# ULLICO INVESTMENT COMPANY, LLC X-17A-5 (2022-04-01) — Broker-dealer annual report - Company: ULLICO INVESTMENT COMPANY, LLC - Form: X-17A-5 - Filed: 2022-04-01 - Period: 2021-12-31 - Accession: 0001324190-22-000003 - CIK: 1324190 - File #: 8-66906 - Type: Broker-dealer - Material weakness: No - Auditor: Ernst & Young LLP - Auditor location: Philadelphia, PA - Contact: Adam Fried - Phone: (202) 354-8062 - Email: ed@ullico.com - Website: ullico.com - Signed by: Adam Fried (VP & CFO) Original filing: https://www.sec.gov/Archives/edgar/data/1324190/000132419022000003/AuditedUICFinancials12.31.21.pdf --- {0}------------------------------------------------ ## FINANCIAL STATEMENTS AND SUPPLEMENTAL INFORMATION Ullico Investment Company, LLC Y car Ended December 31, 2021 With Report of Independent Registered Public Accounting Firm {1}------------------------------------------------ | ANNUAL REPORTS | |----------------| | FORM X-17A-5 | | PART 111 | | | UNITED STATES | | 0MB APPROVAL | |------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------|-------------------------------|--------------------------------------------------| | | SECURITIES AND EXCHANGE COMMISSION | | OM Number 32350123
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res. O1 31, 2023 | | | Washington, D.C. 20549 | | Estimated average burden
hours er response 12 | | | | | | | | ANNUAL REPORTS | | SEC FILE NUMBER | | | FORM X-17A-5 | | | | | PART 111 | | | | | Uc
FACING PAGE | | | | Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 | | | | | I
NG FOR THE PERIOD BEGINNING | O1VO'?' | I
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NG | 12@1V21 | | FIL | MM/DD/YY | AN | MM/DD/YY | | | A. REGISTRANT IDENTIFICATION | | | | : | | | | | NAME OF FIRM | | | | | TYPE OF REGISTRANT (check all applicable boxes): | | | | | [
Broker-dealer | Security-based
swap dealer | Major security-based swap par | t
icipant | | _ Check here if respondent is also an OTC derivatives dealer | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | | | | | | | | | 8403 Colesville RD | (No. and Street) | | | | | | | | | Silver Spring. | MD
(State | | 20910 | | (City) | | | (Zip Code) | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | Adam Fried | (202) 354-8062 | i
ed@ullico.com
afr | | | (Name) | (Area Code - Telephone Number) | (Email Address) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | | | | I
INDEPENDENT PUBL | t
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C ACCOUNTANT whose repor | ained in this
filing" | | | Ernst & Young LLP | | | | | | (Name -- if individual, state last, first, and middle name) | | | | 2005 Market Street, S
uite 700 | Philadelphia, | PA | 19103 | | (Address) | t
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(Ci | (State) | (Zip Code) | | | | | | | (Date of Registration with PCAOB)(it applicable} | | | (PAO Registration Number, it applicable
) | | | FOR OFFICIAL USE ONLY | | | | | | | | | " 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 l? | | | CFR 240.172-5(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 displays a currently valid 0MB control number. {2}------------------------------------------------ #### OATH OR AFFIRMATION | OATH OR AFFIRMATION | fried, | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------| | _
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lY@Sim7@ßC0many | | | | ## This filing"" contains (check all applicable boxes): - & (a) Statement of financial condition. - E(b) Notes to consolidated statement of financial condition. - G (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 5 210.1-02 of Regulation S-X). - K (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. - - 6 (g) Notes to consolidated financial statements. - 8(h) Computation of net capital under 17 CFR 240.153-1 or 17 CFR 240.18a-1, as applicable. - D] (i)Computation of tangible net worth under 17 CFR 240.18a-2. - (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - D(k)Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 0r Exhibit A to 17 CFR 240.18a-4, as applicable. DO (l) Computation for Determination of PAB Requirements under Exhibit A to \$ 240.15c3-3. - - (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - Dl (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 0r 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - DU (p)Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - \$ (a) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. D(r)Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - } (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - - [ (t)independent public accountant's report based on an examination of the statement of financial condition. - X(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 240.172-12, as applicable. - (v)independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - X (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. - G()Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable. - EC (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). O (zl Other: \_ - - *··To request confidential treatment of certain portions of* this *filing, see 17 CFR 240.17a-5(e)(3)* or *17 CFR 240.180-7(d)(2), os applicable.* {3}------------------------------------------------ # Ullico Investment Company, LLC Financial Statements and Supplemental Infonnation Y ear Ended December 3 1, 2021 ## **Contents** | Report of Independent Registered Public Accounting Finn
2 | |---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Financial Statements | | Statement of Financial Condition
3 | | Statement of Income
4 | | Statement of Changes in Stockholder's Equity
5 | | Statement of Cash Flows
6 | | Notes ro Financial Statements
7 | | ormation
Supplemental Inf | | Schedule I- Computation ofNet Capital Pursuant to Ruic 15c3-I of the Securities and
Exchange Commission
13 | | Schedule II - Statement Pursuant to SEC Rule
l 7a-5(d) Regarding Computation for
15c3-3 of the Securitie
Determination of Reserves Requirements under Rule
s and
Exchange Commission
14 | | ent
Schedule III -
at
Pursuant to SEC Rule l 7a-5(d) Regarding Lnformation
St
em
Relating to Possessions or Control of Securities under Ruic I Sc3-3 of the Securities and
Exchange Commission
15 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) Ernst& Young LP 1el .12154485000 **2005 '4+kt St**+t **fax ·12154484069 Suite** *700 ·y***com** P?milatelphua PA 19103 # Report of Independent Registered Public Accounting Firm ## To the Stockholder and Board of Directors of Uliico Investment Company, LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Ullico Investment Company, LLC (the Company) as of December 31, 2021, the related statements of income, changes in shareholder's 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 at December 31, 2021. and the results of its operations and its cash nows for the year then ended in conformity with U.S. generally accepted accounting principles. #### Basis for Opinion These financial statements are the responsiblllty 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 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 statements are free of material misstatement. whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of 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 wel as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### Supplemental Information The accompanying information contained in Schedules I, II, and Ill has been subjected to audit procedures performed In conjunction with the audit of the Company's financial statements. Such information is the responsibility of the Company's management. Our audit procedures Included determining whether the information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information. In forming our opinion on the Information. we evaluated whether such Information, Including Its form and content, is presented In conformity with Rule 1 7a-5 under the Securities Exchange Act of 1934. In our opinion, the information Is fairly stated, in all materiai respects. in relation to the financial statements as a whole. *We have served as the Company's auditor since 2014.* March 17. 2022 {5}------------------------------------------------ # Statement of Financial Condition As of December 31, 2021 | Assets | | | |----------------------------------------------------------------|----|-----------| | Cash and cash equivalents | | 4,781,459 | | Prepaid assets | | 31,938 | | lntercompany receivables | | 18,330 | | Total assets | \$ | 4,831,727 | | Liabilities | | | | Compensation payable | \$ | 1,162,656 | | Intercompany payable | | 129,981 | | Total liabilities | | 1,292637 | | Stockholder's Equity | | | | Common stock (\$1 par value; I ,000 shares authorized, issued, | | | | and outstanding) | \$ | 1,000 | | Additional paid-in capital | | 249,000 | | e
d earnings
Retain | | 3,289,090 | | '
h
Total sto
older
s equity
ck | | 3,539,090 | | Total liabilities and stockholder's equity | s | 4,831,727 | {6}------------------------------------------------ # Statement of Income #### For the Y ear Ended December 3 I, 2021 | Revenues | | | |---------------------------------------------|----|------------| | Commissions | s | 13,342,128 | | c
Interest in
ome | | 1,137 | | Total revenues | | 13,343,265 | | Expenses | | | | Allocated compensation and related expenses | | 6,434,243 | | Allocated operating expenses | | 421,613 | | Promotional fees | | 333,926 | | Professional fees | | 100,932 | | Insurance expense | | 98,016 | | Regulatory fees and expenses | | 35,822 | | Direct operating expenses | | 9,101 | | Total expenses | | 7,433,653 | | Net income | \$ | 5,909,612 | {7}------------------------------------------------ # Ullico Investment Company, LLC Statement of Changes in Stockholder's Equity For the Year Ended December 31, 2021 | | Shares of
Common
Common
Stock
Stock | | | Additional
Paid-in
Capital | | Retained
Earnings | | Total
Stockholder's
Equity | | |--------------------------------|-------------------------------------------------|----|-------|----------------------------------|-----------|----------------------|---|----------------------------------|--| | Balance, December 3 I, 2020 | 1,000 | \$ | 1,000 | \$ | 249,000 | s 1,884,478 | s | 2,134,478 | | | Net income | | | | | | 5,909,612 | | 5,909,612 | | | Dividends to stockholder | | | | | | (4,505,000) | | (4.,505,000) | | | Balance, Decembe
r 31, 2021 | 1,000 | \$ | 1,000 | | s 249,000 | \$ 3,289,090 | s | 3,539,090 | | {8}------------------------------------------------ # Statement of Cash Flows #### For the Y ear Ended December 31, 2021 | Cash flows from operati
ng activities | | |-----------------------------------------------------------------------------------|-----------------| | Net income | \$
5,909.612 | | Adjustments to reconcile net income to net cash provided by operating activities: | | | Change in operating assets and liabilities: | | | Prepaid assets | (3,159) | | Compensation payable | 33,775 | | lntercompany payable | 347,541 | | lntercompany receivable | 129,981 | | Cash provided by operating activities: | 6.417,750 | | Cash flows from financing activities | | | Dividends to stockholder | (4,505.000) | | Cash used in financing activities | 4,505.000) | | Net chang
e in cash and cash equivalents | 1,912,750 | | Cash and cash equivalents at beginning of year | 2.868,709 | | r
d
cash equivalents at end of yea
Cash an | \$
4,781,459 | | Supplemental disclosure of cash flow information | | | Income tax payments (paid to parent) | | {9}------------------------------------------------ # Ullico Investment Company, LLC Notes to Financial Statements December 31, 2021 # **1. Organization and Nature of Business** Ullico Investment Company, LLC (the Company), a wholly owned subsidiary of Ul!ico Inc. (UUico), was incorporated in 2004 as a broker-dealer registered with the U.S. Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulatory Authority (FINRA). The Company markets group annuity contracts and private investment funds that are established, owned, and/or managed by affiliates. The Company is a component of a larger business enterprise, and its officers, personnel and other support are provided by that entity. Substantially all of its revenue is derived from placement agent fees, which represent a percentage of the investment management fees earned by Ullico Investment Advisors, Inc. (UIA) and The Union Labor Life Insurance Company (ULL), both wholly owned subsidiaries of Ullico. All debts, obligations and liabilities of the Company, whether arising in contract, tort or otherwise, shall be solely the debts, obligations and liabilities of the Company, and the stockholder shall not be obligated personally for any such debt, obligation or liability of the Company solely by reason of being a stockholder. The health, economic and business conditions precipitated by the worldwide COVID-19 pandemic that emerged in 2020 continue to moderately affect the Company's business, results of operations and financial condition. The COVID- I 9 pandemic led to an extreme downturn in and volatility of the capital markets in the early part of 2020, record-low interest rates and wide-ranging changes in consumer behavior resulting from quarantines, shelter-in-place orders and limitations on business activity. Although vaccinations have become widely available and business operations have stabilized, COVID-19 variants remain in circulation and hospitalization and death rates remain elevated in populations with lower vaccination rates. While states have recently started to ease restrictions and interest rates are rising, the capital markets remain volatile and it is unclear when the economy will operate under normal conditions. Because the economic and regulatory environment continues to respond and evolve, the Company cannot predict the full impact of the pandemic and ensuing conditions on our business and financial condition. The Company continues to monitor vaccination rates, regulatory developments and U.S. CDC reports related to COVID-19 and the potential impacts of the COVID-19 pandemic on our business. {10}------------------------------------------------ # Ullico Investment Company, LLC Notes to Financial Statements (continued) #### **2. Significant Accounting Policies** ## **Basis of Presentation and Use of Estimates** The Company's financial statements are prepared in accordance with U.S. generally accepted accounting principles (GAAP) which may require the use of management estimares and assumptions. Actual results could differ from those estimates. The Company and other affiliated entities that provide services to the Company arc under common ownership and management control. The existence of this control could result in the Company's operating results or financial position being significantly different from those that would have been obtained if the Company were autonomous. #### **Revenue Recognition** Revenue is recognized as earned in accordance with respective placement agent agreements between the Company and other entities. Under the respective placement agent agreements, the Company receives a percentage of investment management fees earned by ULL and UIA for serving as a placement agent. Revenue is recognized on a daily basis as management fees are earned by ULL and UIA. Effective January I, 2022, the Private Placement Agreement between UTA and UIC for the Ullico Infrastructure Taxable and Tax-Exempt Funds ('UIF") will be amended. The annual fee paid by UIA to UlC will be reduced to 15% from 20% ofUlA's fee revenue related to the UIF. #### **Income Taxes** The Company is organized as a single member Limited Liability Company and has elected to be treated as a disregarded entity for federal and state income tax reporting purposes. The Company's earnings arc included in the federal tax return filed by the sole member. Accordingly, the accompanying financial statements do not reflect any provisions or credits for federal income taxes. #### **Cash and Cash Equivalents** Cash and cash equivalents consist of highly liquid investments in a money market fund and/or investments purchased with an original maturity of three months or less. Fair value approximates carrying value for these investments. #### **Financial Instruments** The Company's financial instruments consist primarily of cash equivalents. The Company believes all of the financial instruments are recorded at values that approximate fair value duc to the short-term nature of these instruments. {11}------------------------------------------------ # Ullico Investment Company, LLC Notes to Financial Statements (continued) #### **2. Significant Accounting Policies (continued)** #### **Stockholder Dividends** During 2021, the Board of Directors approved stockholder dividends of \$4,505,000 which were paid to Ullico, its sole shareholder and parent. #### **Fair Value Measurements** The Company has adopted ASC 820, Fair Value Measurements and Disclosures, for all financial instruments accounted for at fair value on a recurring basis in the Company's financial statements. ASC 820 established a new framework for measuring fair value and expands related disclosures. Broadly, the framework requires fair value to be determined based on the price that would be received for an asset or paid to transfer a liability (an exit price) in an orderly transaction between market participants. It also establishes market or observable inputs as the preferred source of values, followed by assumptions based on hypothetical transactions in the absence of market inputs. ASC 820 specifies that a hierarchy of valuation techniques be determined for each asset based on whether the inputs to the valuation technique for those assets are observable or unobservable. Observable inputs reflect market data corroborated by independent sources while unobservable inputs reflect assumptions that are not observable in an active market or are developed internally. These two types of inputs create three valuation hierarchy levels: - Level I valuations reflect quoted market or exchange prices for the actual or identical assets or liabilities in active markets. - Level 2 valuations reflect inputs other than quoted prices in Level I, which are observable. The inputs can include some or all of the following: - o quoted prices on similar assets in active markets - o quoted prices on actual assets that are not active - o inputs other than quoted prices such as yield curves, volatilities, or prepayments speeds - o inputs derived from market dala - Level 3 valuations reflect valuations in which one or more of the significant valuation inputs are not observable in an active market, there is limited if any market activity, and/or are based on management inputs into a valuation model The Company maintains policies and procedures to value instruments using the best and most relevant data available. For the year ended December 31, 2021, there were no transfers between levels. As of December 31, 2021, the Company held no investments at fair value. {12}------------------------------------------------ # Ullico Investment Company, LLC Notes to Financial Statements ( continued) ## **2. Significant Accounting Policies (continued)** #### **Liabilities Subordinated to the Claims of General Creditors** At December 31, 202 l, and during the year then ended, the Company had no liabilities subordinated to the claims of general creditors. #### **3. Income Taxes** The Company assesses the likelihood, based on their technical merit, that tax positions taken, will be sustained upon examination based on the facts, circumstances, and information available at the end of each period. The measurement of unrecognized tax benefits is adjusted when new information is available, or when an event occurs that requires a change. As of December 31, 2021, the Company had no unrecognized tax benefit. Tax years that remain open and subject to examination by the Internal Revenue Service are calendar years 2018 and forward. #### **4. Net Capital Requirements** Pursuant to the Unifonn Net Capital Rule (Rule 15c3-I) of the SEC, the Company is required to maintain minimum net capital, as defined under such provisions. The rule requires the Company to maintain minimum net capital equal to the greater of \$5,000 or 6½% of aggregate indebtedness. At December 31, 2021, the Company's net capital was \$3,406,1 09 which was \$3,31 9,933 in excess of net capital requirements. The Company's ratio of aggregate indebtedness to net capital was 0.38 to I. #### **5. Related-Party Transactions** The Company earns a placement agent fee derived from an agreed upon percentage of the annual investment management fees earned by UIA through the management of certain privately offered funds. The Company also earns a placement agent fee derived from an agreed upon percentage of the annual investment management fees earned by ULL through the offer of group annuity products. These revenues are reflected in the Commissions line item on the Statement of Income. The Company has entered into an Expense Sharing Agreement (Agreement) with UIA whereby UlA allocates a certain percentage of expenses for rent, utilities, salaries and employee benefits, telephone, equipment, furniture and fixtures, accounting services and other general administrative and office expenses to the Company. These expenses are reflected in the Allocated operating expenses and the Allocated compensation and related expenses line items on the Statement of Income. All other operating expenses other than those allocated under the Agreement are paid directly by the Company. {13}------------------------------------------------ # Ullico Investment Company, LLC Notes to Financial Statements (continued) # **S. Related-Party Transactions (continued)** The intercompany receivable amount of \$18,330 and the intercompany payable amount of \$129,981 are related party balances due from UlA and due to ULL related to activity from the above relatedparty transactions. #### **6. Risks and Uncertainties** The Company maintains its cash in a bank account, which, at times, may exceed federally insured limits. The Company has not experienced any losses on this account. Additionally, approximately 87% of the revenues earned by the Company are generated by two affiliated products, representing a significant concentration. The two affiliated products are Separate Account J and the UIF. Management does not believe there to be any significant risk of loss of these products and its correlated revenues. #### 7. **Subsequent Events** Events or transactions that occur after the balance sheet date but before the financial statements arc issued are categorized as recognized or non-recognized for financial statement purposes. The Company has evaluated subsequent events through March 17, 2022, and has determined the following events requires disclosure. On February I, 2022 and March 3, 2022, the Company paid a dividend to Ullico in the amount of \$475,000, respectively. {14}------------------------------------------------ Supplemental Information {15}------------------------------------------------ # Schedule I- Computation of Net Capital Pursuant to Rule l 5c3- l of the Securities and Exchange Commission December 3 1, 2021 | Total stockholder's equity qualified for net capital | \$
3,539,090 | |----------------------------------------------------------|-----------------| | Less non-allowable assets: | | | pa
terco
ny receivable
In
m | (18,330) | | Prepaid assets | (31,938) | | Tentative Net Capital | 3,488,822 | | Less haircut on securities | (82,713) | | Net capital | 3,406,109 | | Aggregate indebtedness | \$
1,292,637 | | Minimum capital required | | | (greater of6 2/3 % of aggregate indebtedness or \$5,000) | \$
86,176 | | Net capital in excess of minimum required | \$
3,319,933 | | ,
as defined
Excess net capital at 10% | \$
3,276,845 | | Ratio of aggregate indebtedness to net capital | 0.38 to I | Statement Pursuant to Paragraph (d) (4) of SEC Ruic 17a-5 There are no material differences between this computation of net capital and the corresponding computation prepared by the Company and included in the unaudited Part IIA FOCUS filing on January 25, 2022. {16}------------------------------------------------ # Schedule II - Statement Pursuant to SEC Rule 17a-5(d) Regarding Computation for Determination of Reserves Requirements under Rule l 5c3-3 of the Securities and Exchange Commission December 3 I, 2021 # **Computation for Determination of Reserve Requirement** The Company is not subject to the computation of reserve requirements as it is considered a Non-Covered Firm, under Footnote 74 of SEC Release No. 34-70073 and (I) docs not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) does not carry accounts of or for customers; and (3) does not carry PAB accounts. {17}------------------------------------------------ # Schedule III- Statement Pursuant to SEC Rule l 7a-5(d) Regarding Information Relating to Possessions or Control of Securities under Rule I 5c3-3 of the Securities and Exchange Commission December 3 I , 2021 #### **Information Relating to Possession or Control Requirements** The Company did not maintain possession or control of any customer funds or securities as of December 31, 2021 and is exempt from the possession or control requirements as it is considered a Non-Covered Firm, under Footnote 74 of SEC Release No. 34-70073 and (I) does not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) does not carry accounts of or for customers; and (3) does not carry PAB accounts. {18}------------------------------------------------ | SIP | C-7 | |----------------|-----| | (36-REV 12/18) | | #### SECURITIES INVESTOR PROTECTION CORPORATION P.O. B0x 92185 Washington, 0.C. 20090-2185 202-371-8300 General Assessment Reconciliation | SIPC-7 | |----------------| | (36-REV 12/18) | 8.618.87 0.00 For the fiscal **year** ended \_12/31/2021 (Read carefully the instructions in *you:* Working Copy belore completing this Form) #### TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS 1. Name oi Member, address, Designated Examining Authority, 1934 Act registration no and month in which fiscal *year* ends tor purposes ot the audit requirement of SEC Rule 17a-5: ! 10·22·· 1535--· MIXED AADC 220 66906 FINRA DEC ULLICO INVESTMENT COMPANY ATTN: ADAM FRIED 8403 COLESVILLE RD 14TH FL ISILVER SPRING. MD 20910-6331 2. A. General Assessment (item 2e lrom *page* 2) B. Less payment made with SIPC-6 filed (exclude interest) 8/4/2021 7 - Note: It *any* of the information shown on *the* mailing label requires correction, please e-mail any corrections to form@sipc.org *and* so indicate on the form filed. Name *and* telephone number ol person to contact respecting this form. Adam Fried (202) 354-8062 \$ 15.890.79 7,271.92 Date Paid C. Less prior overpayment applied D. Assessment balance due or (overpayment) E. Interest computed on late payment (see instruction E) tot\_days at 20% per annum \$ 8.618.87- F. Total assessment balance and interest due (or overpayment carried forward) G. PAYMENT: V the b6ox Check mailed to P.0. Box OFunds Wlired 3 Total (must be same as F above) H. Overpayment carried forward **S( \_** ACH O 88618.87 3. Subsidiaries (S) and predecessors (P) included in this form (give name and 1934 Act registration number): | The SIPC member submitting this form and the
person by whom it is executed represent thereby
that all information contained herein is true. correct | Ullico Investment Company LLC | | | | | |-----------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------|--|--|--|--| | and complete. | Dvsaa¿.
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) | |-----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------|--------------| | | This form and the assessment payment ls due 60 days after the end of the fiscal year. Retain the Working Copy of this form | | | | for a period of not less than 6 years, the latest 2 years in an easily accessible place. | | | | | | | 5 ates: | | | | z
Postmarked | Received
Reviewed | | | l
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calculations | Documentation | Forward Copy | | r
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Disposit
ns: | | | {19}------------------------------------------------ #### DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT | | | Amounts tor the fiscal period
beginning 1/1/2021
ad ending 12/31/2021 | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|-----------------------------------------------------------------------------| | Item No. | | Eliminate cents | | /
2a. Total revenue (FOCUS Line 12
ant IIA Line 9, Code 4030) | | 13.343.265
\$ | | 2b. Additions:
(1) Total revenues from the securities business ot subsidiaries [except foreign subsidiar
predecessors not included above. | i
es) and | | | (2} Net loss lrom principal transactions in securities in trading accounts. | | | | (3) Net loss trom principal transactions in commodities in trading accounts. | | | | (4) Interest and dividend expense deducted in determinin
g item 2a. | | | | (5) Net loss trom management ot or participation | in the underwriting or distribution ot securities. | | | (6) Exoenses other than advertising, printing, registration lees and legal fees deducted in d
profit iron managemnent ot or participation in underwriting or distribution of | etermining net
securities. | | | (7} Net loss from securities in investment accounts. | | | | Total additions | | 0.00 | | io
ns:
2c. Deduct
(1) Revenues from the distribution o! shares ol a registered open end investment company or unit
investment trust, from the sale ot variable annuities, tom t
advisory services rendered Io registered investment companies or insurance comany separate
accounts, and from transactions in security futures products. | he business of insurance, Irom
vestment
in | 2,748,271 | | transacti
[2) Revenues lrom commodity
ons. | | | | (3} Commissions, floor brokerage and clearance paid to other SIPC members in connection with
i
es transactions.
securit | | | | (4) Reimbursements for postage in connection with proxy solicitation. | | | | i
ties in investment accounts.
(5) Net gain from secur | 1,137 | | | (6) 100% ol commissions and markups earned
trom transactions in (i) cert
l
s, bankers acceptances or commercial paper that mat
(ii) Treasury bil
from issuance date. | \$
i
ficates ol deposit and
ure nine months or less | | | i
sing and legal lees
i
(7} Direct expenses ot printing advert
in
ties business (revenue defined by Section 16(9)(L) o! the Act).
related to the secur | curred in connection with other revenue | | | (8) Other revenue not related either directly or indirectly to the securities business.
i
(See Instruct
on C): | | | | )
i
ons in excess of \$100,000 require documentati
(Deduct
on | | | | (9) {i) Total interest and dividend expense (FOCUS Line 22/P4RT IIA Line 13,
Code 4075 plus line 2b{4) above) but not in excess | S | | | in
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3 | | | | Enter the greater of line (i) or {ii) | | | | Total deductions | | 2,749,408 | | 2d. SIPC Net Operating Revenues | | 10.593.857
s. | | 2e. General Assessment @.0015 | | 15,890.79
\$. | | | | (to page I, line 2.A.) | {20}------------------------------------------------ ![](_page_20_Figure_1.jpeg) {21}------------------------------------------------ ![](_page_21_Picture_0.jpeg) ·+. w'gt #### Report of Independent Registered Public Accounting Firm on Applying Agreed-Upon Procedures To the Board of Directors and Management of Ullico Investment Company. LLC: We have performed the procedures Included In Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules. which are enumerated below on the accompanying General Assessment Reconciliation (Form SIPC- 7) for the year ended December 31, 2021. Management of Ullico Investment Company. LLC (Company) is responsible for its Form SIPC-7 and for Its compliance with the applicable instructions on Form SIPC-7. Management of the Company has agreed to and acknowledged that the procedures performed are appropriate to meet the intended purpose of assisting you and SIPC In evaluating the Company's compliance with the applicable instructions on Form SIPC-7 for the year ended December 31, 2021. Additionally, SIPC has agreed to and acknowledged that the procedures performed are appropriate for their Intended purpose. This report may not be suitable for any other purpose. The procedures performed may not address all the items of interest to a user of this report and may not meet the needs of all users of this report and, as such, users are responsible for determining whether the procedures performed are appropriate for their purposes. The sufficiency of these procedures Is solely the responsibility of those parties specified In this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows: - 1. Compared the assessment payments made in accordance with the General Assessment Payment Form (Form SIPC-6) and applied to the General Assessment calculation on Form SIPC- 7 with respective cash disbursement record entries as follows: - a. We compared the amounts on page 1, item 28 on Form SIPC-6 to the amount on check #411000728 paid to SIPC on August 4, 2021 noting no differences. - b. We compared the amount on page 1, item 2G on Form SIPC- 7 to the amount on check # 41 1000811 paid to SIPC on February 9, 2022 noting no differences. - 2. Compared the amounts reported In the audited financial statements required by SEC Rule 17a-5 with the amounts reported in Form SIPC- 7 for the fiscal year ended December 31, 2021 as follows: - a. We compared total revenues amount of \$13,343,265 reported on page 4 of the audited financial statements on form X-17A-5 for the fiscal year ended December 31, 2021 with the total revenue amount of \$13,343,265 reported on page 2, item 2a in Form SIPC-7 for the fiscal year ended December 31, 2021 noting no differences. - 3. Compared any adjustments reported in Form SIPC- 7 with supporting schedules and working papers supporting the adjustments as follows: {22}------------------------------------------------ ![](_page_22_Picture_0.jpeg) ![](_page_22_Picture_1.jpeg) - a. Agreed the deduction of \$2,748,271 reported on page 2. item 2c(1) of Form SIPC-7 to the supporting schedule prepared by the Company, titled Ullico Investment Company, LLC's Placement Fees, which is derived from the accounting records used to prepare the audited financial statements on form X-17A-5 for the fiscal year ended December 31, 2021 noting no differences. - b. Agreed the deduction of \$1,137 of net gain from securities in investment accounts on line 2c(5) of Form SIPC-7 to the interest income reported on page 4 of the audited financial statements on form X-1 7A-5 for the fiscal year ended December 31, 2021 noting no differences. - 4. Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the schedules and working papers supporting the adjustments as follows: - a. Recalculated the arithmetical accuracy of the SIPC Net Operating Revenues on page 2, line 2d and the General Assessment at 0.0015 on page 2,line 2e of \$10,593,857 and \$15,890.79, respectively. of the Form SIPC-7, noting no differences. - b. Recalculated the arithmetical accuracy of the Ullico Investment Company. LLC's Placement Fees schedule referenced in 3a above. noting no differences. We were engaged by the Company to perform this agreed-upon procedures engagement and conducted our engagement in accordance with attestation standards established by the AICPA and in accordance with the standards of the Public Company Accounting Oversight Board (United States). An agreed-upon procedures engagement involves the practitioner performing specific procedures that the engaging party has agreed to and acknowledged to be appropriate for the purpose of the engagement and reporting on findings based on the procedures performed. We were not engaged to and did not conduct an examination or a review engagement. the objective of which would be the expression of an opinion or conclusion. respectively. on the Company's Form SIPC- 7 and for its compliance with the applicable instructions on Form SIPC-7 for the year ended December 31. 2021. Accordingly. we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. We are required to be independent of the Company and to meet our other ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-upon procedures engagement. This report is intended solely for the information and use of the specified parties listed above and is not intended to be. and should not be. used by anyone other than these specified parties. March 17, 2022 {23}------------------------------------------------ # **Ullico Investment Company LLC. Exemption Report** Ullico Investment Company LLC. (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. S240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following: (1) The Company does not claim an exemption under paragraph (k) of17 C.F.R. § 240.15c3-3, and (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. *\$*240.17a-5 because the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers; (2) did not carry accounts of or for customers; and (3) did not carry any PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. # Ullico Investment Company LLC. I, Adam Fried, swear and affirm that to my best knowledge and belief, this Exemption Report is true and correct. **(o«o** »L"=m± Title: Vice President, Chief Financial Officer, FINOP, Secretary & Treasurer Dated: 03/17/2022 ![](_page_23_Picture_9.jpeg) {24}------------------------------------------------ ![](_page_24_Picture_0.jpeg) Ernst& YoungLLP Tel. ·1215448 5000 2005 Market Street Fax ·'2154484069 Suite 700 eycom Pmladelpha, PA 19103 ## Report of Independent Registered Public Accounting Firm We have reviewed management's statements, included in the accompanying Ul ico Investment Company, LLC's Exemption Report. In which Ullico Investment Company, LLC (the Company) stated that: - (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3. - (2) The Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240. 17a-5 because. the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company, and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers: (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 ended December 31 . 2021. Management is responsible for compliance with 17 C.F .R. § 240. 15c3-3 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 the Company's compliance with 1 7 C.F.R. \$240.15c3-3.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, pursuant to footnote 74 of SEC Release No. 34- 70073 adopting amendments to 1 7 C.F.R. § 240. 17a-5. This report is intended solely for the information and use of the Board of Dí rectors. management. the SEC, FINRA, other regulatory agencies that rely on Rule 17a-5 under the Securities Exchange Act of 1934 in their regulation of registered brokers and dealers, and other recipients specified by Rule 17a-5(0)(6) and is not intended to be and should not be used by anyone other than these specified parties. *6t+ Jg* March 17, 2022 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.