# BUILDER ADVISOR GROUP, LLC X-17A-5 (2019-02-28) — Broker-dealer annual report - Company: BUILDER ADVISOR GROUP, LLC - Form: X-17A-5 - Filed: 2019-02-28 - Period: 2018-12-31 - Accession: 0001511838-19-000001 - CIK: 1511838 - File #: 8-68801 - Material weakness: No - Auditor: Ernst Wintter & Associates - Auditor location: Walnut Creek, CA - Contact: Elizabeth Collins - Phone: 415-526-2759 - Signed by: Elizabeth S. Collins (FINOP) Original filing: https://www.sec.gov/Archives/edgar/data/1511838/000151183819000001/bagaduit.pdf --- {0}------------------------------------------------ Annual Audit Report December 31, 2018 {1}------------------------------------------------ UNITEDST A TES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549 OMS APPROVAL OMB Number: 3235·0123 Expires: August 31, 2020 Estimated average burden hoursQer response ........ 12.00 8-68801 SEC FILE NUMBER # ANNUAL AUDITED REPORT FORM X-17A-5 PART Ill #### FACING PAGE Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-S Thereunder | REPORT FOR THE PERIOD BEGINNING | ____
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_ | |------------------------------------------------------------------------------------------------------------------|----------------------------------------------------|-------------------------|--------------------------------| | | MMIDD/YY | | MIMIDD/YY | | | A. REGISTRANT IDENTIFICATION | | | | NAME OF BROKER-DEALER: Builder Advisor Group, LLC | | | OFFICIAL USE ONLY | | ADDRESS OF PRfNClPAL PLACE OF BUSINESS: (Do not use P.O. Box No.)
One Letterman Drive, BuiJding C, Suite 3800 | | FIRM 1.0. NO. | | | | (No and Street) | | | | San Francisco
California | | 94129 | | | {Ctty)
{State) | | {Z1p Code) | | | NAME AND TELEPHONE NUMBER OF PERSO TO CONTACT I
Elizabeth S. Collins | | REGARD TO THJS REPORT | (415) 526-2759 | | | | | (Area Code - Telephone Number) | | | | | | | | B. ACCOUNTANT IDENTIFICATION | | | | fNDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | Ernst Wintter & Associates LLP | | | | | | (Name-tfmdividun/, state last, first, nuddlt namt) | | | | 675 Ygnacio Valley Road, S uite A200 | Walnut Creek | California | 94526 | | (Address) | {Cuy) | {State) | (Z1p Code) | | | | | | | CHECK ONE: | | | | | Certified Public Accountant
Public Accountant | | | | | §
Accountant not resident in United States or any of its possessions. | | | | *•c laims for exemption from* I *he requirement that the annual report be covered by the opinion of an independent public accountant musl be supported by a statement of f acts and circumstances relied on as* I *he 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 (06-02) {2}------------------------------------------------ #### **OATH** OR AFFIRMATION I, Elizabeth S. Collins, affirm that, to the best of my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of Builder Ad\•isor Group, LLC, as of December 31,2018, are true and correct. I further 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: NONE |
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A tached | Signature
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Tnle | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Notary Public | | | This report •• contains (check all applicable bo.xes):
(a) Facing Page.
C2l
C2l (b) Statement of Financial Condition.
C2l (c) Statement of Income (Loss).
~ (d) Statement of Changes in Financial Condition.
C2l (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors'
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(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
C2l (g) Computation ofNet Capital.
C2l (h) Computation for Determination of Reserve Requirements Pursuant to Rule
C2l (i) Information Relating to the Possession or Control Requirements Under Rule
C2l
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule
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consolidation.
'21 (I) An Oath or Affirmation. | Capital.
15c3-3.
I Sc3-3.
G) A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3-l and the
15c3-3.
(k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of | | 0
{m) A copy of the SIPC Supplemental Report.
0 | (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.* f *7a-5(e){3).* {3}------------------------------------------------ ## **CALIFORNIA JURAT** 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. State of California County of Marin ![](_page_3_Picture_4.jpeg) Subscribed and sworn to (or affirmed) before me on this day of D L 20fl by Date Montll Year (1) £ 1'rzf1 6e *t* h S col /)Yl j Name of Sl"'tr proved to me on the basis of satisfactory evidence to be the person who appeared before me (.) (,) (and) (2) \_\_\_ \_ \_\_\_\_\_\_\_\_ \_ ---J Name or Slantr proved to me on the basis of satisfactory evidence to be the person who appeared before me. - Placo Notary s .. l Above Further description of Any Attached Document Title or Type of Document:. \_ \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_ Document Date: - ------- - ----- Number of Pages \_\_ \_ Signer(s) Other Than Named Above:-------- - -------- {4}------------------------------------------------ #### **Table of Contents** | Report oflndependent Registered Public Accounting Finn | | |----------------------------------------------------------------------------------------------------------------------------|----------| | Statement of Financial Condition | 2 | | Statement of Income | 3 | | Statement of Changes in Member's Equity | 4 | | Statement of Cash Flows | 5 | | Notes to the Financial Statements | 6-
10 | | Supporting Schedules | 11 | | Schedule 1: | 12 | | Computation ofNet Capital Under Rule 15c3-1
of the Securities and Exchange Commission | | | Reconciliation with Company's Net Capital Computation | | | Schedule II: | 13 | | Computation for Determination of Reserve Requirements
Under Rule 15c3-3 of the Securities and Exchange Commission | | | Information Relating to Possession or Control Requirements
Under Rule 15c3-3 of the Securities and Exchange Conunission | | | Report on Exemption Provisions | 14 | | Review Report of the Independent Registered Public Accounting Finn | 15 | | SEA Rule 15c3-3 Exemption Report | 16 | {5}------------------------------------------------ #### *ERNST WINTTER* & *ASSOCIATES LLP Certified Public Accountants* *675 Ygnacio Valley Road, Suite A200 Walnut Creek, CA 94596* *(925) 933-2626 Fax (925) 944-6333* #### Report of Independent Registered Public Accounting Firm To the Member of Builder Advisor Group, LLC #### Opinion on t he Financial Statements We have audited the accompanying statement of financial condition of Builder Advisor Group, LLC (the "Company') as of December 3 l, 2018, the related statements of income, changes in member's equity, and cash flows for the year then ended, and the related notes and schedules I and II (collectively referred to as the financial statements). In our opinion, the financial statements present fairly, in all material respects, the fmancial 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 fmancial statements based on our audit. We are a public accounting firm registered with the Pub lic 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. #### Supplemental Information Schedules I and II have 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, Schedules I and 11 are fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as Builder Advisor Group, LLC's auditor since 2013. Walnut Creek, California February 28, 2019 {6}------------------------------------------------ # Statement of Financial Condition December 31, 2018 | Assets | | |---------------------|---------------| | Cash | \$
360,478 | | Accounts receivable | 225,666 | | Prepaid expenses | 14,417 | | Total Assets | \$
600,561 | | Liabilities | | | Accounts payable | \$
19,306 | | Due to affiliate | 53,070 | | Total Liabilities | | | | 72,376 | | Member's Equity | 528,185 | {7}------------------------------------------------ ### Statement of Income ### For the Year Ended December 31, 2018 | Revenue | | |--------------------------|-----------------| | Investment banking | 8,665,045
\$ | | Reimbursed expenses | 54,842 | | Total Revenue | 8,719,887 | | Expenses | | | Professional fees | 486,245 | | Reimbursable expenses | 52,582 | | Dues and subscriptions | 14,740 | | Bad debt | 2,260 | | Other operating expenses | 58,281 | | Total Expenses | 6
14,108 | | Net Income | 8,105,779
\$ | {8}------------------------------------------------ # Statement of Changes in Member's Equity # For the Year Ended December 31, 2018 | Member's Equity as of January 1, 2018 | \$
292,406 | |-----------------------------------------|---------------| | Distributions | (7 ,870,000) | | Net income | 8,105,779 | | Member's Equity as of December 31, 2018 | \$
528,185 | {9}------------------------------------------------ ### Statement of Cash Flows # For the Year Ended December 31, 2018 | Cash F
lows from Operating Activities | | |-----------------------------------------------|-----------------| | Net income | \$
8,105,779 | | Adjustments to reconcile net income | | | to net cash provided by operating activities: | | | (Increase) decrease in: | | | Accounts receivable | (37,472) | | Prepaid expenses | (6,167) | | Increase (decrease) in: | | | Accounts payable | 9,317 | | Due to affiliate | 30,371 | | Net Cash Provided by Operating Activities | 8,101,828 | | Cash F
lows from Financing Activities | | | Distributions | (7,870,000) | | Net Cash Used by Fiinancing Activities | (7,870,000) | | Net Increase in Cash | 231,828 | | Cash at beginning of year | 128,650 | | Cash at End of Year | \$
360,478 | {10}------------------------------------------------ ### Notes to the Financial Statements ### December 31, 2018 ### 1. Organization Builder Advisor Group, LLC (the "Company") was organized as a California limited liability company in October 2010. The Company is owned by its sole member, Efficient Builder Technology Corporation (the "Member"), and operates in San Francisco, California. Under this form of organization, the Member is not liable for the debts of the Company. The Company is a securities broker dealer and registered with the Securities and Exchange Commission ("SEC") and the Financial Industry Regulatory Authority ("FINRA") in March 2012. The Company engages in advisory services and private placements of securities. ### 2. Significant Accounting Policies ### Cash and Cash Equivalents The Company considers all demand deposits held in banks and certain highly liquid investments with original maturities of three months or less, other than those held for sale in the ordinary course of business, to be cash equivalents. There were no cash equivalents at December 31, 20 18. #### Accounts Receivable Accounts receivable represents amounts that have been billed to clients in accordance with the Company's engagement letters with respective clients that have not yet been collected. Management reviews accounts receivable and sets up an allowance for doubtful accounts when collection of a receivable becomes unlikely. The Company considers accounts receivable to be fully collectible, and accordingly, no allowance for doubtful accounts has been provided. #### Use of Estimates The preparation of financial statements in accordance with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions tihat affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates and may have an impact on future periods. #### Fair Value of Financial Instruments Unless otherwise indicated, the fair values of all reported assets and liabilities that represent financial instruments approximate the carrying values of such amounts. No assets or liabilities are required to be carried at fair value as of December 31, 2018. The Company has no financial instruments required to be reported at fair value on a recurring basis. #### Income Taxes The Company, a limited liability company, is treated as a disregarded entity for tax purposes. In lieu of income taxes, the Company passes 100% of its taxable income and expenses to the Member. Therefore, no provision or liability for federal or state income taxes is included in these financial statements. The Company is however, subject to the annual California limited liability company tax of \$800 and a California limited liability company fee based on gross revenue. The Company is no longer subject to examinations by major tax jurisdictions for years before 2014. The Company does not believe they have any uncertain tax positions. {11}------------------------------------------------ ### Notes to the Financial Statements December 31, 2018 #### 3. New Accounting Pronouncements #### Recently IssUled Accounting Guidance ### ASU 2016-13 *Measurement* qf *Credit ]-Os.res on Financial l!l.rtrument.r* ("ASU 2016-13'? ln June 2016, the F ASB issued ASU 2016-13 which will change the impairment model for most financial assets and require additional disclosures. The amended guidance requires financial assets that are measured at amortized cost be presented at the net amount expected to be collected. The allowance for credit losses is a valuation account that is deducted from the amortized cost basis of the financial assets. The amended guidance also requires us to consider historical experience, current conditions, and reasonable and supportable forecasts that affect the collectibility of the reported amount in estimating credit losses. ASU 2016-13 is effective for us commencing iin the first quarter of fiscal 2020 and will be applied through a cumulative-effect adjustment to retained earnings at the beginning of the year of adoption. Early adoption is permitted. We are currently evaluating the impact ofthe adoption of this standard on our financial statements and do not expect a material impact. #### Recently Adopted Accounting Guidance #### ASU 20 14-09 *Revenue from Contracts with Customers* (" ASU 20 14-09") Effective January 1, 2018, the Company adopted ASU 2014-09, which provides accotmting guidance on the recognition of revenues from contracts and requires gross presentation of certain costs that were previously offset against revenue. The Company has applied ASU 2014-09 under the full retrospective method with the cumulative effect of initial application recognized as an adjustment to beginning retained earnings. As a result, there was no beginning balance effect on the fmancial statements for the year ended December 31, 2018. See Note 7 for detail on how the new revenue standard primarily impacts revenue recognition and presentation accounting policies. #### 4. Risk Concentration The Company's cash consists of cash held at financial institutions where they each may exceed government insurance Limits during the year. At December 31, 2018, the Company's tminsured cash balance was \$110,478. As of December 31 , 2018, 65% of accounts receivable was due from four clients. For the year ended December 31, 2018, 54% of revenue was earned from three clients. #### 5. Net Capital Requirements The Company is subject to the SEC's uniform net capital rule (Rule 15c3-1) which requires the Company to maintain a minimum net capital equal to or greater than \$5,000 and a ratio of aggregate indebtedness to net capital not exceeding 15 to 1, both as defined. At December 31, 2018, the Company's net capital was \$288,102 which exceeded the requirement by \$283,102. {12}------------------------------------------------ ### Notes to the Financial Statements ### December 31, 2018 #### 6. Related Party Transactions The Company has an expense sharing agreement with Avila Encore Management LLC ("AEM"), a company under common control. For a fee of \$1,000 per month, AEM provides office space and pays most overhead expenses for the Company. In 2018, the Company recorded \$12,000 of office service expense. This expense is included in "Other operating expenses" on the Statement of Income. During 2018, there were capital distributions totaling \$7,870,000. \$480,00 of distributions were paid to the previous member, Avila Family Trust, and \$7,390,000 of distributions were due to Member. Of the distributions due to Member, Member assigned \$40,000 to Avila Advisors, LLC and assigned \$7,350,000 to AEM. The Company's results of operations and financial position could differ significantly from those that would have been obtained if the entities were autonomous. ### 7. Revenues from Contracts with Customers Revenue from contracts with customers is recognized when, or as, the Company satisfies performance obligations by transferring the promised goods or services to the customers. A good or service is transferred to a customer when, or as, the customer obtains control of that good or service. A performance obligation may be satisfied over time or at a point in time. Revenue from a performance obligation satisfied over time is recognized by measuring progress in satisfying the performance obligation in a manner that depicts the transfer of the goods or services to the customer. Revenue from a performance obligation satisfied at a point in time is recognized at the point in time when it is determined the customer obtains control over the promised good or service. The amount of revenue recognized reflects the consideration the Company expects to be entitled to in exchange for those promised goods or services (i.e., the "transaction price"). In determining the transaction price, the Company considers multiple factors, including the effects of variable consideration. Variable consideration is included in the transaction price only to the extent it is probable that a significant reversal in the amount of cumulative revenue recognized will not occur and when the u ncertainties with respect to the amount are resolved. In determining when to include variable consideration in the transaction price, the Company considers the range of possible outcomes, the predictive value of past experiences, the time period of when uncertainties expect to be resolved and the amount of consideration that is susceptible to factors outside of the Company's influence, such as market volatility or the judgment and actions of third parties. {13}------------------------------------------------ ### Notes to the Financial Statements ### December 31, 2018 #### 7. Revenues from Contracts with Customers *(continued)* The following provides detailed information on the recognition of revenues from contracts with customers: ### Investment Banking Fees Clients are provided with a full range of capital market services. Capital markets services include capital raising, debt restructuring, and mergers and acquisition services to the residential real estate industry. Capital markets service revenue can be both fixed and variable and can be recognized over time and at a point in time. Success fees in investment banking engagements are recognized at a point in time when a transaction is completed within the terms of the agreemenil:. It is at this point in time that the client obtains the control and benefit of the capital markets service and the related performance obligation to successfully broker a specific transaction has been satisfi ed. Retainer fees, valuation fees, and consulting fees in investment banking engagements are fixed fees r·ecognized over time using a time elapsed measure of progress as the Company's clients simultaneously receive and consume the benefits of those services as they are provided. #### Disaggregation of Revenue The following tables present the Company's revenues from contracts with customers by business activity for the period ended December 31, 2018: | Major business activity: | | |-----------------------------------------|-----------------| | Investment banking -
success fees | 7,737,277
\$ | | retainer fees
Investment banking - | 815,268 | | Investment !banking-
consulting fees | 60,000 | | Investment banking -
valuation fees | 52,500 | | Reimbursed! expenses | 54,842 | | Total | 8,719,887
\$ | #### Information on Remaining Performance Obligations and Revenue Recognized from Past Performance Information is not disclosed about remaining performance obligations pertaining to contracts that have an original expected duration of one year or less. The transaction price allocated to remaining unsatisfied or partially unsatisfied performance obligations with an original expected duration exceeding one year was not material at December 31, 2018. Investment banking fees that are contingent upon completion of specific milestones are not included in the transaction price on December 31, 2018 as it is probable that a significant reversal of revenue will occur. {14}------------------------------------------------ ### Notes to the Financial Statements December 31, 2018 #### 7. Revenues from Contracts with Customers *(continued)* #### Contract Balances Income is re·cognized upon completion of the related performance obligation and when an unconditional right to payment exists. The timing of revenue recognition may differ from the timing of customer payments. A receivable is recognized when a performance obligation is met prior to receiving payment by the customer. Receivables related to revenue from contracts with customers totaled \$188,194 and \$225,666 as of January 1, 2018 and December 3 1,2018 respectively. Alternatively, fees received prior to the completion of the performance obligation are recorded as deferred revenue on the statement of financial condition until such time when the performance obligation is met. Deferred revenue would primarily relate to retainer fees received in investment banking engagements. As of January 1, 2018 and December 31, 2018 there were no amounts of revenue deferred. #### Costs to Obtain or Fulfill a Contract with a Customer The Company incurs incremental costs to obtain and/or fulfill contracts associated with investment banking and advisory engagements. These expenses are deferred only to the extent they are explicitly reimbursable by the client and the related revenue is recognized at a point in time. All other investment banking advisory related expenses are expensed as incurred. For the year ended December 31, 2018, reimbursed expensed income was \$54,842 and client reimbursable expenses were \$52,582 on the Statement of Income. #### 8. Subsequent Events The Company has evaluated subsequent events through February 28, 2019, the date which the financial statements were issued. {15}------------------------------------------------ ## Supporting Schedules #### Pursuant to Rule 17a-5 of the Securities Exchange Act {16}------------------------------------------------ # Builder Advisor Group, LLC Schedule I # Computation of Net Capital Under R ule 15c3-1 of the Securities a nd Exchange Commission ## As of December 31, 2018 | Net Capital | | | |----------------------------------------------------------|----|---------| | Total member's equity | \$ | 528,185 | | Less: Non-allowable assets | | | | Accounts receivable | | 225,666 | | Prepaid expenses | | 14,417 | | Total non-allowable assets | | 240,083 | | Net Capital | | 288,102 | | Net minimum capital requirement of 6.67% of aggregate | | | | indebtedness of\$72,376 or \$5,000, whichever is greater | | 5,000 | | Excess Net Capital | \$ | 283,102 | # Reconciliation with Company's Net Capital Computation (Included in Part II of Form X-17A-5 as of December 31, 2018) | Net capital, as reported in Company's | | |--------------------------------------------------|---------------| | Part II of Form X-17-A-5 as of December 31, 2018 | \$
275,221 | | Increase in equity | 10,202 | | Decrease in non-allowable assets | 2,679 | | Net Capital per above computation | \$
288,102 | {17}------------------------------------------------ # Builder Advisor Group, LLC Schedule II # Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission # For the Year Ended December 31, 2018 An exemption from Rule 15c3-3 is claimed, based upon section (k)(2)(i). All transactions are processed in accordance with Rule 1 5c3-1 (a)(2). # Information Relating to Possession or Control Requirements Under Rule 15c3-3 of the Securities and Exchange Commission ### For the Year Ended December 31, 2018 An exemption from Rule 15c3-3 is daimed, based upon section (k)(2)(i). {18}------------------------------------------------ # Report on Exemption Provisions Pursuant to Rule 17 C.F.R. §240.15C3-3(k) {19}------------------------------------------------ *675 Ygnacio Valley Road, SuiteA200 Walnut Creek, CA 94596* *(925) 933-2626 Fax (925) 944-6333* #### Review Report oflndependent Registered Public Accounting Firm To the Member of Builder Advisor Group, LLC We have reviewed management's statements, included in the accompanying SEA 15c3-3 Exemption Report, in which (I) Builder Advisor Group, 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 :(k)(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 compHance 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. Acc<>rdingly, 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. Walnut Creek, California February 28, 2019 {20}------------------------------------------------ ![](_page_20_Picture_0.jpeg) ## **SEA RULE 15c3-3 EXEMPTION REPORT** February 28,2019 I, Elizabeth Collins, FINOP of Builder Advisor Group, LLC (the "Company" ) represent the following: - l. The Company claims the k(2)(i) exemption from 17 C.F.R. §240.15c3-3; - 2. The Company met the identified exemption provisions in 17 C.F.R. §240.15c3-3(k) throughout the most recent fiscal year as of December 31, 20 I 8 without exception; and - 3. There were no exceptions during the most recent fiscal year in meeting the identified exemption provisions in 17 C.F.R. §240.1 Sc3-3(k). I affi1m that, to my best knowledge and belief, this Exemption Report is true and correct. The Company does not handle cash or securities on behalf of customers. RcspectfuJiy submitted, ~ L:.li~ s rJNOP One letterman Drive, Building C Suite 3800 San Francisco, CA 94129 (415) 561~600 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.