold their investment, insurance policy or annuity contract). The revenue will not be recognized until it is probable that a significant reversal will not occur. #### Commission Revenue Commission revenue is generally recognized at a point in time upon delivery of contracted services based on a predefined contractual amount on a trade date for a trade execution services based on providing market prices and internal and regulatory guidelines. Commission revenue consists of the sale of mutual fund, variable insurance products and unit investment trusts. Commissions receivable are generally collected in full in the month following their accrual. As such, management has not recorded an allowance for doubtful accounts on these receivables. Management records an allowance for bad debts based on a collectability review of specific accounts. Any receivables deemed uncollectible are written off against the allowance. Commissions receivable as of September 30,2021 were \$42,436. Income taxes are provided for the tax effects of transactions reported in the financial statements and consist of taxes currently due plus deferred taxes related primarily to differences between the basis of assets and liabilities for financial and income tax reporting. Deferred tax assets and liabilities represent future tax return benefits and consequences of those differences, which will either be taxable or deductible when the assets and liabilities are recovered or settled. Deferred income taxes payable of \$54,791 are included in Accounts Payable and Accrued liabilities. Tax benefits associated with uncertain tax positions are recognized in the period in which one of the following conditions is satisfied: (1) the more likely than not recognition threshold is satisfied; (2) the position is ultimately settled through negotiation or litigation; or (3) the statute of limitations for the taxing authority to examine and challenge the position has expired. Tax benefits associated with an uncertain tax position are derecognized in the period in which the more likely than not recognition threshold is no longer satisfied. Any potential interest and penalty associated with a tax contingency, should one arise, would be included as a component of income tax expense in the period in which the assessment arises. {11}------------------------------------------------ ### PERRYMAN SECURITIES. INC. Notes to Financial Statements September 30.2021 # Note 1- Summary of Significant Accounting Policies, continued Income tax returns are generally subject to examination by the respective federal and state authorities over various statutes of limitations generally three to five years from date of filing. The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. ## Note 2 - Fair Value Disclosures Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. In determining fair value, the Company uses various methods including market, income, and cost approaches. Based on these approaches, the Company often utilizes certain assumptions that market participants would use in pricing the asset or liability, including assumptions about risk and/or the risks inherent in the inputs to the valuation technique. These inputs can be readily observable, market corroborated, or generally unobservable inputs. The Company utilizes valuation techniques that maximize the use of observable inputs and minimize the use of unobservable inputs. Based on the observability of the inputs used in the valuation techniques, the Company is required to provide the following information according to the fair value hierarchy. The fair value hierarchy ranks the quality and reliability of the information used to determine fair values. Financial assets and liabilities carried at fair value will be classified and disclosed in one of the following three categories: Level 1 •Valuations for assets and liabilities traded in active exchange markets, such as the New York Stock Exchange. Level 1 also includes U.S. Treasury and federal agency securities and federal agency mortgagebacked securities, which are traded by dealers or brokers in active markets. Valuations are obtained from readily available pricing sources for market transactions involving identical assets or liabilities. Level 2 - Valuations for assets and liabilities traded in less active dealer or broker markets. Valuations are obtained from third party pricing services for identical or similar assets or liabilities. Level 3 - Valuations for assets and liabilities that are derived from other valuation methodologies, including option pricing models, discounted cash flow models and similar techniques, and not based on market exchange, dealer, or broker traded transactions. Level 3 valuations incorporate certain assumptions and projections in determining the fair value assigned to such assets or liabilities. For the year ended September 30, 2021, the application of valuation techniques applied to similar assets and liabilities has been consistent. The fair value of all securities owned are deemed to be Level 1 investments at September 30, 2021 and for the year then ended. ### Note 3 - Net Capital Requirements At September 30, 2021, die Company had net capital of approximately \$215,085 and net capital requirements of \$5,000. The Company's ratio of aggregate indebtedness to net capital was 0.28 to 1. The Securities and Exchange Commission permits a ratio of no greater than 15 to 1. {12}------------------------------------------------ ### **PERRYMAN SECURITIES. INC. Notes to Financial Statements September 30.2021** ### **Note 3 - Net Capital Requirements, continued** **Pursuant to the net capital provisions of Rule 15c3-1 of the Securities Exchange Act of 1934, the Company is required to maintain a minimum net capital, as defined under such provisions. Net capital and the related net capital ratio may fluctuate on a daily basis.** ### **Note 4 - Related Party** **An affiliated company has agreed by contract to furnish office space, various items of personal property, and various general and administrative services to the Company. Expenses incurred with the affiliate under this contract through September 30, 2021, were \$390,786 and are reflected in management fees, The Company and the affiliate are under common control and the existence of that control creates operating results and a financial position significantly different than if the companies were autonomous.** ### **Note 5 - Employee Benefits** **The Company has a medical expense plan used to reimburse an employee who is a Participant ("Participant") in the plan for the medical care of the Participant, the Participant's spouse and dependents not otherwise reimbursed under any other plan of the Company, and to replace Participant's lost wages due to absence from work caused by occupational and non-occupational personal injuries and sickness.** {13}------------------------------------------------ Supplementary Information Pursuant to Rule 17a-5 of the **Securities Exchange Act of 1934** As of September 30,2021 {14}------------------------------------------------ # ScheduleI ### PERRYMAN SECURITIES. INC. Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission As of September 30.2021 ### **COMPUTATION OF NET CAPITAL** | Total stockholder's equity
qualified for net capital | 314,998
S | |----------------------------------------------------------------------------------------------------------------------------|------------------------------| | Add:
Other deductions or allowable credits | | | Total capital and allowable subordinated liabilities | 314,998 | | Deductions and/or charges
Non-allowable assets:
Due from broker
Commissions receivable
Income taxes receivable | (538)
(42,262)
/8,7151 | | Net capital before haircuts on securities positions | 263,483 | | Haircuts on securities (computed,where
applicable,
pursuant to Rule 15c3-1(f))
Other securities | /48.399) | | Net capital | 215.084
S | | AGGREGATE INDEBTEDNESS | | | Items included in the statement of financial condition | | | Accounts payable and accrued expenses
Commissions payable | 57,911
\$
2.841 | | Total aggregate indebtedness | | {15}------------------------------------------------ # ScheduleI(continued) ### PERRYMAN SECURITIES. INC. Computation of Net Capital Under Rule 15c3-1 of the Securities and Exchange Commission As of September 30.2021 ## COMPUTATION OF BASIC NET CAPITAL REQUIREMENT | Minimum net capital required (6 2/3%
of total
aggregate indebtedness) | 4.050 | |-------------------------------------------------------------------------------|--------------| | Minimum dollar net capital requirement of
reporting broker or dealer | 5.000
£ | | Net capital requirement (greater of above two
minimum requirement amounts) | 5.000
£ | | Net capital in excess of required minimum | 210.084
£ | | Excess net capital at 1000% | £
209.009 | | Ratio:
Aggregate indebtedness to net capital | Q.?8 to 1 | # RECONCILIATION WITH COMPANY'S COMPUTATION There were no material differences in the computation of net capital under Rule 15c3-1 from the Company's computation. {16}------------------------------------------------ ## **Schedule II & III** ### **PERRYMAN SECURITIES. INC. Computation For Determination Of Reserve Requirements And Information Relating To Possession Or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission September 30, 2021** **The Company is considered a "Non-Covered Firm" exempt from 15c3-3 by relying on footnote 74 to SEC Release 34- 70073 and therefore, is not required to maintain a "Special reserve bank account for the Exclusive benefit of customers."** {17}------------------------------------------------ Report of Independent Registered Public Accounting Firm On Management's Exemption Report Required By SEC Rule 17a-5 Year Ended September 30, 2021 {18}------------------------------------------------ ROBERT F.SANV1LLE,CPA MICHAEL T. BARANOWSKY, CPA JOHN P. TOWNSEND, CPA NATHANIEL S. HARTGRAVES, CPA 1514 OLD YORK ROAD ABINGTON, PA 19001 (215) 884-8460 •(215) 884-8686 FAX CERTIFIED PUBLIC ACCOUNTANTS *SanviCCe & Company* GOVERNANCE OF AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS PENNSYLVANIA INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS 100 WALL STREET 8 ' h FLOOR NEW YORK,NY 10005 (212) 709-9512 ### **Report of Independent Registered Public Accounting Firm** To the Shareholder and Board of Directors of Perryman Securities, Inc. We have reviewed management's statements, included in the accompanying Exemption Report in which (1) Perryman Securities Inc. (the "Company") identified that it is considered a "Non-Covered Firm" exempt from provisions of 17 C.F.R. §15c3-3 and is filing its Exemption Report relying on footnote 74 to SEC Release 34-70073, and as discussed in Q&A 8 of the related FAQ issued by the SEC staff. The Company limits its business activities exclusively to conducting business activities as a mutual fund retailer on an application basis, broker or dealer selling variable life insurance or annuities, private placements of securities, broker or dealer selling tax shelters or limited partnerships in primary distributions and municipal securities transactions (529 plans) only. (2) The Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4; (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3), throughout the most recent fiscal year without exception. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Perryman Securities, Inc.'s compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in Rule 15c3-3 under the Securities Exchange Act of 1934. Abington, PA November 18, 2021 {19}------------------------------------------------ ### **Perryman Securities, Inc. Exemption Report** Perryman Securities, Inc, (the 'Company") is a registered broker-dealer **subject to Rule** 17a-5 promulgated **by** the Securities and Exchange Commission (17 C.F.R. §24017a-5, 'Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5(d)(1) and (4).To the best of its knowledge and belief,the Company states the following: - **(1)** The Company is considered **"Non-Covered** Firm' **exempt** from 17 C.F.R, §240.15c3-3 and is filing an Exemption Report relying on footnote 74 to SEC Release 34-70073,and as discussed in Q&A 8 of the related FAQ issued by the SEC staff.The Company limits its business activities exclusively to: activities as a mutual funds retailer on an application basis, selling variable life Insurance or annuities, the private placements of securities, acting as a broker or dealer selling tax shelters or limited partnerships in primary distributions and municipal securities transactions (529 plans) only. - (2) The Company (1) did not directly or indirectly receive, hold or otherwise owe funds or securities for or to customers, other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4; (2) did not cany accounts of or for customers; and (3) did not carry PAB accounts (as defined In Rule 15c3-3), throughout the most recent fiscal year without exception. I,William D.Perryman,swear(or affirm)that,to my best knowledge and belief,this exemption report is true and correct. Regards, President Date of Report October 21, 2021 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.