# BRIDGEWATER JAMES LIMITED, LLC X-17A-5 (2019-02-28) — Broker-dealer annual report

- Company: BRIDGEWATER JAMES LIMITED, LLC
- Form: X-17A-5
- Filed: 2019-02-28
- Period: 2018-12-31
- Accession: 0001357351-19-000001
- CIK: 1357351
- File #: 8-67293
- Material weakness: No
- Auditor: Eisner Amper LLP
- Auditor location: San Francisco, CA
- Contact: Elizabeth Collins
- Phone: 415-526-2759
- Signed by: William Bennington (Managing Member)

Original filing: https://www.sec.gov/Archives/edgar/data/1357351/000135735119000001/bwj2018.pdf

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#### BRIDGEWATER JAMES LIMITED, LLC

FINANCIAL STATEMENTS TOGETHER WITH SUPPORTING SCHEDULES AND AUDITORS' REPORT

DECEMBER 31, 2018

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## TO THE COMMISSIONER OF CORPORATIONS OF THE STATE OF CALIFORNIA

### VERIFICATION FORM PURSUANT TO CALIFORNIA CODE OF REGULATIONS RULE 260.241.2(b)

## (Executed WITffiN OR WITHOUT of the State of California)

I, William J. Bennington, declare under penalty of peijury under the laws of the State of California that I have read the annexed fmancial report and supporting schedules and know the contents thereof to be true and correct to my best knowledge and belief; and neither the licensee nor any partner, officer, or director thereof have any proprietary interest in any account classified

solely as that of a customer.

Executed this t---1- day of (~1.. ~'1 <sup>c</sup> ,2019,at

San Francisco, California.

ilL J. Bennington gingMember

Bridgewater James Limited, LLC

140205 (File Number)

INSTRUCTIONS:

1. If the broker-dealer, investment adviser is a sole proprietorship, the verification shall be made by the proprietor; if a partnership, by a general partner; or if a corporation, by a duly authorized officer.

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UNITEDST ATES SECURITIES AND EXCHANGECOMMISSION Washington, D.C. 20549

## **ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill**

OMB APPROVAL OMBNumber: 3235-Q123 Expire\$; Augu\$t 31,2020 Estimated average burden hours per res~nse .. . . .. 12.00

| SEC FILE NUMBER |
|-----------------|
| B-67293         |

#### FACING PAGE

Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder

| REPORT FOR THE PERIOD BEGINNING January 1 • 2018                                                                             |                                                        |         | AND ENDING December 31, 2018       |  |
|------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------|---------|------------------------------------|--|
|                                                                                                                              | MM/00/YY<br>MM/ 00/YY                                  |         |                                    |  |
|                                                                                                                              | A. REGISTRANT IDENTIFICATION                           |         |                                    |  |
| NAME oF BROKER-DEALER: Bridgewater James Limited, LLC<br>ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)   |                                                        |         | OFFICIAL USE ONLY<br>FIRM I.D. NO. |  |
|                                                                                                                              |                                                        |         |                                    |  |
| One Maritime Plaza, Suite 2250                                                                                               |                                                        |         |                                    |  |
|                                                                                                                              | (No. and Street)                                       |         |                                    |  |
| San Francisco                                                                                                                | CA                                                     |         | 94111                              |  |
| (City)                                                                                                                       | (State)                                                |         | (Zip Code)                         |  |
| NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT<br>Willlam S.nnlngton (41 5) 6&4·!1466               |                                                        |         |                                    |  |
|                                                                                                                              |                                                        |         | (Arc:~ Code- Telephone Number)     |  |
|                                                                                                                              | B. ACCOUNT ANT IDENTIFICATION                          |         |                                    |  |
| INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained. in this Report•<br>Eisner Amper LLP                               |                                                        |         |                                    |  |
|                                                                                                                              | (Name - If Individual, star~ lasr, first, middl' nam') |         |                                    |  |
| One California St., Suite 1700                                                                                               | San Francisco                                          | CA      | 94111                              |  |
| (Addres.s)                                                                                                                   | (City)                                                 | ( Suue) | (Zip Code)                         |  |
| CHECK ONE:                                                                                                                   |                                                        |         |                                    |  |
| §<br>Certified Public Accountant<br>Public Accountant<br>Accountant not resident in United States or any of its possessions. |                                                        |         |                                    |  |
|                                                                                                                              | FOR OFFICIAL USE ONLY                                  |         |                                    |  |
|                                                                                                                              |                                                        |         |                                    |  |
|                                                                                                                              |                                                        |         |                                    |  |
|                                                                                                                              |                                                        |         |                                    |  |

*•claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.17a-5(e)(2)* 

> Potential persons who are to respond to the collection of Information contained In this form are not required to respond unless the form displays a currently valid OMB control number.

SEC 1410 (11 -05)

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#### **OATH OR AFFIRMATION**

| I, William J. Bennington                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             |                                                                                                                                                                   | , swear (or affirm) that, to the best of                                                                                                                                                                                                                                                                                                                               |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of<br>Bridgewater James Limited, LLC                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    |                                                                                                                                                                   | • as                                                                                                                                                                                                                                                                                                                                                                   |
| of December 31                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       | 20 18                                                                                                                                                             | are true and correct. I further swear (or affirm) that                                                                                                                                                                                                                                                                                                                 |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                                                                                                                   | neither the company nor any partner, proprietor, principal officer or director has any proprietary interest in any account                                                                                                                                                                                                                                             |
| classified solely as that of a customer, except as follows:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |                                                                                                                                                                   |                                                                                                                                                                                                                                                                                                                                                                        |
| lEAH M. RESCATE<br>~<br>Nolaty Public - Calilomia<br>1<br>s;<br>San Frar.osco Coon tv<br>i<br>t<br><br>COIMI SSI()Ill< 222'-477<br>:<br>: g:c!<br>(<br>My ec;:n<br>xo                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                | Managmg Member                                                                                                                                                    |                                                                                                                                                                                                                                                                                                                                                                        |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                                                                                                                   | Title                                                                                                                                                                                                                                                                                                                                                                  |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      | .re c.<br><j VL~ titf                                                                                                                                             | a ')tu ch ecA<br>)                                                                                                                                                                                                                                                                                                                                                     |
| This report •• contains (check all applicable boxes):<br>0 (a) Facing Page.<br>0 (b) Statement of Financial Condition.<br>~ (d) Statement of Changes in Financial Condition.<br>0 (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.<br>0 (f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.<br>' (g) Computation of Net Capital.<br>(h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.<br><br>(i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.<br>./<br>consolidation.<br>0<br>{I) An Oath or Affirmation.<br>D (m) A copy of the SIPC Supplemental Report. | of Comprehensive Income (as defined in §210.1-02 of Regulation S-X).<br>Computation for Determination of the Reserve Requirements Under Exhibit A of Rule l5c3-3. | IZJ (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement<br>0 G) A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3-l and the<br>0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      |                                                                                                                                                                   | D (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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#### **CALIFORNIA JURAT** GOVERNMENT CODE § 8202

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 truthfulness, accuracy, or validity of that document.

| Sao<br>~r\ Olr1G.(S co<br>County of  |                                                                                                                                                                                                                                                                                                                                                                                                              |
|--------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Place Notary Seal ond/or Stamp Above | Subscribed and sworn to (or affirmed) before me on<br>, 20~ by<br>1---t~<br>day of rehi'CIA UI";J<br>this<br>Date<br>Month<br>Year<br>u .<br>-------------=<br>r:s en n : f> 01 To n<br>If\} II \. 01 rn<br>'"----<br>o,J<br>(1)<br>_____ -r----<br>___ \\_1<br>_,/_A<br>(and (2)<br>Name(s) of Signer(f<br>proved to me 09 the basis of satisfactory evidence to<br>be the person(~ who appeared before me. |
| .-----------------------------       | ------------------------------,<br>OPTIONAL                                                                                                                                                                                                                                                                                                                                                                  |
|                                      | Completing this information can deter alteration of the document or<br>fraudulent reattachment of this form to on unintended document.                                                                                                                                                                                                                                                                       |
| Description of Attached Document     |                                                                                                                                                                                                                                                                                                                                                                                                              |
| Title or Type of Document:           | ----------------------------                                                                                                                                                                                                                                                                                                                                                                                 |
| Date:------------------<br>Document  | Number of Pages:--------                                                                                                                                                                                                                                                                                                                                                                                     |
| Signer(s) Other Than Named           | -----<br>Above:-------------------                                                                                                                                                                                                                                                                                                                                                                           |

<02018 National Notary Association

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# **EISNERAMPER** EisnerAmper LLP

#### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Member of Bridgewater James Limited, LLC

#### Opinion on the Financial Statements

We have audited the accompanying statement of financial condition of Bridgewater James Limited, LLC (the "Company") as of December 31 , 2018, and the related statements of operations, changes in member'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 as of December 31 , 2018, 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 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 well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

#### Report on Supplemental Information

The information contained in Schedules I, II, Ill, and IV (the "supplemental information") has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. The supplemental information is the responsibility of the Company's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the information contained in Schedules I, II, Ill, and IV 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 2012. Partners of Harb, Levy & Weiland LLP ("HLW') joined EisnerAmper LLP in 2012. HLW had served as the Company's auditor since 2006.

EISNERAMPER LLP San Francisco, California February 27, 2019

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## BRIDGEWATER JAMES LIMITED, LLC Statement ofFinancial Condition December 31,2018

| Assets                                |              |
|---------------------------------------|--------------|
| Cash                                  | \$<br>61,395 |
| Prepaid expenses                      | 15,309       |
| Equipment, net                        | 1,308        |
| Total assets                          | \$<br>78,012 |
| Liabilities and Member's Equity       |              |
| Accounts payable and accrued expenses | \$<br>8,905  |
| Member's equity                       | 69,107       |
| Total liabilities and member's equity | \$<br>78,012 |
|                                       |              |

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## BRIDGEWATER JAMES LIMITED, LLC Statement of Operations Year Ended December 31, 2018

| Revenue                | \$              |
|------------------------|-----------------|
| Expenses               |                 |
| Rent                   | 57,971          |
| Travel                 | 60,720          |
| Professional fees      | 45,693          |
| Telephone and Internet | 9,510           |
| Office Expenses        | 3,747           |
| Depreciation           | 1,499           |
| Other                  | 9,108           |
| Total expenses         | 188,248         |
| Net loss               | (188,248)<br>\$ |

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## BRIDGEWATER JAMES LIMITED, LLC Statement of Changes in Member's Equity Year Ended December 31, 2018

| Member's equity, beginning of the year | \$<br>257,355 |
|----------------------------------------|---------------|
| Net loss                               | ( 188,248)    |
| Member's equity, end of the year       | \$<br>69,107  |

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## BRIDGEWATER JAMES LIMITED, LLC Statement of Cash Flows Year Ended December 31, 2018

## *Cash flows from operating activities:*

| Net loss                                                                       | \$ (188,248) |
|--------------------------------------------------------------------------------|--------------|
| Adjustments to reconcile net loss to net cash<br>used in operating activities: |              |
| Depreciation                                                                   | 1,499        |
| Increase in prepaid expenses                                                   | (8,866)      |
| Increase in accounts payable and accrued expenses                              | 60           |
|                                                                                |              |
| Total adjustments                                                              | (7,307)      |
| Net cash used in operating activities                                          | (195,555)    |
| Cash flows from investing activities                                           |              |
| Purchase of equipment                                                          | (1 ,122)     |
| Net decrease in cash                                                           | (196,677)    |
| Cash, beginning of year                                                        | 258,072      |
| Cash, end of year                                                              | 61,395<br>\$ |
|                                                                                |              |

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## BRIDGEWATER JAMES LIMITED, LLC Notes to Financial Statements December 31, 2018

#### 1. Business and Summary of Significant Accounting Policies

#### Business

Bridgewater James Limited, LLC (the "Company") is a single member limited liability company managed by Mr. William J. Bennington. The Company is registered with the Securities and Exchange Commission as a fully disclosed securities broker-dealer and is a member of the Financial Industry Regulatory Authority, Inc. ("FfNRA"). The Company provides placement services to pnvate mvestment funds.

As a limited liability company, the member's liability is limited to amounts reflected in the member's capital account.

#### Cash

The Company maintains its cash in a bank deposit account which at times may exceed federally insured limits. The Company has not experienced any losses in such account and believes it is not exposed to any significant credit risk.

#### Equipment

Equipment includes furniture and office equipment recorded at cost net of accumulated depreciation of \$8,306. Depreciation is computed on an accelerated basis using an estimated economic life of 3 years.

#### Revenue Recognition

Effective January 1, 2018, the Company adopted the requirements ofFinancial Accounting Standard Board's ASU No. 2014-09, *Revenue from Contracts with Customers (Topic 606),* as amended. The Company completed its implementation analysis, reviewing current accounting pol ides and practices to identify potential differences that would result from applying the requirements under the new standard. The Company had evaluated the potential impacts of the new revenue recognition standards on its fmancial statements and has not identified any material changes in the timing of revenue recognition. The adoption of the new guidance for revenue recognition did not result in any changes to the financial statements for the year ended December 3 1, 2018.

During 20 18, the Company did not generate any revenue and did not have any contracts with customers.

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## BRIDGEWATER JAMES LIMITED, LLC Notes to Financial Statements December 31, 2018

## 1. Business and Summary of Significant Accounting Policies (continued)

#### Income Taxes

The Company is treated as a single member limited liability company for all relevant jurisdictions and its taxable income and taxes paid, if any, are included with the income tax return of the member. Management has concluded that the Company is not subject to income taxes in any jurisdiction and that there are no uncertain tax positions that would require recognition in the fmancial statements. Accordingly, no provision for income taxes is reflected in the accompanying financial statements. If the Company were to incur an income tax liability in the future, interest on any income tax liability would be reported as interest expense and penalties on any income tax liability would be reported as income taxes. Management's conclusions regarding uncertain tax positions may be subject to review and adjustment at a later date based upon ongoing analyses of tax laws, regulations and interpretations thereof as well as other factors.

#### Use ofEstirnates

The financial statements are prepared in accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP"). Financial statements prepared on a U.S. GAAP-basis require management to make estimates and assumptions that affect the amounts and disclosures reported in the financial statements and accompanying notes. Such estimates and assumptions could change in the future as more information becomes known, which could impact the amounts reported and disclosed herein.

#### 2. Net Capital Requirements

The Company is subject to the Securities and Exchange Commission Uniform Net Capital Rule (SEC R.ule 15c3-1 ), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defmed, shall not exceed 15 to 1. At December 31, 2018, the Company had net capital of \$52,490 which was \$47,490 in excess of its required net capital of \$5,000. The Company's aggregate indebtedness to net capital ratio was 0.1697 to 1.

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## BRIDGEWATER JAlvfES LIMITED, LLC Notes to Financial Statements December 31.2018

## 3. Operating Losses and Capital Contributions

The Company has generated no revenues and has recurring losses from operations. The sole member contributes capital, as necessary, so that the Company can meet its financial obligations.

The sole member has currently evaluated the Company's ability to meet its obligations and has assessed that the Company will have sufficient cash to meet its obligations over the next year.

## 4. Financial Instruments not Carried at Fair Value

The carrying value of financial assets and liabilities approximate estimated fair value. The company's financial instruments are classified within the fair value hierarchy as follows:

| Cash is carried at                                    | Level I    |
|-------------------------------------------------------|------------|
| Prepaid Expenses are carried at                       | Level2     |
| Accounts Payables and accrued expenses are carried at | Level<br>2 |

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## SUPPLEI\t1ENTARY INFORMATION

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## **FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT PART**  IIA

#### BROKER OR DEALER: BRIDGEWATER JAMES LIMITED, LLC as of December 31, 2018

| 1. Total ownership equity from Statement of Financial Condition •••                                           | \$<br>69,107 | 3480 |
|---------------------------------------------------------------------------------------------------------------|--------------|------|
| 2. Deduct ownership equity not allowable for Net Capital  .                                                   |              | 3490 |
| 3. Total ownership equity qualified for Net Capital  .                                                        | 69,107       | 3500 |
| 4. Add:                                                                                                       |              |      |
| A. Liabilities subordinated to claims of general creditors allowable in computation of net capital.  .        |              | 3520 |
| B. Other (deductions) or allowable credits (List)   .                                                         |              | 3525 |
| 5. Total capital and allowable subordinated liabilities  .                                                    | 69, 107      | 3530 |
| 6. Deductions and/or charges:                                                                                 |              |      |
| A. Total non-allowable assets from Statement of Financial Condition<br>(Notes Band C)<br>16.617<br>3540<br>\$ |              |      |
| B. Secured demand note delinquency<br>3590                                                                    |              |      |
| C. Commodity futures contracts and spot commodities- proprietary<br>capital charge.<br>3600                   |              |      |
| D. Other deductions and/or charges  .<br>3610                                                                 | ( 16.617)    | 3620 |
| 7. Other additions and/or allowable credits (list)  .                                                         |              | 3630 |
| 8. Net capital before haircuts on securities positions  .                                                     | 52.490       | 3640 |
| 9. Haircuts on securities (computed, Where applicable, pursuant to 15c3-1(f):                                 |              |      |
| A. Contractual securities commitments<br>13660                                                                |              |      |
| B. Subordinated securities borrowings  .                                                                      |              |      |
| C. Trading and Investment securities:                                                                         |              |      |
| 1. Exempted Securities  .<br>3735                                                                             |              |      |
| 2. Debt securities  .<br>3733                                                                                 |              |      |
| 3. Options<br>3730                                                                                            |              |      |
| 4. Other securities<br>3734                                                                                   |              |      |
| D. Undue Concentration<br>3650                                                                                |              |      |
| E. Other (List)  .<br>3736                                                                                    |              | 3740 |
| <br>10. Net Capital  .                                                                                        | 52.490       | 3750 |

OMIT PENNIES

#### Notes:

|                | Prepaid expenses | 15,309 |
|----------------|------------------|--------|
| Equipment, net | 1,308            |        |
|                |                  |        |

Total

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## **FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLE REPORT PART**  IIA

## BROKER OR DEALER: BRIDGEWATER JAMES LIMITED, UC as of December 3 I 20 I 8

COMPUTATION OF NET CAPITAL REQUIREMENT

#### Part A

| 11. Minimum net capital required (6 213% of line 19)  .                                                                                                                | \$<br>5g4    | 3756 |  |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|------|--|
| 12. Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital requirement<br>of subsidiaries computed in accordance with Note (A) • | 5,000        | 3758 |  |
| 13. Net capital requirement (greater of line 11 or 12)  .                                                                                                              | 5,000        | 3760 |  |
| 14. Excess net capital (line 10 less 13)                                                                                                                               | 47,490       | 3770 |  |
| 15. Excess net capital at greater of (10% of line 19 or 120% of line 12)                                                                                               | \$<br>46,490 | 3780 |  |

#### COMPUTATION OF AGGREGATE INDEBTEDNESS

| 16. Total A.l. liabilities from Statement of Financial Condition                          |                                                                                                   |      |                              |  | 8.905                                     | I<br>3790                  |
|-------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|------|------------------------------|--|-------------------------------------------|----------------------------|
| 17. Add:                                                                                  |                                                                                                   |      |                              |  |                                           |                            |
| A.                                                                                        | Drafts for immediate credit :::.S                                                                 | ____ | -1-.::.38:::0::0:__-1        |  |                                           |                            |
| B.                                                                                        | Market value of securities borrowed for which no equivalent value is<br>paid or credited  :;.\$ _ |      | ___<br>-+-.=.38;;.1.:;0:---i |  |                                           |                            |
| C.                                                                                        | Other unrecorded amounts (List) --"-\$                                                            | ____ | _._.::.38;:;;2:::0:_ _ _._   |  | ____                                      | __<br>_ --1_3:::8:::3::::0 |
| 19. Total Aggregate indebtedness  :::.\$                                                  |                                                                                                   |      |                              |  | __<br>;:8c:::.9::::0.::.5_+-3;:;;84::.::0 | __                         |
| 20. Percentage of aggregate indebtedness to net capital (line 19/ line 10)  .             |                                                                                                   |      |                              |  | 16.97%                                    | 3850                       |
| 21. Percentage of debt to debt-equity total computed in accordance with Rule 15c3-1(d)  . |                                                                                                   |      |                              |  | 0.00                                      | 3860                       |

#### COMPUTATION OF ALTERNATE NET CAPITAL REQUIREMENT

#### Part B

| 22. 2% of combined aggregate debit Items as shown in Formula for Reserve Requirement pursuant to Rule<br>15c3·3 prepared as of the date of the net capital computation including both brokers of dealers and<br>consolidated subsidiaries debits    . | 3970         |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| 23. Minimum dollar net capital requirement of reporting broker or dealer and minimum net capital requirement<br>or subsidiaries computed in accordance with Note (A)                                                                                  | 3880         |
| 24. Net capital requirement (greater of line 22 or 23)                                                                                                                                                                                                | 3760         |
| 25. Excess capital (line 10 or 24)  .<br>26. Net capital excess of the greater of:<br>A. 5% of combined aggregate debit items or 5120,000  .                                                                                                          | 3910<br>3920 |

#### NOTES:

- (A) The minimum net capital requirement should be computed by adding the minimum dollar net capital requirement of the reporting broker dealer and, for each subsidiary to be consolidated, the greater of.
	- 1. Minimum dollar net capital requirement, or
	- 2. 6 2/3% of aggr99ated indebtedness or 4% of aggregate debits if alternative method is used.
- (B) Do not deduct the value of securities borrowed under subordination agreements or secured demand note covered by subordination agreements not in satisfactory form and the rnarllet values of memberships in exchanges contributed for use of company (contra to item 1740) and partners' sea.Jrities which were induded in non-aiiO'Nable assets.
- (C) For reports filed pursuant to paragraph (d) of Rule 17a-5, respondent should provide a list of material non-allowable assets.

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### SCHEDULE II

BRIDGEWATER JAMES LIMITED, LLC Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3 December 31, 2018

The Company claims an exemption under Rule 15c3-3(k)(2)(i) and therefore is not subject to the reserve requirements ofRule 15c3-3.

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## SCHEDULE ill

## BRIDGEWATER JAMES LIMITED, LLC Information Relating to the Possession Or Control Requirements Under Rulel5c3-3 December 31, 201 8

The Company claims an exemption under Rule 15c3-3(k)(2)(i) and therefore is not subject to the possession or control provisions ofRule 15c3-3.

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#### SCHEDULE IV

## BRIDGEWATER JA11ES LIMITED, LLC Reconciliations Pursuant to Rules 15c3-1 and15c3-3 December 31,2018

## 1. Reconciliation of Computation ofNet Capital to Respondent's Computation

|                            |             |   | Aggregate    |   |            |  |
|----------------------------|-------------|---|--------------|---|------------|--|
|                            | Net CaRita! | - | Indebtedness | - | Percentage |  |
| Computation per respondent | 52,490      |   | \$<br>8,905  |   | 16.97%     |  |
| Computation per Schedule I | 52,490      | - | 8 905        |   | 16.97%     |  |
| Differences                | -<br>~      |   | s<br>-       |   |            |  |
|                            |             |   |              |   |            |  |

## 2. Reconciliation of Computation ofReserve Requirements to Respondent's Computations

The Company claims an exemption under Rule 15c3-3(k)(2)(i) and therefore is not subject to the reserve requirements ofRule 15c3-3.

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## **EISNERAMPER** EisnerAmper LLP

One California Street. Suite 1700 San Francisco, CA 94111 T 415.974.6000 F 415.974.5488

#### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM**

To the Member of Bridgewater James Limited, LLC

We have reviewed management's statements, included in the accompanying Exemption Report, in which (1} Bridgewater James Limited, LLC (the "Company"} identified the following provisions of 17 C.F.R. §15c3-3(k) under which the Company claimed an exemption from 17 C.F.R. §240.15c3-3: (2)(i) (the "exemption provisions"), and (2) the Company stated that it met the identified exemption provisions throughout the most recent fiscal year without exception. The Company'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 the Company's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.

Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k}(2}(i) of Rule 15c3-3 under the Securities Exchange Act of 1934.

LL?

EISNERAMPER LLP San Francisco, California February 27, 2019

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## Bridgewater James Limited, LLC Exemption Report

Bridgewater James Limited, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-s promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-s, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.17a-s(d)(1) and (4). To the best of its knowledge and belief, the Company states the following:

(1) The Company claimed an exemption from 17 C.F.R. § 240.15c3-3 under the following provision of 17 C.F.R. § 240.15c3-3 (kJ:[2] [i]

(2) The Company met the identified exemption provisions in 17 C.F.R. §240.15c3-3Ck) throughout the most recent fiscal year without exception.

Bridgewater James Limited, LLC

I, William J. Bennington, swear (or affirm) that, to my best knowledge and belief, this Ex tion Report is true and correct.

I~\_J~

liam J. Bennington a aging Member

February. 1.\_.-:r. 2019

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#### BRIDGEWATER JAMES LIMITED, LLC

FINANCIAL STATEMENTS TOGETHER WITH SUPPORTING SCHEDULES AND AUDITORS' REPORT

DECEMBER 31,2018


Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.
