# KITTLE CAPITAL MARKETS, LLC X-17A-5 (2023-03-08) — Broker-dealer annual report - Company: KITTLE CAPITAL MARKETS, LLC - Form: X-17A-5 - Filed: 2023-03-08 - Period: 2022-12-31 - Accession: 0001530263-23-000001 - CIK: 1530263 - File #: 8-68967 - Type: Broker-dealer - Material weakness: No - Auditor: Katz, Sapper & Miller, LP - Auditor location: Indianapolis, IN - Contact: Jeffrey L. Kittle - Phone: 317-846-3111 - Email: jkittle@kittleproperties.com - Website: kittleproperties.com - Signed by: Jeffrey L, Kittle (Manager) Original filing: https://www.sec.gov/Archives/edgar/data/1530263/000153026323000001/kittlecap.pdf --- {0}------------------------------------------------ FINANCIAL STATEMENTS AND INDEPENDENT Auditor's REPORT December 31, 2022 {1}------------------------------------------------ ### **CONTENTS** | | Page | |--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------| | FINANCIAL STATEMENTS | | | Facing Page | | | Oath or Affirmation | 2 | | Report of Independent Registered Public Accounting Firm | 3-4 | | Statement of Financial Condition | 5 | | Statement of Operations | 6 | | Statement of Changes in Member's Equity | 7 | | Statement of Cash Flows | 8 | | Notes to Financial Statements | 9-10 | | SUPPLEMENTARY INFORMATION AND REPORTS | | | Computation of Net Capital Pursuant to Uniform Net Capital Rule 15c3-1 of
the Securities and Exchange Commission | 11 | | Computation for Determination of the Reserve Requirements and Information
Relating to Possession or Control Requirements for Brokers and
Dealers Pursuant to Rule 15c3-3 | 12 | | Exemption Report Pursuant to SEA Rule 17a-5(d)(4) | 13 | | Report of Independent Registered Public Accounting Firm on the Exemption Report | 14 | {2}------------------------------------------------ UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: Oct. 31, 2023 Estimated average burden hours per response: 12 # **ANNUAL REPORTS FORM X-17 A-5 PART Ill** | SEC FILE NUMBER | | |-----------------|--| | 68967 | | FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and lBa-7 under the Securities Exchange Act of 1934 FILING FOR THE PERIOD BEGINNING Q 1/01 /2022 MM/DD/YY AND ENDING 12/31 /2022 MM/DD/YY A. REGISTRANT IDENTIFICATION NAME oF FIRM: Kittle Capital Markets, LLC TYPE OF REGISTRANT (check all applicable boxes): El Broker-dealer D Security-based swap dealer 0 Major security-based swap participant CJ Check here if respondent Is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) | | 310 E 96th Street, Suite 400 | | |--|------------------------------|--| | | | | | | | (No. and Street) | | | | |---------------------------------------------------------------------------------------------------------|--|--------------------------------|--------------------------------------------|------------------------------|--| | Indianapolis | | Indiana | | 46240 | | | (City) | | (State) | | (Zip Code) | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | Jeffrey L. Kittle | | 317 -846-3111 | | jkittle@kittleproperties.com | | | (Name} | | (Area Code - Telephone Number} | (Emall Address} | | | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing*
Katz, Sapper & Miller, LLP | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | | | 800 E 96th Street, Suite 500 Indianapolis | | | Indiana | 46240 | | | (Address} | | (City) | (State) | (Zip Code} | | | 11/13/2006 | | | 2804 | | | | (Date of Registration with PCAOB)(if applicable) | | | (PCAOB Registration Number, if applicable) | | | | | | FOR OFFICIAL USE ONLY | | | | •Claims for exemption from the requirement that the annual reports be covered by the reports of an Independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.l 7a-S(e)(l)(ll), If applicable. Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. {3}------------------------------------------------ #### OATH OR AFFIRMATION | 1, Jeffrey L. Kittle | | swear (or affirm) that, to the best of my knowledge and belief, the | |-----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------| | financial report pertaining to the firm of Kittle Caoital Markets. LLC | | , as of | | December 31 | , 2022 , Is true and correct. I further swear (or affirm) that neither the company nor any | | | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any | | unt classified solely | | as that of a customer. | | | | | ANDREAM KRAMER
My Commission Expies
September 23, 2025
Convnisslon Nurrber 703128
HM!ilkln County | | | | | | ### This filing\*\* contains (check all applicable boxes): - 01 (a) Statement of financial condition. - OJ (b) Notes to consolidated statement of financial condition. - 01 (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). - Ell (d) Statement of cash flows. - Ell (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - ClJ (f) Statement of changes In llabllltles subordinated to claims of creditors. - IJl (g) Notes to consolidated financial statements. - 1211 (h) Computation of net capital under 17 CFR 240.15c3-1or17 CFR 240.18a-1, as applicable. - Ill (i) Computation of tangible net worth under 17 CFR 240.18a-2. - 01 0) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - IJl (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - al (I) Computation for Determination of PAB Requirements under Exhibit A to§ 240.15c3-3. - 01 (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - aJ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - Ell (o) Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-1, or 17 CFR 240.lSa-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3or17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - []] (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - Ell (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - DJ (r) Compliance report in accordance with 17 CFR 240.17a-5or17 CFR 240.18a-7, as applicable. - ~ (s) Exemption report In accordance with 17 CFR 240.17a-5or17 CFR 240.18a-7, as applicable. - OJ (t) Independent public accountant's report based on an examination of the statement offlnanclal condition. - 01 (u) Independent public accountant's report based on an examination of the flnanclal report or financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - OJ (v) Independent public accountant's report based on an examination of certain statements In the compliance report under 17 CFR 240.17a-5or17 CFR 240.18a-7, as applicable. - Ell (w) Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - DJ (x) Supplemental reports on applying agreed-upon procedures, In accordance with 17 CFR 240.1Sc3-1e or 17 CFR 240.17a-12, as applicable. - Ql (y) Report describing any material Inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material Inadequacies exist, under 17 CFR 240.17a-12(k). CI! (z) Other=------ ----------------------------- - - ""'To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.1Ba-7(d)(2), as applicable. {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) Report of Independent Registered Public Accounting Firm To the Member and Board of Directors of Kittle Capital Markets, LLC ### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Kittle Capital Markets, LLC as of December 31, 2022, and the related statements of operations, changes in member's equity and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the financial statements). In our opinion, the financial statements present fairly, in all material respects, the financial position of Kittle Capital Markets, LLC as of December 31, 2022, and the results of its operations and its cash flows for the year then ended, in conformity with accounting principles generally accepted in the United States of America. ## Basis for Opinion These financial statements are the responsibility of Kittle Capital Markets, LLC's management. Our responsibility is to express an opinion on Kittle Capital Markets, LLC'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 Kittle Capital Markets, LLC 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. {5}------------------------------------------------ ## **Auditor's Report on Supplemental Information** The Computation of Net Capital Pursuant to Uniform Net Capital Rule 15c3-1 of the Securities and Exchange Commission and Computation for Determination of the Reserve Requirements and Information Relating to Possession or Control Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 has been subjected to audit procedures performed in conjunction with the audit of Kittle Capital Markets, LLC's financial statements. The supplemental information is the responsibility of Kittle Capital Market, LLC'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. §240.1 ?a-5. In our opinion, the Computation of Net Capital Pursuant to Uniform Net Capital Rule 15c3-1 of the Securities and Exchange Commission and Computation for Determination of the Reserve Requirements and Information Relating to Possession or Control Requirements for Brokers and Dealers Pursuant to Rule 15c3-3 is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as Kittle Capital Markets, LLC's auditor since 2013. Indianapolis, Indiana February 23, 2023 {6}------------------------------------------------ ### **STATEMENT OF FINANCIAL CONDITION December 31, 2022** #### **ASSETS** | ASSETS
Cash
Prepaid expenses and other | \$
42,255
14,306 | |------------------------------------------------------|------------------------| | TOT AL ASSETS | \$
56,561 | | LIABILITIES AND MEMBER'S EQUITY | | | LIABILITIES
Accounts payable and accrued expenses | \$
466 | | MEMBER'S EQUITY | 56,095 | | TOTAL LIABILITIES AND MEMBER'S EQUITY | \$
56,561 | {7}------------------------------------------------ ### **STATEMENT OF OPERATIONS Year Ended December 31, 2022** | REVENUE | | | |--------------------------|----|------------| | Commission Income | \$ | 27,500 | | Private Placement Income | | 734,250 | | | | | | Total Revenue | | 761,750 | | EXPENSES | | | | Salary and benefits | | 57,000 | | Professional services | | 117,940 | | Commissions and Fees | | 679,843 | | | | | | Rent | | 1,200 | | Internet | | 2,794 | | Insurance | | 84 | | Licenses and permits | | 5,789 | | Office Expenses | | 236 | | Total Expenses | | 864,886 | | | | | | NET OPERATING LOSS | \$ | (103, 136) | | OTHER INCOME | | | | | | | | Debt Forgiveness | \$ | 119,085 | | NET OTHER INCOME | \$ | 119,085 | | NET INCOME | | 15,949 | | | ~ | | | | | | {8}------------------------------------------------ #### STATEMENT OF CHANGES IN MEMBER'S EQUITY Year Ended December 31, 2022 | MEMBER'S EQUITY AT JANUARY 1, 2022 | \$
40,146 | |---------------------------------------|--------------| | NET INCOME | 15,949 | | MEMBER'S EQUITY AT DECEMBER 31 , 2022 | \$
56,095 | {9}------------------------------------------------ ### **STATEMENT OF CASH FLOWS Year Ended December 31, 2022** | OPERATING ACTIVITIES | | |------------------------------------------------------------------------------------------------------------------------------------|-----------------| | Net Income | \$
15,949 | | Debt forgiveness | \$
(119,085) | | Adjustments to reconcile net income to net cash used by operating activities
Changes in certain current assets and liabilities: | | | Prepaid Expenses | (2,841) | | Accounts payable and accrued expenses (related party) | 54,791 | | Net Cash Used by Operating Activities | (51,186) | | NET DECREASE IN CASH | (51 ,186) | | CASH
Beginning of Year | 93,441 | | | | | End of Year | \$
42.255 | {10}------------------------------------------------ ### **NOTES TO FINANCIAL STATEMENTS December 31, 2022** ### **NOTE 1 -ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES** Kittle Capital Markets, LLC (the Company) is organized as an Indiana limited liability company. The Company is a broker-dealer registered with the Securities and Exchange Commission (SEC) and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA). The Company was approved by FINRA on July 11, 2013. The Company was formed to engage primarily in the distribution of private placements of real estate products as well as to a lesser extent, the public offering of unlisted shares of Real Estate Investment Trusts ("REITs"). The private placements will typically consist of Regulation D offerings. The offerings will be structured by the Firm's parent company, Herman & Kittle Properties, Inc., or one of its affiliates, together with outside legal counsel. Once structured, the offerings will be marketed by the Company. The securities will be offered on a best-efforts basis to investment advisors, accredited investors that are known to the Company's registered personnel. The Company is also affiliated with two registered representatives operating as Skellig Capital Advisors ("Skellig"). Skellig provides M&A advisory services for mainly Midwestern clients in a myriad of industries from healthcare and business services to technology, media, telecoms, manufacturing, agriculture, logistics and distributions. Clients are either long-term clients of Skellig, referred to Skellig or the Company through contacts or Skellig becomes aware of a potential client's needs through networking. The Company, for the year ended December 31, 2022 had commission income, and while operations did not result in a loss, the managing member has stated he has the intent and ability to fund any future losses either individually or through the parent company. **Estimates:** The Company uses estimates and assumptions in preparing financial statements in accordance with accounting principles generally accepted in the United States of America. Those estimates and assumptions affect the reported amounts of assets and liabilities, the disclosure of contingencies and the reported revenues and expenses. Accordingly, actual results could vary from those estimates. ### **Revenue from Contracts with Customers** **Performance Obligations:** Revenue from contracts with customers is recognized when, or as, the Company satisfies its performance obligations by transferring promised goods or services performed to customers. A good or service is transferred to or performed for a customer when, or as, the customer obtains control of that good or service performed. A performance obligation may be satisfied over time or at a point in time. Revenue from a performance obligation satisfied at a point in time is recognized at the point in time that the Company determines the customer obtains control over the promised good or service performed. The amount of revenue recognized reflects the consideration to which the Company expects to be entitled in exchange for those promised goods or services performed. **Private Placement:** Performance obligations in these arrangements vary dependent on the contract, but are typically satisfied upon completion of the arrangement. Placement fees are recognized upon completion of a deal and are generally classified as Commission Income. **Investment Banking:** Transaction fees resulting from investment banking activities are recorded at closing of the transaction. Subsequent contingent fees are recorded upon the occurrence of additional funding related to the original transaction and the income is reasonably determinable. {11}------------------------------------------------ ### **NOTES TO FINANCIAL STATEMENTS December 31, 2022** ### **NOTE 1 - ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (Continued)** **Cash** is maintained in bank deposit accounts which, at times, may exceed federally insured limits of \$250,000. To date, there have been no losses in such accounts. **Income Taxes:** The Company is a limited liability company whereby taxable income, losses, credits, etc. are recognized for federal and state income tax reporting purposes by its member. Accordingly, no provision or liability for federal or state income taxes has been reflected in the accompanying financial statements. The Company's member files federal and various state income tax returns. The Company's member is no longer subject to U.S. federal and state income tax examinations by tax authorities for all years before 2019. **Subsequent Events:** The Company has evaluated the financial statements for subsequent events occurring through February 23, 2023, the date the financial statements were available to be issued. ### **NOTE 2 - NET CAPITAL REQUIREMENT** As a broker-dealer registered with the SEC and FINRA, the Company is subject to the SEC Uniform Net Capital 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 times Net Capital. At December 31, 2022, the Company had Net Capital of \$41,789, which was \$36,789 in excess of the required Net Capital of \$5,000. #### **NOTE 3 - CONCENTRATION** Approximately 96% of revenue is from four investment banking deals. ### **NOTE 4 - RELATED PARTY TRANSACTIONS** The Company incurs expenses pursuant to an expense sharing arrangement with its Parent Company for expenditures such as salaries and rent. Expenses related to this arrangement totaled \$58,200 for the year ended December 31, 2022. The Company's Parent forgave expenses pursuant to the expense sharing arrangement for the years ended December 31, 2022 and December 31, 2021. The total forgiveness by the Company's Parent was \$119,085. During the year \$27,500 of private placement income was transacted with Kittle Funding, LLC, an affiliate of the Parent Company. {12}------------------------------------------------ SUPPLEMENTARY INFORMATION AND REPORTS {13}------------------------------------------------ ### COMPUTATION OF NET CAPITAL PURSUANT TO UNIFORM NET CAPITAL RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION December 31, 2022 | CREDITS | | | |---------------------------------------------------------------------------------------------|----|------------------| | Total Member's Equity | \$ | 56,095 | | DEBITS
Non-allowable Assets:
Prepaid expenses and other
Total Non-allowable Assets | | 14,306
14,306 | | NET CAPITAL COMPUTED | | 41,789 | | MINIMUM NET CAPITAL REQUIRED | | 5,000 | | NET CAPITAL IN EXCESS OF REQUIREMENT | ~ | 36,789 | | | | | | AGGREGATE INDEBTEDNESS - Accounts payable and accrued expenses | \$ | 466 | | RATIO OF AGGREGATE INDEBTEDNESS TO NET CAPITAL | | 0.011 | | RECONCILIATION OF NET CAPITAL
Net Capital Per Form X-17A-5, Part II A (FOCUS Report) | \$ | 41 789 | | Net Capital Per Above | \$ | 41 789 | {14}------------------------------------------------ ### **COMPUTATION FOR DETERMINATION OF THE RESERVE REQUIREMENTS AND INFORMATION RELATING TO POSSESSION OR CONTROL REQUIREMENTS FOR BROKERS AND DEALERS PURSUANT TO RULE 15c3-3 Year Ended December 31, 2022** (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3, and is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a· 5 because the Company limits its business activities exclusively to: (1) mergers and acquisitions advisory services; (2) private placement of securities, and (3) wholesale and/or retail distribution of publicly registered non-traded real estate investment trusts (REITS), and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. {15}------------------------------------------------ # **Exemption Report Pursuant to SEA Rule 17a-S(d)(4)** Kittle Capital Markets LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-S(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 1Sc3-3, and (2) The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to: (1) mergers and acquisitions advisory services; (2) private placement of securities, and (3) wholesale and/or retail distribution of publicly registered non-traded real estate investment trusts (REITS), and the Company (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule 15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 1Sc3-3) throughout the most recent fiscal year without exception. Kittle Capital Markets LLC | I, Jeff Kittle, affirm that, to my b | | | nowledge and belief, this Exemption Report is true and | |--------------------------------------|--|--|--------------------------------------------------------| | correct. | | | | | Signature | | |-----------|--| | Manager | | | Title | | ![](_page_15_Picture_7.jpeg) {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) Report of Independent Registered Public Accounting Firm on the Exemption Report To the Member and Board of Directors of Kittle Capital Markets, LLC We have reviewed management's statements, included in the accompanying Exemption Report Pursuant to SEA Rule 17a-5(d)(4 ), in which (1) Kittle Capital Markets, LLC did not claim an exemption under paragraph (k) of 17 C.F.R. § 240.15c3-3, and (2) Kittle Capital Markets, LLC is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because Kittle Capital Markets, LLC limits its business activities exclusively to: (1) mergers and acquisitions advisory services; (2) private placement of securities; and (3) wholesale and/or retail distribution of publicly registered non-traded real estate investment trusts (REITS), and Kittle Capital Markets, LLC (1) did not directly or indirectly receive, hold, or otherwise owe funds or securities for or to customers, (other than money or other consideration received and promptly transmitted in compliance with paragraph (a) or (b)(2) of Rule15c2-4 and/or funds received and promptly transmitted for effecting transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to Kittle Capital Markets, LLC); (2) did not carry accounts of or for customers; and (3) did not carry PAB accounts (as defined in Rule 15c3-3) throughout the most recent fiscal year without exception. Kittle Capital Markets, LLC's management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Kittle Capital Markets, 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, 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 upon Kittle Capital Markets, LLC business activities contemplated by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5, and related SEC Staff Frequently Asked Questions. Indianapolis, Indiana February 23, 2023 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.