# OBJECTIVE EQUITY, LLC X-17A-5 (2022-12-28) — Broker-dealer annual report - Company: OBJECTIVE EQUITY, LLC - Form: X-17A-5 - Filed: 2022-12-28 - Period: 2022-09-30 - Accession: 0001293168-22-000008 - CIK: 1293168 - File #: 8-66541 - Type: Broker-dealer - Material weakness: No - Auditor: Rubio CPA, PC - Auditor location: Atlanta, GA - Contact: Brian Megenity - Phone: 7702636003 - Email: bmegenity@bdcaonline.com - Website: bdcaonline.com - Signed by: David Riedel (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1293168/000129316822000008/oeaudit1.pdf --- {0}------------------------------------------------ #### UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 | ANNUAL REPORTS | |----------------| | FORM X-17A-5 | | PART III | OMB APPROVAL DAVIS Number: 3235-0123 Expires: Oct. 31, 2023 Estimated everage burdlen hours per rasponse: 12 SEC FIEE NIAMBER 8-66541 FACING PAGE | AUNG FOR THE PERIOD BECINNING | 10/01/21 | AND ENDING | 09/30/22 | |--------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|------------|--------------------------------------------| | | MM/DD/YY | | RAPODITAM | | | A. REGISTRANT IDENTIFICATION | | | | | | | | | NAME OF FIRM: Objective Equity, LLC | | | | | TYPE OF REGISTRANT [check all applicable boxes]: | | | | | @ Broker-dealer D Security-based swap dealer Major security-based swap participant | | | | | | [ Check here if respondent is also an OTC derivatives dealer | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | | | | | 380 Bretano Way | (No. and Street) | | | | | | | | | | | | | | | C | | 949 04 | | Greenbrae
House
PERSON TO CONTACT WITH REGARD TO THIS FILING | a tate | | (Zig Code) | | | (770) 263-6003 | | bmegenity@bdcaonline.com | | | Area Code - Telephone Number) | | (Email Address) | | | B. ACCOUNTANT IDENTIFICATION | | | | | | | | | | | | | | Brian Megenity
(Name)
INDEPENDENT PUBLIC ACCOLINTANT whose reports are contained in this filing *
Rubio CPA, PC | | | | | | [Mame = If Individual, seate lass, first, and middle marme] | | | | | | | | | 2727 Paces Ferry Rd SE, STE 2-1680 Atlanta
(Address) | (Crap) | | Georgia
이러운 글
[State]
(Zip Code) | | | | | | | | | | 3514 | | 05/05/2009
[Date of Registration with PCAOB [d applicable] | FOR OFFICIAL USE ONLY | | {PCAOS Registration Number, (1 applicable) | OF R 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 uniess the form displays a currently valid OMB control number. {1}------------------------------------------------ #### CATH OR AFFIRMATION David Riedel David Riedel \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ financial report pertaining to the firm of \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ and of the same as of September 30 \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classfied solely as that of a customer. Signaffure: Titlet See Atlached Centificate Notary Public #### This filing \*\* contains (check all applicable boxes): - 121 [a) Statement of financial condition. - [b] {b} Notes to consolidated statement of financial condition. - @ (c) Statement of income (loss) or, if there is other comprehensive in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation 5-X). - E {d] Statement of cash flows. - [e] Statement of changes in stockholders' or partners' or sole proprietor's equity. . - O {() Statement of changes in Babilities 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. - [1] Computation of (anglore net worth under 17 CFR 240.18a-2. - [] Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR.240.15c3-3. - [ {} Camputation for determination of security-based swap reserve requirements parsuant to Exhipit B to 17 CFR 740.15c3-3 or Exhibit A to 17 OFR 240.18a-4, as applicable. - [ ] Computation for Determination of PAB Requirements under Exhibit A to § 240.15;3-3. - [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 secority-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - [0] 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-2, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.156-3 or 17 CFR 240.3Ba-4, as applicable, if material differentes exist, or a statement that no material differences exist. - [0] Summary of financial data for subsidiaries not consplidated in the statement of financial condition. - 6) (q) Oath or affirmation in accordance with 17 CFR 240.178-12, or 17 CFR 240.178-12, or 17 CFR 240.386-7, as applicable. - [r] Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - [5] Exemption report in accordance with 17 CFR 240.173-5 or 17 CFR 240.18a-7, as applicable. - [1] Independent public accountant's report based on an examination of the statement of financial condition. - (q) (ndispendent 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. - [0] Independent public actountant'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. - [x] Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.17a-12, as applicable. - O ty) 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 240,178-12(k). - O (z) Other: - " To request canfidential treatment of certain portions of this filing, see 17 CFR 240.17to 5(c)(2), os applicable. {2}------------------------------------------------ | | ACKNOWLEDGMENT | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | A notary public or other officer completing this
certificate verifies only the identity of the individual
who signed the document to which this certificate is
attached, and not the fruthfulness, accuracy, or
validity of that document. | | | State of California
Marin
County of | | | 12/27/2022
្រីក | before me. Dipu Nepali, Notary Public
(insert name and little of the officer) | | personally appeared Sovid Riede
person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. | who proved to me on the basis of salisfactory evidence to be the person(e) whose name(e) is/are
subscribed to the within instrument and acknowledged to me that helshelthey executed the same in
his/herftheir authorized bapacity(ies), and that by his/her/their signsture(s) on the instrument the
I certify under PENALTY OF PERJURY under the Jaws of the State of Caffornia that the foregoing | | paragraph is true and correct.
WITNESS my hand and official seal, | BINU NEPALI
Barry Puller, - California
Costra Costa Councy
Corronission 4 2290254 | | | | {3}------------------------------------------------ OBJECTIVE EQUITY, LLC Financial Statements For the Year Ended 6HSWHPEHU 30, 20 With Independent Auditor's Report {4}------------------------------------------------ RUBIO CPA, PC CERTIFIED PUBLIC ACCOUNTANTS 2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770690-8995 Fax: 770838-7123 #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Members of Objective Equity, LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Objective Equity, LLC (the "Company") as of September 30, 2022, the related statements of operations, changes in members' equity, and cash flows for the year then ended and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of September 30, 2022, and the results of its operations and its cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### Basis for Opinion These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements 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 the U.S. federal securities laws 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 statements are 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 to the financial statements, 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 statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### Supplemental Information The information contained in Schedules I, II and III has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the Company's management. Our audit procedures included determining whether the information in Schedules I. II and III reconciles to the financial statements or the underlying and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the accompanying schedules. In forming our opinion on the accompanying schedules, we evaluated whether the supplemental information, including its form and content, is presented {5}------------------------------------------------ in conformity with I 7 C.F.R. §240.17a-5. In our opinion, the aforementioned supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as the Company`s auditor since 2019. December 27, 2022 Atlanta, Georgia ![](_page_5_Picture_3.jpeg) {6}------------------------------------------------ # **Objective Equity, LLC Statement of Financial Condition September 30, 2022** ### **Assets** | Cash
Due from related parties
Prepaid expenses | \$
12,891
26,603
170 | |------------------------------------------------------|-------------------------------| | Total assets | \$
39,664 | | Liabilities and members' equity
Liabilities | | | Total Liabilities | \$
- | | Members' equity | 39,664 | | Total liabilities and members' equity | \$
39,664 | {7}------------------------------------------------ # **Objective Equity, LLC Statement of Operations For the Year Ended September 30, 2022** **Revenues** | Advisory fees
Fees from registered representatives | \$
17,639
2,500 | |-------------------------------------------------------|-----------------------| | Total Revenues | 20,139 | | Expenses | | | Professional fees
Other | 28,821
8,136 | | Total Expenses | 36,957 | | Net loss | \$
(16,818) | {8}------------------------------------------------ # **Objective Equity, LLC For the Year Ended September 30, 2022 Statement of Changes in Members' Equity** | September 30, 2022, Balance | \$
39,664 | |-----------------------------|----------------| | Net loss | (16,818) | | Distributions | (17,639) | | Contributions | 87,285 | | October 1, 2021, Balance | \$
(13,164) | {9}------------------------------------------------ # **Objective Equity, LLC Statement of Cash Flows For the Year Ended September 30, 2022** | Cash flows from operating activities: | | |----------------------------------------------------|----------------| | Net loss | \$
(16,818) | | Adjustments to reconcile net loss to net cash used | | | by operating activities: | | | Increase in due from related parties | \$
(23,403) | | Decrease in due to member | (80) | | Decrease in prepaid expenses | 757 | | Decrease in accounts payable and accrued expenses | (28,503) | | Net cash used by operating activities | (68,047) | | Cash flows from financing activities: | | | Contributions | 87,285 | | Distributions | (17,639) | | Net cash provided by financing activities | 69,646 | | Net increase in cash | 1,599 | | Cash at beginning of year | 11,292 | | Cash at end of year | \$
12,891 | | Supplemental Information: | | | Non-cash financing activity | | | Contribution of expenses paid by member | \$
4,285 | {10}------------------------------------------------ # **Objective Equity, LLC NOTES TO FINANCIAL STATEMENTS September 30, 2022** # NOTE A- DESCRIPTION OF BUSINESS AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Description of Business: Objective Equity, LLC (the "Company") is a broker-dealer that was organized in April 2004 as a New York limited liability company. The Company is approved to operate as a broker-dealer, with a perpetual period of duration, registered with the Securities and Exchange Commission ("SEC"). The Company is also a member of the Financial Industry Regulatory Authority ("FINRA"). The Company provides research and corporate advisory services. The Company's customers are primarily corporations and financial institutions located throughout the United States. As a limited liability company, the members' liability is limited to their investments. Cash: The Company maintains its bank accounts in a high credit quality financial institution. The balances at times may exceed federally insured limits. Income Taxes: The Company has elected to be taxed as a partnership under the provisions of the Internal Revenue Code and, accordingly, is not subject to income taxes. Instead, members are liable for federal and state income taxes on their respective share of the taxable income of the Company. Accordingly, no provision for income tax has been provided for in the accompanying financial statements. Under the provisions of FASB Accounting Standards Codification 740-10 (ASC 740-10), Accounting for Uncertainty in Income Taxes, the Company is required to evaluate each of its tax positions to determine if they are more likely than not to be sustained if the taxing authority examines the respective position. A tax position includes an entity's status, including its status as a pass-through entity, and the decision not to file a return. The Company has evaluated each of its tax positions and has determined that it has no uncertain tax positions for which a provision or liability for income taxes is necessary. Revenue Recognition: Revenue from contracts with customers includes placement and advisory services. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transactions prices where multiple performance obligations are identified; when to recognize revenue based on appropriate measure of the Company's progress under the contract; whether revenue should be presented gross or net of certain costs; and whether constraints on variable consideration should be applied due to uncertain future events. {11}------------------------------------------------ # **Objective Equity, LLC NOTES TO FINANCIAL STATEMENTS September 30, 2022** ## NOTE A- DESCRIPTION OF BUSINESS AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED) # Revenue Recognition (continued): The Company provides placement and advisory services related to capital raising activities and mergers and acquisition transactions. Revenue for advisory arrangements is generally recognized at the point in time that performance under the agreement is completed (the closing of the transaction). In some circumstances, significant judgment is needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract. Retainers and other fees received from customers prior to recognizing the revenue are reflected as unearned income. All advisory fee revenue recognized by the Company during fiscal year 2022 pertains to a transaction from a prior year where collectability was not reasonably assured. Basis of Presentation: The Company maintains its accounting records on an accrual basis and follows Generally Accepted Accounting Principles (GAAP), as established by the Financial Accounting Standards Board (the FASB), to ensure consistent reporting of financial condition, results of operation, and cash flows. Use of Estimates: Management uses estimates and assumptions in preparing financial statements in accordance with generally accepted accounting principles. Those estimates and assumptions affect the reported amounts of assets, liabilities, revenues and expenses. Actual results could vary from the estimates that were assumed in preparing the financial statements. Date of Management's Review: Subsequent events were evaluated through the date the financial statements were issued. # NOTE B - NET CAPITAL The Company, as a registered broker dealer, is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC Rule l5c3-l), which requires the maintenance of minimum net capital, equal to the greater of \$5,000 or 6 2/3% of aggregate indebtedness and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. At September 30, 2022, the Company's net capital was \$12,891, which was \$7,891 in excess of its required net capital of \$5,000 and its ratio of aggregate indebtedness to net capital was 0.00 to 1.00. ## NOTE C – CONTINGENCIES The Company is subject to litigation in the normal course of business. The Company has no litigation in progress as defendant at September 30, 2022. {12}------------------------------------------------ # **Objective Equity, LLC NOTES TO FINANCIAL STATEMENTS September 30, 2022** # NOTE D – RELATED PARTY TRANSACTIONS The Company has extended informal loans to an affiliated company in the amount of \$26,578 as of September 30, 2022. This entity is affiliated with the Company through common ownership with the Company's majority member. The loans are payable on demand, do not bear interest and are included in "Due from related parties" on the statement of financial condition. The Company operates from office space provided by its majority member at no cost. Financial position and results of operations could differ from the amounts in the accompanying financial statements if these related party transactions did not exist. ## NOTE E – NET LOSS The Company incurred a loss for fiscal year 2022 and was dependent upon capital contributions from its members for working capital and net capital. The Company's members have represented that they intend to continue to make capital contributions as needed to ensure the Company's survival through at least one year subsequent to the date of the report of the independent registered public accounting firm. Management expects the Company to continue as a going concern and the accompanying financial statements have been prepared on a going-concern basis without adjustments for realization in the event that the Company ceases to continue as a going concern. # NOTE F - CONCENTRATIONS All of the Company's advisory fee revenue during fiscal year 2022 came from one customer. {13}------------------------------------------------ #### **Schedule I** ## **Objective Equity, LLC Pursuant to Rule 15c3-1 of the September 30, 2022 Computation of Net Capital Securities Exchange Act of 1934** | \$
39,664 | |--------------| | | | 170 | | 26,603 | | 26,773 | | 12,891 | | - | | \$
12,891 | | \$
- | | | | | | \$
5,000 | | \$
7,891 | | 0.00 to 1.00 | | | #### **Reconciliation of Computation of Net Capital** There is no significant difference between net capital above and net capital as reported on Part IIA of Form X-17a-5 as of September 30, 2022. {14}------------------------------------------------ # **OBJECTIVE EQUITY, LLC** ## SCHEDULE II COMPUTATION FOR DETERMINATION OF RESERVE REQUIREMENTS UNDER SEA RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF SEPTEMBER 30, 2022 With respect to the Computation for Determination of Reserve Requirements under SEA Rule 15c3-3, the Company does not claim an exemption from SEA Rule 15c3-3 in reliance upon footnote 74 of SEC Release No. 34-70073 dated July 30, 2013, and as discussed in Question 8 of the related FAQ released by SEC staff on April 4, 2014. The Company does not hold customer funds or securities. ## SCHEDULE III # INFORMATION RELATING TO THE POSSESSION OR CONTROL REQUIREMENTS UNDER SEA RULE 15c3-3 OF THE SECURITIES AND EXCHANGE COMMISSION AS OF SEPTEMBER 30, 2022 With respect to the Information Relating to Possession and Control Requirements under SEA Rule 15c3-3, the Company does not claim an exemption from SEA Rule 15c3-3 in reliance upon footnote 74 of SEC Release No. 34- 70073 dated July 30, 2013, and as discussed in Question 8 of the related FAQ released by SEC staff on April 4, 2014. The Company does not hold customer funds or securities. {15}------------------------------------------------ # RUBIO CPA, PC CERTIFIED PUBLIC ACCOUNTANTS 2727 Paces Ferry Road SE Building 2, Suite 1680 Atlanta, GA 30339 Office: 770690-8995 Fax: 770838-7123 #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Members of Objective Equity, LLC We have reviewed management's statements included in the accompanying Broker's Annual Exemption Report in which (1) Objective Equity, LLC did not claim an exemption from Rule 15c3-3 in reliance upon Footnote 74 of the 2013 Release, and (2) Objective Equity, LLC stated that Objective Equity, LLC met the identified conditions for such reliance throughout the most recent fiscal year without exception. Objective Equity, LLC's management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Objective Equity, LLC's compliance with the exemptions. 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 Footnote 74 of the 2013 Release. December 27, 2022 Atlanta, GA Rubio CPA. PC {16}------------------------------------------------ 380 Bretano Way Greenbrae, CA 94904 Tel: 212-334-6365 Fax: 212-253-4263 # . . Objective Equity, LLC . . . . . . . - We, as members of management of Objective Equity, LLC (the "Company"), are responsible for complying with Rule 17a-5, "Reports to be made by certain brokers and dealers". We have performed an evaluation of the Company's compliance with the requirements of Rule 17a-5 and the exemption provisions in Rule 15c3-3(k) (the "exemption provisions") and of the 2013 Release adopting amendments to Rule 17a-5, including Footnote 74 of the 2013 Release. We have determined that the Company does not meet any of the exemption conditions of paragraph (k) of Rule 15c3-3 (i.e., paragraph (k)(1), (k)(2)(i) or (k)(2)(ii)) but also (1) does 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 Exchange Act Rule 15c2-4 ("Rule 15c2-4"); (2) does not carry accounts of or for customers; and (3) does not carry PAB accounts (as defined in Rule 15c3-3) and therefore is covered by Footnote 74 of the 2013 Release. Accordingly, based on our evaluation we make the following statements to the best knowledge and belief of the Company: - 1. We reviewed the provisions of Rule §15c3-3 and related guidance stated in the SEC Staff's FAQ and confirmed that the Company relied on Footnote 74 of the 2013 Release. - 2. The Company conducted business activities involving placement and advisory services to customers consisting of capital raising activity throughout the year ended September 30, 2022, without exception. - 3. The Company met the identified conditions for such reliance throughout the period October 1, 2021, to September 30, 2022, without exception. . . . . . . . . . . . . . . . . . . . . . . . . . . . . David Riedel, President November 1 8 , 2022 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.