# SEPULVEDA DISTRIBUTORS LLC X-17A-5 (2021-03-01) — Broker-dealer annual report
- Company: SEPULVEDA DISTRIBUTORS LLC
- Form: X-17A-5
- Filed: 2021-03-01
- Period: 2020-12-31
- Accession: 0001565380-21-000003
- CIK: 1565380
- File #: 8-69221
- Material weakness: No
- Auditor: Ernst & Young LLP
- Auditor location: Los Angeles, CA
- Contact: Al Hassanein
- Phone: 3102355942
- Signed by: Paul Douglas (Chief Compliance Officer)
Original filing: https://www.sec.gov/Archives/edgar/data/1565380/000156538021000003/SDLLC2020.pdf
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549
# **ANNUAL AUDITED REPORT FORM X-17A-5 PARTlll**
OMB APPROVAL OMS Number: 3235-0123 Expires: October 31, 2023 Estimated average burden hours per response .... .. ii 2.00
# SEC FILE NUMBER 8-69221
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 T HE PERIOD BEGINNING 01/01/20
12/31/20
AND ENDING ~~~~~~~~~~~ | | | |
|---------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|
| MWDDIYY | | MM/DDIYY | |
| | | | |
| | | OFFICIAL USE ONLY | |
| ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do uot use P.O. Box No.) | | FIRM l.D. NO. | |
| | | | |
| (No. and Street) | | | |
| CA | 90025 | | |
| (State) | (Zip Code) | | |
| | | | |
| | | | |
| | | (J\rca C11100 Santa Monica Blvd, Ste 2000
(Name - if i11dirid11al. s1a1e fos1. | A. REGISTRANT IDENTIFICATION
NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT TN REGARD TO THIS REPORT
B. ACCOUNTANT JDENTIFICATION
INDEPENDENT PUBLIC ACCOUNTANT wl10se opinion is contained in this Report*
jirs1. middle 11a111e1) | |
*\*Claims jbr exemption ji-om !he requirement t/Ja t the a111111al report be corered* by *!he opi11io11 of an i11depe11de111 p ublic accountani must be supported* by *a sfalemenl of facts a11d circ11111slc111ces relied on as the bas;s jbr the exe111ptio11. See Section 240. l 7a-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.
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# **OATH OR AFFIRMATION**
| I. Paul Douglas | | , swear (or affirm) that, to the best of |
|-----------------------------|-------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Sepulveda Distributors, LLC | | my knowledge \Ind belief the accompanying financial statement and supporting schedules pertaining to the firm of
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~·as |
| of December 31st | 20 20 | . arc lrne and correct. I further swear (or affirm) thal |
neither the company nor any partner, proprietor, principal officer or director has any propric1ary interest in any accounc classified solely as that of a customer. except as follows:
| | | | ~
PLEASE SEE N(n Ah |
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| | | Notary Public | ATfAC |
| | | This report **contains (check all applicable boxes): | INT
_ |
| | | 0 (a) Facing Page. | |
| | | 0 (b) Statement of Financial Condition. | |
| | | | [Z] (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presen1cd, a Statement |
| | | of Comprehensive Income (as defined in §210.1-02 of Regulation S-X). | |
| | | § (d) Statement or Changes in Financial Condition . | |
| ./ | | (e) Statement of Changes in Stockholders' Equity or Partners· or Sole Proprietors' Capital. | |
| | (l) Statement of Changes in Liabilities Subordinated to Claims of Creditors. | | |
| | J (g) Computation or Net Capital. | | |
| | (h) Computation for Determination of Reserve Requirements Pursuant to Ruic l 5c3-3.
"
(i) Information Relating. to the Possession or Control Requirements Under Ruic 15c3-3. | | |
| ~./ | | D (i) A Reconciliation, inc ludiug appropriate explanation of the Computation or Net Capitnl Under Ruic I | |
| | | | 5c~- I and the |
| | | Computation for Determination of the Reserve Requirements Under Exhibit A of Ruic l 5c3-3. | |
| | | | D (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods or |
| | consolidation.
0 (I) An Oath or Affirmation. | | |
| | | | |
| | | D (m) A copy of the SIPC Supplemental Report. | D (n) A report describing any material inadequacies found to exist or round to have existed since the date of the previous audit. |
| | | | |
| | | u For c:o11ditio11s of co11fitle11linl treatment of cer1ai11 porlio11s of tliis.flling, see sectio11240.J7a-5(e)(3). | |
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| 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 Q,\J,tyS\dL
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Subscribed and sworn to (or affirmed) before me on this | __
Ho ytk=\
\ ___ day of
.?.IJL/ |
| ~
~u/~ts
by | Year
Date
Month |
| Name of Signers | |
| proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me. | |
| | • [
LINDA AVILA LIRA
z
COMM. #2279529
Notary Public · California
~
Riverside County
M Comm. Ex ires Mar. 30 2023
Seal
Place Notary Seal Above |
| --------------------------------------------------- | ()f>"fl()l\l~L --------------------------------------------------- |
| Though this section is optional, completing this information can deter alteration of the document or fraudulent
attachment of this form to an unintended document. | |
| I t1.
Description of Attached Do
~:k.j J{JJ f
ment
Title or Type of Document:
/10l14 | a |
| Document Date: | ________________________________
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| Number of Pages:-------------------------------~ | |
| Signer(s) Other Than Named Above: _
_ | _______________________
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Financial Statements and Supplementary Information
As of and for the Year Ended December 31 , 2020
(With Report of Independent Registered Publfo Accounting Firm Thereon)
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# **Table of Contents**
**Page**
| Report of Independent Registered Public Accounting Firm | |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|
| FinanciaJ Statements: | |
| Statement of Financial Condition | 2 |
| Statement of Operations | 3 |
| Statement of Changes in Member's Capital | 4 |
| Statement of Cash Flows | 5 |
| Notes to Financial Statements | 6 |
| Supplementary Schedule I: Computation of Net Capital Under Rule 15c3-1 of the
Securities and Exchange Commission | 9 |
| Supplementary Schedule II: Computation for Determination of Reserve Requirements
and Information Relating to Possession and Control Requirements under
Rule 15c3-3 of the Securities and Exchange Commission | 10 |
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Ernst & Young LLP 725 South Figueroa Street LOS Angeles, CA 90017 United States of America
Tel: +1213977 *3?00* Fax: +1 213 977 3729 www.ey.com
#### Report of Independent Registered Public Accounting Firm
To the Member of Sepulveda Distributors, LLC
#### Opinion on the Financial Statements
We have audited the accompanying statement of financial condition of Sepulveda Distributors, LLC (the Company) as of December 31, 2020, and the related statements of operations, changes in member's capital, 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 fuirly, in all material respects, the financial position of the Company at December 31, 2020, and the results of its operations and its cash flows for the year then ended in conformity with U.S. generally accepted accounting principles.
#### 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 finn 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 perfonning 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
The accompanying information contained in Schedules I and II has been subjected to audit procedures performed in conjunction with the audit of the Company's financial statements. Such infonnation is the responsibility of the Company's management. Our audit procedures included detem1ining whether the infom1ation 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. ln forming our opinion on the information, we evaluated whether such information, including its form and content, is presented in conformity with Rule I 7a-5 under the Securities Exchange Act of 1934. In our opinion, the information 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 2014.
March 1, 202 l
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Statement of Financial Condition As of December 31 , 2020
| Assets | |
|----------------------------------------|---------------|
| Cash | \$
139,997 |
| Prepaid expenses | 64,613 |
| Total assets | \$
204,610 |
| Liabilities | |
| Accrued expenses | \$
45,107 |
| Total liabilities | 45,107 |
| Member's Capital | |
| Member's capital | 159,503 |
| Total member's capital | 159,503 |
| Total liabilities and member's capital | \$
204,610 |
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Statement of Operations For the year ended December 31, 2020
| Revenues | | |
|-----------------------------------|-----------|------------|
| Placement fees from Member | \$ | 9,888,915 |
| Total revenues | | 9,888,915 |
| Expenses | | |
| Allocated Commissions from Member | 9,888,915 | |
| Audit and tax services | 39,500 | |
| Regulatory fees | 101,738 | |
| Taxes | | 800 |
| Total expenses | | 10,030,953 |
| Net loss | \$ | (142,038) |
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Statement of Changes in Member's Capital For the year ended December 31, 2020
| \$
75,740 |
|---------------|
| 225.801 |
| (142,038) |
| \$
159,503 |
| |
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Statement of Cash Flows
For the year ended December 31, 2020
| Cash flow from operating activities: | |
|-----------------------------------------------------------------------------|-------------------|
| Net Joss | \$
(142,038) |
| Adjustments to reconcile net loss to net cash used in operating activities: | |
| Increase in prepaid expenses | (14,713) |
| Decrease in deposits | 13,649 |
| Increase in accrued expenses | 7,007 |
| Decrease in due to affiliate | (64,706) |
| Net cash used in operating activities | (200,801) |
| Cash flow from financing activities: | |
| Capital contributions | 225,801 |
| Net cash provided by financing activities | 225,801 |
| Net increase in cash | 25,000 |
| Cash as of January 1, 2020 | 114,997 |
| Cash as ofDecember 31, 2020 | \$ ===1=39=,9=9=7 |
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# SEPULVEDA DISTRIBUTORS, LLC Notes to Financial Statements
# (1) Organization and Nature of Business
Sepulveda Distributors, LLC (the "Company") is a Delaware limited liability company formed on November 15, 2012 with the U.S. Securities and Exchange Commission (the "SEC") and has been a member of the Financial Industry Regulatory Authority ("FINRA") since April 29, 2014. The Company is engaged in a single line of business as a securities broker-dealer.
The Company is 100% owned by Crescent Capital Group, L.P. (the "Member"). The Member is registered as an investment adviser under the Advisers Act of 1940 as amended. The Member is 99.8% owned by Crescent Capital Group Holdings, LP, a Delaware limited partnership.
# (2) Summary of Significant Accounting Policies
# *(a) Basis of Presentation*
The Company's financial statements are prepared m accordance with U.S. generally accepted accounting ptinciples ("U.S. GAAP").
#### *(b) Cash*
The Company maintains its cash in a bank deposit account, which at times may exceed the federally insured limits. No losses have been experienced to date related to such account. The Company monitors the financial condition of the financial institution and does not anticipate any losses due to its exposure.
# *(c) Deposits*
The Company maintains a FINRA Flex-Funding Account. This account is used to pay invoices and fees formerly paid through the Web CRD system and is recorded in Prepaid Expenses on the Statement of Financial Condition.
# *(d} Use of Estimates*
The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.
#### *(e) Income Taxes*
The Company is a limited liability company with a single owner, and does not record a provision for U.S. federal, U.S. state, or local income tax.cs because the Member repo1ts the Company's income or loss on its income tax return and consequently, no income tax provision has been made in the financial statements.
The Company reviews and evaluates tax positions in its major jurisdictions and determines whether or not there are uncertain tax positions that require financial statement recognition. The Company is subject to examination by state tax authorities for returns for the prior four years.
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Notes to Financial Statements
The Company recognizes interest and penalties, if any, related to unrecognized tax benefits as an income tax expense in the Statement of Operations. For the year ended December 31, 2020, the Company did not have a liability for any unrecognized tax benefits nor did it recognize any interest and penalties related to unrecognized tax benefits.
# *(/) Prepaid Expenses*
Prepaid expenses consist of prepaid FfNRA registration fees and the Flex-Funding account balance withflNRA.
# *(g) Revenue Recognition*
In May 2014, the Financial Accounting Standards Board issued Accounting Standard Update 2014- 09 ("ASU 2014-09"), "Revenue from Contracts with Customers (Topic 606)." The guidance in ASU 2014-09 supersedes the revenue recognition requirements in "Revenue Recognition (Topic 606)." In accordance with ASU 2014-09, the Company recognizes revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the Company expects to be entitled in exchange for those goods or services.
# (3) Related Party Transactions
# *(a) Due to Affiliate*
Amount due to affiliate relates to monies owed to the Member for expenses paid on behalf of the Company. The Company had no liability to the Member as of December 31, 2020.
# *(b) Expense Sharing Agreement*
The Company and Member entered into an expense sharing agreement on December 26, 2013, which was amended and restated on May 27, 2015 and January I, 2020, whereas the Member agreed to make available office space, office equipment, administrative support and personnel to the Company. The Member is solely responsible for the payment of any administrative expenses incun-ed and those administrative expenses are reflected in the Member·s consolidated financial statements. The Company maintains a separate schedule of the allocable costs of the services.
# *(c) Allocated Commissions from Member*
For the year ended December 31, 2020, the Company recorded commission expenses of \$9,888,915 allocated from the Member.
# *( d) Placement Agent Agreement*
The Company and Member entered into a placement agent agreement on January 1, 2020, whereas the Company assists the Member, on a best effort basis, with the solicitation of potential investors to purchase fund interests. In return for the services provided by the Company, the Company receives from the Member such fees as are negotiated between the Member and the Company. For the year ended December 31, 2020, the Company recognized \$9,888,915 in placement fees from Member.
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# SEPULVEDA DISTRIBUTORS, LLC Notes to financial Statements
### (4) Net Capital Requirements
The Company is subject to the SEC Uniform Net Capital Rule ("SEC Rule 15c3-l "), which requires the maintenance of minimum net capital and requires that the ratio of aggregate indebtedness to net capital, both as defined in SEC Rule 15c3-l, shall not exceed 15 to 1 (and the rule of the "applicable" exchange also provides that equity capital may not be withdrawn or cash dividends paid if the resulting net capital percentage would exceed 10 to 1 ). As of December 31, 2020, the Company had net capital of \$89,890.
| | | December 31, 2020 | |
|--------------------------------------------------------------------|----------|---------------------------|--|
| Net capital as a percent of aggregate indebtedness to net capital: | | 47.54% | |
| Net capital | \$ | 94,890 | |
| Less: required net capital | | (5,000) | |
| Excess net capital | ==
\$ | ==
89,890
-===
- | |
| | | | |
### (5) Subsequent Events
Management has evaluated the activity of the Company through March I, 2021, the date that the financial statements are available to be issued, and concluded that no further subsequent events have occurred that would require recognition or disclosure, except as disclosed below.
On January 5, 2021 , Sun Life Financial Inc. C'Sun Life") completed a 51 % majority stake acquisition of the Member. The Member will form part of SLC Management, Sun Life's alternatives asset management business. The transaction has a put I call option that will allow the transfer of remaining interests by the end of 2026. The Member will continue to operate under its current leadership and will retain its individual brand, office locations and clients. This transaction does not impact the Company.
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SUPPLEMENTAL SCHEDULES I TO II ·
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#### **SEPULVEDA DISTRIBUTORS, LLC** Supplementary Schedule I Computation of Net Capital Under Rule I 5c3-I of the
#### Securities and Exchange Commission As of December 31, 2020
| l. Total ownership equity from Statement of Financial Condition | | \$
159,503 |
|-----------------------------------------------------------------------------------------------------------------|--------|-----------------|
| 2. Deduct ownership equity not allowable for Net Capital | | |
| 3. Total ownership equity qualified for Net Capital | | 159,503 |
| 4. Add: | | |
| A. Liabilities subordinated to claims of general creditors allowable in | | |
| computation of net capital | | |
| B. Other {deductions) or allowable credits (List) | | |
| 5. Total capital and allowable subordinated liabilities | | \$
159,503 |
| 6. Deductions andlor charges: | | |
| A. Total non-allowable assets from | | |
| Statement of Financial Condition | 64,613 | |
| B. Secured demand note delinquency | | |
| C. Commodity futures contracts and spot commodities - | | |
| proprietary capital charges | | |
| D. Other deductions and/or charges | | (64,613) |
| 7. Other additions and/or allowable credits (List) | | |
| 8. Net capital before haircuts on securities positions | | 94,890 |
| 9. Haircuts on securities (computed, where applicable, pursuant to 15c3-l(t)): | | |
| A. Contractual securities commitments | | |
| B. Subordinated securities borrowings | | |
| C. Trading and investment securities: | | |
| I. Exempted securities | | |
| 2. Debt securities | | |
| 3. Options | | |
| 4. Other securities | | |
| D. Undue Concentration | | |
| E. Other (List} | | |
| 10. Net Capital | | \$ =-9-4,,8_90_ |
| COMPUTATION OF NET CAPITAL REQUIREMENT | | |
| Part A | | |
| 11. Minimum net capital required (6 2/3 % of line 19) | | \$
3,007 |
| 12. Minimum dollar net capital requirement of reporting broker or dealer and
minimum net capital requirement | | |
| of subsidiaries computed in accordance with Note (A) | | 5,000 |
| .13. Net capital requirement (greater of line ll or 12) | | 5,000 |
| 14. Excess net capital (line 10 less 13) | | 89,890 |
| 15. Net capital less greater of I 0% of line 19 or 120% of line l2 | | 88,890 |
| COMPUTATION OF AGGREGATE INDEBTEDNESS | | |
| 16. Total A.I. liabilities from Statement of Financial Condition | | 45, 107 |
| 17. Add: | | |
| A. Drafts for immediate credit | | |
| B. Market value of securities borrowed for which no equivalent value | | |
| is paid or credited | | |
| C. Other unrecorded an1ounts (List) | | |
| 19. Total aggregate indebtedness | | \$
45,107 |
| 20. Percentage of aggregate indebtedness to net capital (line 19 + by line 10) | | 47.54% |
| 21. Percentage of debt to debt-equity total computed in accordance | | |
| with Rule 15c3-l(d) | | 0.0% |
There are no material differences between the computation of net capital presented above and the computation of net capital in the company's unaudited Fonn X-17A-5, Part llA filing as of December 31, 2020.
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S\lpplementary Schedule II
Computation for Determination of Reserve Requirements and Information Relating to Possession and Control Requirements under Rule 15c3-3 of the Securities and Exchange Commission As of December 31, 2020
Sepulveda Distributors, LLC (the "Company") does not claim exemption under Rule l 5c3-3 and relies on Footnote 74 of the SEC Release 34-70073 adopting amendments to 17 C.F.R. § 240. l 7a-5 and the Company carries no accounts, does not hold funds or securities for, or owe money or securities to customers. Accordingly, there are no items to report under the requirements of Rule 15c3-3.
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Ernst & Young LLP 725 South Figueroa Street Los Angeles. CA 90017 United States of America
Tel: +I 213 977 3200 Fax: + 1213 977 3729 wwwny.com
# Report of Independent Registered Public Accounting Firm
The Member of Sepulveda Distributors, LLC
We have reviewed management's statements, included in the accompanying Exemption Report, in which Sepulveda Distributors, LLC (the Company) stated that:
- (1) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. 15c3-3.
- (2) The Company is relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to participating in private placement of securities (excluding oil and gas offerings, and 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 recentfiscal year ended December 31, 2020 without exception.
Management is responsible for compliance with 17 C.F.R. § 240.15c3-3 and its statements.
Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company's compliance with 17 C.F.R. § 240.15c3-3. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion.
Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, pursuant to footnote 74 of SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5.
This report is intended solely for the information and use of management, the SEC, FINRA, and other regulatory agencies that rely on Rule 17a-5 under the Securities Exchange Act of 1934 in their regulation of registered brokers and dealers, and other recipients specified by Rule 17a-5(d)(6) and is not intended to be and should not be used by anyone other than these specified parties.
~l'/~u\_P
March 1, 2021
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#### Exemption Report
Sepulveda Distributors, LLC (the "Company") is a registered broker-dealer subject to Rule 1 7a-5 promulgated by the Securities and Exchange Commission (17 C.F.R. §240.I 7a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.l 7a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following:
- (i) The Company does not claim an exemption under paragraph (k) of 17 C.F.R. § 240. l 5c3-3, and
- (ii) 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 participating in private placement of secmities (excluding oil and gas offerings, and 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.
The Company met the identified exemption provisions throughout the year ended December 31, 2020 without exception.
I, Paul Douglas, swear thai, to my 2Irn.owledge and belief, this Exemption Report is true and correct
By 4;;)
Title: Chief ~o~ ~ce Officer March I, 2021 ~anc
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| the document, to which this certificate is attached, and not the truthfulness, accuracy, or validity of that
document. | CALIFORNIA JURAT
A notary public or other officer completing this certificate verifies only the identity of the individual who signed |
|---------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| STATE OF CALIFORNIA
} | |
| COUNTY Of Qw.ir~.tlL
Subscribed and sworn to (or affirmed) before me on this
"""
bv~'-'\~~o.,S | _____
ffiLI
Ha~ ~V\
day of
Year
Month
Date |
| | |
| Name of Signers
proved to me on the basis of satisfactory evidence to be the person(s) who appeared before nne. | |
| | • t
LINDA AVILA LiRA
z
COMM. #2279529
Notary Public • California
~
Riverside County
M Comm. Ex ires Mar. 30 2023 |
| | Seal
Place Notary Seal Above |
| | |
| ---------------------------------------------------
attachment of this form to an unintended document. | C>J>l"IC>l'\l~L ---------------------------------------------------
Though this section is optional, completing this information can deter alteration of the document or fraudulent |
| Description of Attached Docurp.ent
-~->~~~
-~
Tltleor~peofDocument:~ | I).
____________ ~
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| Document Date: | _________________________________
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| | Number of Pages:, _________________________________
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| _______
Signer(s) Other Than Named Above: | __
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Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.