# PRIVATE PLACEMENT INSURANCE PRODUCTS, LLC X-17A-5 (2020-02-13) — Broker-dealer annual report
- Company: PRIVATE PLACEMENT INSURANCE PRODUCTS, LLC
- Form: X-17A-5
- Filed: 2020-02-13
- Period: 2019-12-31
- Accession: 0001356559-20-000001
- CIK: 1356559
- File #: 8-67284
- Material weakness: No
- Auditor: Brian W. Anson CPA
- Auditor location: Tarzana, CA
- Contact: Tradyn Foley
- Phone: 7012351183
- Signed by: Turner Fixen (Registered Principal)
Original filing: https://www.sec.gov/Archives/edgar/data/1356559/000135655920000001/privateplace2019report.pdf
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**Private Placement Insurance Products, LLC Report Pursuant to Rule 17a-5 (d) Financial Statements For the Year Ended December 31, 2019**
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UNITEDSTATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549
# ANNUAL AUDITED REPORT FORM X-17A-5 PART III
OMB APPROVAL OMB Number: 3235-0123 Expires: August 31, 2020 Estimated average burden hours per response .. . . . . . 12.00
| SEC FILE NUMBER |
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| 8-67284 |
FACING PAGE
Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder
| AND ENDING 12/31/2019
A. REGISTRANT IDENTIFICATION
NAME OF BROKER-DEALER: Private Placement Insurance Products, LLC
ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)
NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
B. ACCOUNTANT IDENTIFICATION | MM/DD/YY
OFFICIAL USE ONLY
FRM I.D. NO.
58104
(Zip Code)
(Area Code - Telephone Number) |
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| CA | 91356 |
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| Accountant not resident in United States or any of its possessions. | |
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| | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report*
*Claims for exemption from the requirement that the annual renort be covered by the oninion of on independent while assounter |
must be supported by a statement of facts and circumstances relied on the exemption. See Section 240c accomination (2017
Potential persons who are to respond to the collection of information contained in this form are not required to respond mormation Sontained in this form are not required to respond
unless the form displays a currently valid OMB control number.
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#### OATH OR AFFIRMATION
I. Turner Fixen -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of Private Placement Insurance Products, LLC Castler , as Decem ber 3 | 3 | 3 | 3 | 8 , are true and correct. I further swear (or affirm) that of neither the company nor any partner, principal officer or director has any proprietary interest in any account classified solely as that of a customer, except as follows: LAVON JOHNSON Signature Notary Public State of North Dakota My Commission Expires Dec 12, 2022 Notary Public This report \*\* contains (check all applicable boxes): (a) Facing Page. (b) Statement of Financial Condition. (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement of Comprehensive Income (as defined in \$210.1-02 of Regulation S-X). (d) Statement of Changes in Financial Condition. (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital. (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors. (g) Computation of Net Capital. (h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3. (i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3. L (j) A Reconciliation, including appropriate explanation of Net Capital Under Rule 15c3-1 and the Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. (k) A Reconciliation between the audited Statements of Financial Condition with respect to methods of consolidation. (l) An Oath or Affirmation. (m) A copy of the SIPC Supplemental Report. (n) A report describing any material inadequacies found to exist or found to have existed since the date of the previous audit. \*\* For conditions of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).
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#### **Private Placement Insurance Products, LLC**
#### **Statement of Financial Condition December 31, 2019**
#### **Assets**
| Cash | \$
72,660 | |
|---------------------------------------|---------------|--|
| Accounts receivable | 17,992 | |
| Due from related party | 65,216 | |
| CRD Deposit | 2,000 | |
| Total assets | \$
157,868 | |
| Liabilities and Member's Equity | | |
| Liabilities | | |
| Commissions payable | \$
23,234 | |
| Due to related party | 19,982 | |
| Total liabilities | 43,216 | |
| Member's equity | | |
| Member's equity | 114,652 | |
| Total member's equity | 114,652 | |
| Total liabilities and member's equity | \$
157,868 | |
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## **Private Placement Insurance Products, LLC Statement of Income For the Year Ended December 31, 2019**
#### **Revenues**
| Revenues from the Sale of Insurance Based Products | | 938,371 |
|----------------------------------------------------|----|---------|
| Total revenues | | 938,371 |
| Expenses | | |
| Employee compensation and benefits | | 133,794 |
| Commission | | 546,470 |
| Professional fees | | 24,537 |
| Insurance expense | | 36,673 |
| Occupancy expense | | 33,281 |
| Other operating expenses | | 78,707 |
| Total expenses | | 853,462 |
| Net income (loss) before income tax provision | | 84,909 |
| Income tax provision | | 3,300 |
| Net income (loss) | \$ | 81,609 |
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# **Private Placement Insurance Products, LLC Statement of Changes in Member's Equity For the Year Ended December 31, 2019**
| | Member's
Equity | | | |
|------------------------------|--------------------|----------|--|--|
| Balance at December 31, 2018 | \$ | 117,043 | | |
| Member's distributions | | (84,000) | | |
| Net income (loss) | | 81,609 | | |
| Balance at December 31, 2019 | \$ | 114,652 | | |
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## **Private Placement Insurance Products, LLC Statement of Cash Flows For the Year Ended December 31, 2019**
| Cash flow from operating activities: | | | |
|------------------------------------------------------------------------|----|------------------|--------------|
| Net income (loss)
Adjustments to reconcile net income (loss) to net | | | \$
81,609 |
| cash provided by (used in) operating activities: | | | |
| (Increase) decrease in assets: | | | |
| Accounts receivable | | | |
| Due from related party | | | |
| | \$ | (377)
(2,233) | |
| Increase (decrease) in liabilities: | | | |
| Commissions payable | | (11,470) | |
| Due to related party | | (132) | |
| Total adjustments | | | (14,212) |
| Net cash provided by (used in) operating activities | | | 67,397 |
| Net cash provided by (used in) in investing activities | | | - |
| Cash flow from financing activities:
Member distributions | | (84,000) | |
| Net cash provided by (used in) financing activities | | | (84,000) |
| Net increase (decrease) in cash | | | ( 16,603) |
| Cash at beginning of year | | | 89,263 |
| Cash at end of year | | | \$
72,660 |
| Supplemental disclosure of cash flow information: | | | |
| Cash paid during the year for: | | | |
| Interest | \$ | - | |
| Income taxes | \$ | 3,300 | |
*The accompanying notes are an integral part of these financial statements.*
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### **Note 1: GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES**
#### *General*
Private Placement Insurance Products, LLC (the "Company"), was originally organized in the State of Delaware on March 14, 2005, and was approved to conduct business in California on August 17, 2006. The Company is a single member limited liability company operating as a registered broker/dealer in securities under the Securities and Exchange Act of 1934, and is a member of the Financial Industry Regulatory Authority ("FINRA").
The Company is authorized to sell variable life insurance or annuities, and private placement of variable life insurance or annuities on a best efforts basis. The Company assists in the placement of and due diligence for Bank Owned Life Insurance (BOLI) and Corporate Owned Life Insurance (COLI) plans.
Under its membership agreement with FINRA and pursuant to Rule 15c3-3(k) (2)(i), the Company conducts business on a fully disclosed basis and does not execute or clear securities transactions for customers. Accordingly, the Company is exempt from the requirement of Rule 15c3-3 under the Securities Exchange Act of 1934 pertaining to the possession or control of customer assets and reserve requirements.
#### *Summary of Significant Accounting Policies*
The presentation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates.
Accounts receivable are stated at face amount with no allowance for doubtful accounts. An allowance for doubtful accounts is not considered necessary because probable uncollectible accounts are immaterial.
Rent expense for the year ended December 31, 2019, was \$33,281 included in occupancy expense. The amount of rent is determined annually by the expense sharing agreement.
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### **Note 1: GENERAL AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)**
All tax effects of the Company's income or loss are passed through to the member. Therefore, no provision or liability for Federal Income Taxes is included in these financial statements.
The Company has evaluated events subsequent to the balance sheet date for items requiring recording or disclosure in the financial statements. The evaluation was performed through February 6, 2020, the date the financial statements were available to be issued. Based upon this review, the Company has determined that there were no events which took place that would have a material impact on its financial statements.
### *Revenue*
Significant accounting policy
Revenue is measured based on a consideration specified in a contract with a customer, and excludes any sales incentives and amounts collected on behalf of third parties. The Company recognizes revenue when it satisfied a performance obligation by transferring control over a product or service to a customer.
Taxes and regulatory fees assessed by a government authority or agency that are both imposed on and concurrent with a specified revenue-producing transaction, that are collected by the Company from a customer, are from revenue.
Nature of services
The following is a description of activities – separated by reportable segments, per FINRA Form "Supplemental Statement of Income (SSOI)"; from which the Company generates its revenue. For more detailed information about reportable segments.
Revenue from the sale of Investment Company Shares: This includes concessions earned from the sale of open-end mutual funds that contain a load. Included are commissions charged on transactions on no load funds and UIT's to the extent they are open end companies.
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#### **Note 2: INCOME TAXES**
The Company is treated as a disregarded entity for federal income tax purposes, in accordance with single member limited liability company rules. All tax effects of the Company's income or loss are passed through to the member. Therefore, no provision or liability for Federal Income Taxes is included in these financial statements.
The Company is subject to audit by the taxing agencies for the years of 2016, 2017, and 2018.
The Company is subject to a limited liability company gross receipts tax, with a minimum franchise tax. As of December 31, 2019, the income tax provision consists of the following:
| Franchise tax | \$
800 |
|----------------------------|-----------|
| Gross receipts tax | 2,500 |
| Total income tax provision | \$ 3,300 |
#### **Note 3: RELATED PARTY TRANSACTIONS**
The sole member in the Company is also a member in a related entity - MB Schoen & Associates, Inc. (MBSA). The Company has an expense sharing agreement with the related entity. As outlined in the agreement, rent, salaries, and other operating expenses will be shared. For the year ending December 31, 2019 \$240,320, of operating costs were allocated from the related entity to the Company. At December 31, 2019, \$65,216 was due from MBSA. In addition, \$19,982 was due to MBSA as of December 31, 2019.
For the year ended December 31, 2019, 62% of the Company's revenue passed through the related entity. This revenue represents trail commissions earned by the sole member, but earmarked for the Company to fund its operations. In addition, \$388,070 in commissions expense was redirected commissions paid to MBSA.
It is possible that the terms of certain of the related party transactions are not the same as those that would result for transactions among wholly unrelated parties.
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## **Note 3: RELATED PARTY TRANSACTIONS (Continued)**
In February 2016 the FASB issued ASU 2016-02 on Leases. Under the new guidance lessees are required to recognize a lease liability and a right-to-use asset for all leases at the commencement date, with the exception of short-term leases. ASU 2016-02 is effective for annual and interim periods beginning after December 15, 2018 and early adoption is permitted. The company is not subjected to this requirement inasmuch as it has an expense sharing agreement with its Parent.
#### **Note 4: CONCENTRATION OF CREDIT RISKS**
For the year ended December 31, 2019, 80% of the commissions were earned from four clients.
#### **Note 5: NET CAPITAL REQUIREMENTS**
The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC rule 15c3-1), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined, shall not exceed 15 to 1. Rule 15c3-1 also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital ratio would exceed 10 to 1. Net capital and aggregate indebtedness change day to day, but on December 31, 2019, the Company had net capital of \$50,590 which was \$45,590 in excess of its required net capital of \$5,000 or 6-2/3 of A.I.; and the Company's ratio of aggregate indebtedness (\$43,217) to net capital was .86 to 1, which is less than the 15 to 1 maximum allowed.
#### **Note 6: RECONCILIATION OF AUDITED NET CAPITAL TO UNAUDITED FOCUS**
There was no difference between the computation of net capital under net capital SEC Rule 15c3-1 and the corresponding unaudited FOCUS part IIA.
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#### **Note 7: COMMITMENTS AND CONTINGENCIES**
The Company is required to file income tax returns in state tax jurisdictions. The Company's tax returns are subject to examination by taxing authorities in the jurisdictions in which it operates in accordance with the normal statutes of limitations in the applicable jurisdiction. The statute of limitations for state purposes is generally three years, but may exceed this limitation depending upon the jurisdiction involved. Returns that were filed within the applicable statute remain subject to examination. As of December 31, 2019, no jurisdiction has proposed any adjustment to the Company's tax position.
### **Note 8: GUARANTEES**
FASB ASC 460, Guarantees, requires the Company to disclose information about its obligations under certain guarantee arrangements. FASB ASC 460 defines guarantees as contracts and indemnification agreements that contingently require a guarantor to make payments to the guaranteed party based on changes in an underlying factor (such as an interest or foreign exchange rate, security or commodity price, an index or the occurrence or nonoccurrence of a specified event) related to an asset, liability or equity security of a guaranteed party. This guidance also defines guarantees as contracts that contingently require the guarantor to make payments to the guaranteed party based on another entity's failure to perform under an agreement as well as indirect guarantees of indebtedness of others.
The Company has issued no guarantees at December 31, 2019 or during the year then ended.
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#### **Private Placement Insurance Products, LLC Schedule I - Computation of Net Capital Requirements Pursuant to Rule 15c3-1 As of December 31, 2019**
| Computation of net capital | | |
|-----------------------------------------------------------------------------|---------------------|---------------|
| Member's equity | \$
114,652 | |
| Total member's equity | | \$
114,652 |
| Less: Non-allowable assets | | |
| Due from related party
CRD Deposit | (62,062)
(2,000) | |
| Total non-allowable assets | | (64,062 ) |
| Net capital | | 50,590 |
| Computation of net capital requirements
Minimum net capital requirements | | |
| 6 2/3 percent of net aggregate indebtedness | \$
2,883 | |
| Minimum dollar net capital required | \$
5,000 | |
| Net capital required (greater of above) | | (5,000) |
| Excess net capital | | \$
45,590 |
| Ratio of aggregate indebtedness to net capital | .86: 1 | |
There was no difference in net capital computation shown here and the net capital computation shown on the Company's unaudited Form X-17A-5 report dated December 31, 2019 (See Note 6).
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## Private Placement Insurance Products, LLC **Schedule II- Computation for Determining of Reserve Requirements Pursuant to Rule 15c3-3 As of December 31, 2019**
A computation of reserve requirements is not applicable to Private Placement Insurance Products, LLC as the Company qualifies for exemption under Rule 15c3-3(k)(2)(i).
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## Private Placement Insurance Products, LLC **Schedule III - Information Relating to Possession or Control Requirements Pursuant to Rule 15c3-3 As of December 31, 2019**
Information relating to possession or control requirements is not applicable to Private Placement Insurance Products, LLC as the Company qualifies for exemption under Rule 15c3-3(k)(2)(i).
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BRIAN W. ANSON
Certified Public Accountant
18401 Burbank Blvd., Suite 120, Tarzana, CA 91356 · Tel. (818) 636-5660 · Fax (818) 401-8818
#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
Board of Members Private Placement Insurance Products, LLC Fargo, North Dakota
I have reviewed management's statements, included in the accompanying Exemption Report in which (1) Private Placement Insurance Products, LLC, identified the following provisions of 17 C.F.R. §15c3-3(k) under which Private Placement Insurance Products, LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (k)(2)(i) (the "exemption provisions") and (2) Private Placement Insurance Products, LLC, stated that Private Placement Insurance Products, LLC, met the identified exemption provisions throughout the most recent fiscal year without exception. Private Placement Insurance Products, LLC's management is responsible for compliance with the exemption provisions and its statements.
My 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 Private Placement Insurance Products, LLC's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, I do not express such an opinion.
Based on my review, I am 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 paragraph (k)(2)(i) of Rule 15c3-3 under the Securities Exchange Act of 1934.
Brian W. Anson Certified Public Accountant Tarzana, California February 6, 2020
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RONALD BORIO FINOP
OFFICE (619) 246·9428 EMAIL RBORIO@COLIAUDlT.COM
# **Assertions Regarding Exemption Provisions**
We, as members of management of Private Placement Insurance Products, LLC ("the Company "), are responsible for compliance with the annual reporting requirements under Rule 17a-5 of the Securities Exchange Act of 1934. Those requirements compel a broker or dealer to file annuals reports with the Securities Exchange Commission (SEC) and the broker or dealer's designated examining authority (DEA). One of the reports to be included in the annual filing is an exemption report prepared by an independent public accountant based upon a review of assertions provided by the broker or dealer. Pursuant to that requirement , the management of the Company hereby makes the following assertions:
#### **Identified Exemption Provision:**
The Proprietor claims exemption from the custody and reserve provisions of Rule 15c3 3 by operating under the exemption provided by Rule 15c3-3 , Paragraph (k)(2)(1)
#### **Statement Regarding Meeting Exemption Provision:**
The Company met the identified exemption provision without exception throughout the period ending: January 1,2019 through December 31,2019.
Private Placement Insurance Products , LLC
By:
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#### BRIAN W. ANSON
Certified Public Accountant
18401 Burbank Blvd., Suite 120, Tarzana, CA 91356 · Tel. (818) 636-5660 · Fax (818) 401-8818
#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPLYING AGREED-UPON PROCEDURES RELATED TO AN ENTITY'S CLAIM FOR EXCLUSION FROM MEMBERSHIP IN SIPC
To the Board of Members of Private Placement Insurance Products, LLC
In accordance with Rule 17a-5(e)(4) of the Securities and Exchange Commission Act of 1934 and with the SIPC Series 600 Rules, I have performed the procedures enumerated below with respect to the accompanying Schedule of Form SIPC-3 Revenues of Private Placement Insurance Products, LLC or the year ended December 31, 2019, which were agreed to by Private Placement Insurance Products, LLC IO nnd the Securities Investor Protection (SIPC), solely to assist you and SIPC in evaluating Private Placement Insurance Products, LLC's compliance with the exclusion requirements from membership in SIPC under section 78ccc(a)(2)(A) of the Securities Investor Protection Act of 1970 durine the year ended December 31, 2019 as noted on the accompanying Certification of Exclusion from Membership (Form SIPC-3). Private Placement Insurance Products, LLC's management is responsible for Private Placement Insurance Products, LLC's compliance with those requirements. This agreed-upon ITrocedures engagement was conducted in accordance with attestation standards established by the Public Company Accounting Oversight Board (United States). The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, I 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 I performed and my findings are as foot in
- 1) Compared the Total amount included in the accompanying Schedule of Form SIPC-3 Revenues prepared by Private Placement Insurance Products, LLC for the year ended December 31, 2019 to the total revenues in Private Placement Insurance Products, LLC's audited financial statements in luded on Annual Audited Report Form X-17A-5 Part III for the year ended December 31, 2019, noting no differences;
- 2) Compared the amount in each revenue classification reported in the Schedule of Form SIPC-3 Revenues prepared by Private Placement Insurance Products, LLC for the year ended December 31, 2019 to supporting schedules and workpapers, noting no differences;
- 3) Recalculated the arithmetical accuracy of the Total Revenues amount reflected in the Schedule of Form SIPC-3 Revenues prepared by Private Placement Insurance Products, LLC for the year ended December 31, 2019 and in the related schedules and workpapers, noting no differences.
I was not engaged to, and did not conduct an examination, the objective of which would be the expression of an opinion on Private Placement Insurance Products, LLC's claim for exclusion from membership in SIPC. Accordingly, I do not express such an opinion. Had I performed additional proomines, other matters might have come to my attention that would have been reported to you.
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.
Brian W. Anson. CPA Tarzana, California February 6, 2020
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| Securities Investor Protection Corporation
1667 K Street NW, Ste 1000
Washington, DC 20006-1620
Forwarding and Address Correction Requested | Check appropriate boxes.
(i) its principal business, in the determination of SIPC, taking into account business of affiliated
entities, is conducted outside the United States and its territories and possessions; *
its business as a broker-dealer is expected to consist exclusively of:
the distribution of shares of registered open end investment companies or unit investment trusts;
(II) the sale of variable annuities;
(III) the business of insurance;
(IV) the business of rendering investment advisory services to one or more registered investment
companies or insurance company separate accounts:
[(iii) it is registered pursuant to 15 U.S.C. 780(b)(11)(A) as a broker-dealer with respect to transactions in
securities futures products;
Pursuant to the terms of this form (detailed below).
119/2019
Co-ce
Authorized Signature/Title
IDate | |
|------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| 8- | | |
| 8-67284 FINRA DEC
08/16/2006
PRIVATE PLACEMENT INSURANCE PRODUCTS DEC
2754 BRANDT DR SO STE 200
FARGO, ND 58104 | Securities Investor Protection Corporation
1667 K Street NW, Ste 1000
Washington, DC 20006-1620 | |
Form SIPC-3
6
SIPC-3 20 1
# FY 201 9
#### Certification of Exclusion From Membership.
TO BE FILED BY A BROKER-DEALER WHO CLAIMS EXCLUSION FROM MEMBERSHIP IN THE SECURITIES INVESTOR PROTECTION CORPORATION ("SIPC") UNDER SECTION 78cc(a)(2)(A) OF THE SECURITIES INVESTOR PROTECTION ACT OF 1970 ("SIPA").
The above broker-dealer certifies that during the fiscal year ending 12/31/2019 to consist exclusively of one or more of the following (check appropriate boxes):
[ (i) its principal business, in the determination of SIPC, taking into account business, is conducted outside the United States and its territories and possessions; \*
(ii) its business as a broker-dealer is expected to consist exclusively of:
- (1) the distribution of shares of registered open end investment companies or unit investment trusts;
- the sale of variable annuities; (11)
- (III) the business of insurance;
- (IV) the business of rendering investment advisory services to one or more registered investment companies or insurance company separate accounts;
- [ (ii) it is registered pursuant to 15 U.S.C. 780(b)(1)(A) as a broker-dealer with respect to transactions in securities futures products;
and that, therefore, under section 78ccc(a)(2)(A) of SIPA it is excluded from membership in SIPC.
\*If you have any questions concerning the foreign exclusion please contact SIPC via telephone at 202-371-8300 or e-mail at asksipc@sipc.org to request a foreign exclusion questionnaire.
The following bylaw was adopted by the Board of Directors:
Interest on Assessments.
... If any broker or dealer has incorrectly filed a claim for exclusion from membership in the Corporation, such broker or dealer shall pay, in addition to all assessments due, interest at the rate of 20% per annum of the unpaid assessment for each day it has not been paid since the date on which it should have been paid.
In the event of any subsequent change in the undersigned broker-dealer that would terminate such broker-dealer's exclusion from membership in SIPC pursuant to section 78cc(a)(2)(A) of the SIPA, the undersigned broker-dealer will immediately give SIPC written notice thereof and make payment of all assessments thereafter required under section 78dd(c) of the SIPA.
Sign, date and return this form no later than 30 days after the beginning of the enclosed return envelope.
Retain a copy of this form for a period of not less than 6 years, the latest 2 years in an easily accessible place.
Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.