# AMD CAPITAL, LLC X-17A-5 (2022-02-25) — Broker-dealer annual report

- Company: AMD CAPITAL, LLC
- Form: X-17A-5
- Filed: 2022-02-25
- Period: 2021-12-31
- Accession: 0001175989-22-000002
- CIK: 1175989
- File #: 8-65422
- Type: Broker-dealer
- Material weakness: No
- Auditor: Hochfelder & Weber
- Auditor location: Chicago, IL
- Contact: Robin Armour
- Phone: 847-317-9300
- Email: robin@amdcapital.com
- Website: amdcapital.com
- Signed by: Robin Armour (Principal)

Original filing: https://www.sec.gov/Archives/edgar/data/1175989/000117598922000002/2021sfcpublic1.pdf

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### AMD CAPITAL, LLC

#### STATEMENT OF FINANCIAL CONDITION FORM X-17A-5 DECEMBER 31, 2021

# PUBLIC

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UNITED STATES SECURITIES **AND EXCHANGE COMMISSION**  Washington, D.C. 20S49

0MB APPROVAL 0MB Number: 3235-0123 Expires: Oct. 31, 2023 Estimated average burden hours per response: 12

### **ANNUAL REPORTS FORM X-17A-5 PART Ill**

SEC FILE NUMBER

FACING PAGE

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

| FILING FOR THE PERIOD BEGINNING _-=-0  1/-=-0_,_,1/-=2-02=-1.:.--                                                                    | __<br>MM/DD/VY                                             | AND ENDING _ | __<br>___.1.-2  13  1  l?_0,_2,1<br>MM/0O/YY    |
|--------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------|--------------|-------------------------------------------------|
|                                                                                                                                      | A. REGISTRANT IDENTIFICATION                               |              |                                                 |
| AMO Capital, LLC<br>NAME OF FIRM:                                                                                                    |                                                            |              |                                                 |
|                                                                                                                                      |                                                            |              |                                                 |
| TYPE OF REGISTRANT {check all applicable boxes):<br>[x Broker-dealer<br>□ Check here if respondent is also an OTC derivatives dealer | □ Security-based swap dealer                               |              | □ Major security-based swap participant         |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do notuse a P.O. box no.)                                                                   |                                                            |              |                                                 |
| 100 Tri-State International, Suite 245                                                                                               |                                                            |              |                                                 |
|                                                                                                                                      | {No. and Street)                                           |              |                                                 |
| Lincolnshire                                                                                                                         | IL                                                         |              | 60069                                           |
| (City)                                                                                                                               | (State)                                                    |              | {Zip Code)                                      |
| PERSON TO CONTACT WITH REGARD TO THIS FILING                                                                                         |                                                            |              |                                                 |
| Robin Armour                                                                                                                         | 312-961-7237                                               |              | robin@amdcapital.com                            |
| (Name)                                                                                                                               | (Area Code - Telephone Number)                             |              | (Email Address)                                 |
|                                                                                                                                      | B. ACCOUNTANT IDENTIFICATION                               |              |                                                 |
| INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*                                                            |                                                            |              |                                                 |
| Hochfelder & Weber, P.C.                                                                                                             |                                                            |              |                                                 |
|                                                                                                                                      | (Name - if individual, state last, first, and middle name) |              |                                                 |
| 525 W. Monroe, Suite 910                                                                                                             | Chicago                                                    | IL           | 60661                                           |
| (Address)                                                                                                                            | (City)                                                     | (State)      | (Zip Code)                                      |
| 11/25/2003                                                                                                                           |                                                            | 880          |                                                 |
| (rte of Registration with PCAOBJ(lfapplicable)                                                                                       | FOR 0FFIOAL USE 0NL y                                      |              | I<br>{PCAOB Registration Number, If applicable) |
|                                                                                                                                      |                                                            |              |                                                 |
| • Claims for exemption from the requirement that the annual reports be covered by the reports of an independent public               |                                                            |              |                                                 |

accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5{e)(1)(ii), if applicable.

Persons who are to respond to the collection of Information contained In this form are not required to respond unless the form diss;lays a currently valid 0MB control number.

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#### **OATH OR AFFIRMATION**

J, Robin Armour swear (or affirm) that, to the best of my knowledge and belief, the

financial report pertaining to the firm of AMD Capital, 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.

*7\_ <sup>I</sup>*I

Notary Public

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

- **Ga (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 5-X).
- □ (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.
- liJ (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.
- □ U) 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 240.1Sc3-3 or Exhibit A to 17 CFR 240.lBa-4, as applicable.
- □ (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.1Sc3-3.
- D (m) information relating to possession or control requirements for customers under 17 CFR 240.1Sc3-3.
- □ (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.
- □ (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.lBa-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.
- ~ (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.lSa-7, as applicable.
- □ (r) Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.lBa-7, as applicable.
- □ (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.lSa-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 report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable.
- D (v) Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR. 240.17a-5 or 17 CFR 240.lSa-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.
- □ (x) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-le or 17 CFR 240.17a-12, as applicable.
- □ (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). □ (z) Other: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_
- 
- \*\*To *request confidential treatment* of *certain portions* of *this filing1* see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18a-7(d)(2}, *as applicable.*

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| State of Ca~ia<br>)<br>County of L1:::'1 ll ff,Je.StO J~-<br>)                                                            |
|---------------------------------------------------------------------------------------------------------------------------|
| /t) /h<br>day<br>Subscribed and sworn to (or affirmed) before me on this<br>,--                                           |
| __<br>__<br>of_J-,_e_· _ro_. _Y'_{IL_a.,_r'_~----f.----<br>f)_Y-_ffl_e_-·u,_v<br>, 20 :.22-. , by<br>(,/_~_-cJ_.• _b_,_AJ |
| proved to me on the basis of satisfactory evidence to be the person(s)<br>who appeared before me.                         |
| I I                                                                                                                       |
| (<br>\__<br>/i<br>-<br>(Seal)<br>/I<br>~,i.~~                                                                             |

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Although the Information in this section ls not required by iaw, it could prevent fraudulent ;emoval and reattachment of this jurat to an unauthorized document and may prove useful to persons relying on the attached document.

#### Description of Attached Document

This certificate is attached to a document titled/for the purpose of containing \_\_\_ pages, and dated \_\_\_\_\_\_\_\_\_\_\_ \_

| Method of Affiant Identification                                                   |                        |
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| Proved to me on the basis of satisfactory evidence:<br>0 form(s) of identification | O credible witness(es) |
| Notarial event is detailed in notary journal on:                                   |                        |
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| Notary contact:                                                                    | __________<br>_        |
| Other                                                                              |                        |
| 0 Affiant(s} Thumbprint(s) 0 Describe;                                             | -----                  |
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# **AMD Capital, LLC Statement of Financial Condition As of December 31, 2021**

| ASSETS                                                            |          |                    |
|-------------------------------------------------------------------|----------|--------------------|
| CURRENT ASSETS                                                    |          |                    |
| Cash                                                              | \$       | 79,076             |
|                                                                   |          |                    |
|                                                                   |          |                    |
| Total Current Assets                                              | \$       | 79,076             |
|                                                                   |          |                    |
| PROPERTYAND EQUIPMENT                                             |          |                    |
| Office Equipment<br>Less: Accumulated Depreciation                | \$<br>\$ | 99,288<br>(85,494) |
|                                                                   |          |                    |
| -Net Property and Equipment                                       | \$       | 13,794             |
|                                                                   |          |                    |
|                                                                   |          |                    |
| OTHER ASSETS<br>Deposits                                          | \$       | 3,738              |
|                                                                   |          |                    |
| TOTAL ASSETS                                                      | \$       | 96,608             |
|                                                                   |          |                    |
| LIAl3ILITIES AND MEMBERS EQUITY                                   |          |                    |
|                                                                   |          |                    |
| CURRENT LIABILITIES                                               |          |                    |
| Acco_unts Payable                                                 | \$       | 17,343             |
| Accrued Expenses                                                  | \$       | 5,276              |
|                                                                   |          |                    |
| Total Current Liabilities                                         | \$       | 22,619 '           |
| rvlEMBERS EQU!TY                                                  |          | 73,989             |
|                                                                   |          |                    |
| TOTAL LIABILITIES AND MEMBERS EQUITY                              | \$       | 96,608             |
|                                                                   |          |                    |
|                                                                   |          |                    |
| The. accompanying notes are an integral part of these statements. |          |                    |
|                                                                   |          |                    |

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## **AMD Capital, LLC Notes to Financial Statements December 31, 2021**

#### **1. Nature of Business**

AMD Capital, LLC (The Company) is in the business of capital raising advisory services. The Company was formed March 1, 2002 and will continue operations perpetually unless terminated in accordance with the operating agreement.

#### **2. Summary of Significant Accounting Policies**

#### **Basis of Accounting**

The financial statements are prepared on the accrual basis of accounting.

#### **Cash and equivalents**

For the purposes of the Statement of Cash Flows, the Company considers all highly liquid investments with a maturity of three months or less to be cash equivalents.

#### **Use of Estimates**

The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect certain reported amounts and disclosures. Accordingly, actual results could differ from these estimates.

#### **Property and Equipment**

Property and Equipment are stated at cost. Depreciation is computed using the straight line method over the estimated useful lives of the related assets. The cost of repairs and maintenance is expensed as incurred. Depreciation expense was \$2,023 for the year ended December 31, 2021.

#### **Income Taxes**

The Company has elected to be taxed as a partnership under the Internal Revenue Code. Under those provisions, the Company does not pay federal income taxes, instead, the limited liability members include their respective shares of the Company's income in their individual income tax returns.

The Company files income taxes in the U.S. federal jurisdiction and various state jurisdictions. The Company is no longer subject to the U.S. federal income tax examinations by tax authorities for years before 2018.

The Company has elected to remit the Illinois Pass-Through Entity tax on behalf of its partners. This election allows the company to remit the individual partners income tax liability based on their respective share of the company's

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# **AMD Capital, LLC Notes to Financial Statements** , **December 31, 2021**

annual income. The company remitted \$645,000 of Illinois Pass Through Entity tax for the 2021 tax year.

#### **Revenue Recognition**

AMD Capital will represent and market each Client Firm's services and products to large institutions, investment consultants, intermediaries, and others - for the direct purpose of increasing assets under management with the Client Firm. AMD Capital will receive a portion of the asset management fees generated as its fee. AMD Capital may also receive a retainer or fee for consulting services. Fees are not receivable until the Client Firm is successful in collecting fees for the investor.

#### **Accounts Receivable**

The Company uses the specific identification method to determine uncollectable accounts receivable. At December 31, 2021 the Company considers all accounts receivable to be collectable.

#### **3. Commitments**

The Company leases office space in Lincolnshire, Illinois under a non-cancelable operating lease which expires July 31, 2023. Rent expense, including operating expenses and real estate taxes was \$42,644 for the year ended December 31, 2021.

The Company also leases office space in Chicago, Illinois from related parties on a month to month basis. Total rent expense was \$5,500 for the year ended December 31, 2021.

The future minimum lease payments required under the lease are as follows:

| Year Ending |          |
|-------------|----------|
| December 31 | Amount   |
| 2022        | \$24,226 |
| 2023        | \$14,489 |
| Total       | \$38,715 |

#### **4. Net Capital Requirements**

The Company is subject to the Security and Exchange Commission Uniform Net Capital Rule (Rule 1Sc3-1). Under this rule, the Company is required to maintain net capital equivalent of \$5,000 or 6-2/3 percent of aggregate indebtedness, whichever is greater

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# **AMD Capital, LLC Notes to Financial Statements December 31, 2021**

Net Capital and Aggregate indebtedness changes daily but at December 31, 2021, the Company has adjusted Net Capital and Net Capital requirements of \$56,457and \$5,000, respectively.

#### **5. Major Customers**

At December 31, 2021, there were no significant accounts receivable concentrations. During 2021, three clients accounted for 12%, 38% and 40% of total revenue, respectively. No other client accounted for more than 10% of 2021 revenue.

#### **6. Concentration of Credit Risk**

The Company maintains cash balances at a Chicago financial institution. The account is insured by the Federal Deposit Insurance Corporation. At December 31, 2021, the entire balance was insured.

#### **7. Retirement Plans**

During 2006, the Company formed two retirement plans, a cash balance profit sharing plan and a 401(k) plan. Contributions to the cash balance profit sharing plan are based on the annual earnings of the Company's members and employees, subject to maximum earnings amount determined by the Internal Revenue Code. Contributions to the 401(k) plan include participant deferrals and a discretionary company contribution. There were contributions of \$91,750 in discretionary contributions for 2021.

#### **8. Subsequent Events**

The Company did not have any subsequent events through February 10, 2022, which was the date the financial statements were available to be issued for events requiring recording or disclosure in the financial statements for the year ended December 31, 2021.

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

#### SECURITIES INVESTOR PROTECTION CORPORATION Mail Corle: 8967 P.O. Box 7247 Philadelphia, PA i9170-0001

| (36·REV 12/18) |  |  |
|----------------|--|--|

| (36-REV 12/18)                                                                                                                 | General Assessment R&concllietlon                                                                                                                                                                                                                 |                                                                                                                                                       | (36·REV 12/18)          |  |  |  |
|--------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------|--|--|--|
| _____<br>For the fiscal year ended<br>_<br>(Reed carefully the Instructions in your Working Copy before, completing this Form) |                                                                                                                                                                                                                                                   |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                |                                                                                                                                                                                                                                                   |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | TO BE FILED BV ALL SIPC MEMBERS VJITH FISCAL YEAR ENDINGS<br>1. Name of Member, address, Designated Examining Authority, 193~ Act registraUon no. and month in which fiscal year ends for<br>purposes of the audit requirement of SEC Rule 17a-5: |                                                                                                                                                       |                         |  |  |  |
| I                                                                                                                              | "#<br>·<br>\'<br>~7<br>LL[,<br>17:A-!N\<br>s .<br>/)<br>1 1! !.--' '-<br>r<br>~· r'<br>.L<br>f. -<br>-n .IV'\<br>)<br>\ V1 ~-LA"\10/()~<br>l                                                                                                      | Note: If any of the information shown on the<br>mailing label requires c_ orrection, please e•mail<br>L _-v,rany corrections to for!"@sipc.org and so |                         |  |  |  |
|                                                                                                                                | \ 00<br>u1,<br>oo toq<br>UAIJc&en~ re, , 11                                                                                                                                                                                                       | 1 · l/1.;U.; i?'1.J Indicate on the form filed.<br>Name and telephone number of person to                                                             |                         |  |  |  |
|                                                                                                                                | le,<br>_J                                                                                                                                                                                                                                         | contact respecting this form.                                                                                                                         |                         |  |  |  |
| L                                                                                                                              | r,~<LA<br>\).\~'3q                                                                                                                                                                                                                                |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | 2. A. General Assessment {item 2e from page 2)                                                                                                                                                                                                    |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | B. Less payment made with SIPC-6 filed (Hclude Interest)<br>__J~2~fil_.<br>,_                                                                                                                                                                     |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | Date Paid<br>C. less prior overpayment applied                                                                                                                                                                                                    |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | D. Assessment balance due or (overpayment)                                                                                                                                                                                                        |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | __<br>E. Interest computed on late payment (see instruction E) for<br>days at 20% per annum                                                                                                                                                       |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | F. Total assessment balance and interest due (or overpayment carried forward)                                                                                                                                                                     |                                                                                                                                                       |                         |  |  |  |
| G. PAVIJENT:                                                                                                                   | q<br>□<br>□<br>✓ the bH<br>Check malted to P.O. BO! .<br>Funds Wired<br>AC<br>Total (must be ssme ;s F above)                                                                                                                                     |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | ________<br>\${<br>H. Overpayment carried forward                                                                                                                                                                                                 | _                                                                                                                                                     |                         |  |  |  |
| 3. Subsidiaries {S) and predecessors (P) included In this form (give name and 1934 Act registration number):                   |                                                                                                                                                                                                                                                   |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                |                                                                                                                                                                                                                                                   |                                                                                                                                                       |                         |  |  |  |
| and complete.                                                                                                                  | The SIPC member submitting this form and the<br>person by whom it is executed represent thereby<br>-<br>that all Information contained herein is true, correct                                                                                    | LLl-<br>er oreanlHtlon)                                                                                                                               | -                       |  |  |  |
| Dated theJ.day of                                                                                                              | ~•<br>~<br>l_<br>20.2J<br>ti l/'\A                                                                                                                                                                                                                | ~-~<br>]?(UYJ{Av<br>(TII)                                                                                                                             |                         |  |  |  |
|                                                                                                                                | l'Mt. form end the Hsessment p~ymen It due 80 dcy~ after the end of the HH~I wei<br>for I period of not IHG iben 6 years, ih& latest 2 YHVS In en H&U\r I<br>CCGSSlble place.                                                                     | r. Reteln the Working Copy of this form                                                                                                               |                         |  |  |  |
|                                                                                                                                |                                                                                                                                                                                                                                                   |                                                                                                                                                       |                         |  |  |  |
| ffi Dates:<br>:=                                                                                                               | -<br>-· __<br>Postmarked<br>Received<br>ReYiewed                                                                                                                                                                                                  |                                                                                                                                                       |                         |  |  |  |
| I.LI<br>> Calculations _<br>l,U                                                                                                | --<br>_<br>Documentation-=-                                                                                                                                                                                                                       |                                                                                                                                                       | __<br>_<br>Forward Copy |  |  |  |
| m:<br>u<br>Exceptions:                                                                                                         |                                                                                                                                                                                                                                                   |                                                                                                                                                       |                         |  |  |  |
| A,,.                                                                                                                           | iii Disposition of exceptions:                                                                                                                                                                                                                    |                                                                                                                                                       |                         |  |  |  |
|                                                                                                                                | 1                                                                                                                                                                                                                                                 |                                                                                                                                                       |                         |  |  |  |

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oererum~AY~ON Of "S PC N(ff OPE~JrnHG REVf.~UES" **AND GENERAL ASSESSMENT** 

Amounts for the fiscal period <sup>~</sup> beginning r:,;.- / -*;;z.o~* <sup>1</sup>and ending\_! -=?J -4P ...L-\

|  | Eliminate cents |              |  |
|--|-----------------|--------------|--|
|  | UG              | 14<br>a, 100 |  |

| Item No.<br>2a. Total revenue (FOCUS line 12/Parr IIA Line 9, Code ,io30)                                                                                                                                                                                                                                                                                                                     |                        |
|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------|
| 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 trensactions 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) E,cpenses other than advertising, printing, registration fees and legal fees deducted in determining net<br>protit from management of or participation in underwriting or distribution ot securities.                                                                                                                                                                                     |                        |
| (7) Net loss from securities in investment accounts.                                                                                                                                                                                                                                                                                                                                          |                        |
| Total additions                                                                                                                                                                                                                                                                                                                                                                               |                        |
| 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. |                        |
| (2) Re\lenues 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) 10D% 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 or less<br>from issuance date.                                                                                                                                                                        |                        |
| (7) Direct expenses of printing aduertising 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 e~pense (FOCUS Line 22/PART IIA Line 13,<br>_________<br>Code 4075 plus line 2b(4) above) but not in excess<br>of total interest and dividend income.<br>\$<br>_<br>_________<br>{ii) 40% of margin Interest earned on customers securities<br>\$<br>_<br>accounts (40% of FOCUS line 5, Code 3960).                                                      |                        |
| Enter the greater of line (i) or (ii)                                                                                                                                                                                                                                                                                                                                                         |                        |
| Total deductions                                                                                                                                                                                                                                                                                                                                                                              |                        |
| 2d. SIPC Net Operating Revenues                                                                                                                                                                                                                                                                                                                                                               |                        |
| 2e. General Assessment@ .0015                                                                                                                                                                                                                                                                                                                                                                 | I ~6,qff ;t~<br>:<br>~ |
|                                                                                                                                                                                                                                                                                                                                                                                               | (to page 1. line 2.A.) |


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