# ASSETPOINT FINANCIAL, LLC X-17A-5 (2020-03-02) — Broker-dealer annual report - Company: ASSETPOINT FINANCIAL, LLC - Form: X-17A-5 - Filed: 2020-03-02 - Period: 2019-12-31 - Accession: 0001584248-20-000001 - CIK: 1584248 - File #: 8-69332 - Material weakness: No - Auditor: KPMG LLP - Auditor location: Mclean, VA - Contact: William Bergin - Phone: 7032923489 - Website: bankassetpoint.com - Signed by: William T. Bergin (Chief Compliance Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1584248/000158424820000001/apfconf2019final.pdf --- {0}------------------------------------------------ UNITEDSTATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 # ANNUAL AUDITED REPORT FORM X-17A-5 PART III | OMB Number: | | 3235-0123 | | | |---------------------------|-----------------|-----------|--|--| | Expires: | August 31, 2020 | | | | | Estimated average burden | | | | | | hours per response 12.00 | | | | | | | | | | | OMB APPROVAL | SEC FILE NUMBER | |-----------------| | 8-69332 | 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 | 1/1/2019 | AND ENDING | 12/31/19 | | |----------------------------------------------------------------------------------------------|--------------------------------------------------------|------------|----------------------------------------------------------------------------------------------------------------------|--| | | MM/DD/YY
MM/DD/YY | | | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: Assetpoint Financial, LLC
OFFICIAL USE ONLY | | | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | FIRM I.D. NO. | | | 1300 North 17th Street, Suite 1800 | | | | | | | (No. and Street) | | | | | Arlington | VA | | 22209 | | | (City) | (State) | | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
William T. Bergin | | | 703-292-3489 | | | | | | (Area Code - Telephone Number) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | KPMG LLP | | | | | | | (Name - if individual, state last, first, middle name) | | | | | 8350 Broad Street | McLean | VA | 22102 | | | (Address) | (City) | (State) | (Zip Code) | | | CHECK ONE: | | | | | | Certified Public Accountant | | | | | | Public Accountant | | | | | | Accountant not resident in United States or any of its possessions. | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | | | | | and and the neaving work that the annual hy the online of an indonendent minion of an indonemant minion of conventor | | \*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. {1}------------------------------------------------ # OATH OR AFFIRMATION | William T. Bergin
1. | | | and and a more , swear (or affirm) that, to the best of | |-------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of | | | | Assetpoint Financial, LLC
of December 31 | | | . as
are true and correct. I further swear (or affirm) and correct. I further swear (or affirm) that | | | neither the company nor any partner, principal officer or director has any proprietary interest in any account
classified solely as that of a customer, except as follows: | | | | No exceptions | | | | | RACHEL LEE SIPE
NOTARY PUBLIC
REGISTRATION # 7699599
COMMONWEALTH OF VIRGINIA
MY COMMISSION EXPIRES
OCTOBER 31, 2020 | | Signature
Chief Compliance Officer
Title | | | Notary Public
(a) Facing Page.
(b) Statement of Financial Condition.
(c) Statement of Income (Loss). | This report ** contains (check all applicable boxes):
(d) Statement of Changes in Financial Condition. | | | | (g) Computation of Net Capital. | (e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
(h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.
(i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3. | | (i) A Reconciliation, including appropriate explanation of Net Capital Under Rule 15c3-1 and the | | consolidation.
(I) An Oath or Affirmation. | Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.
(m) A copy of the SIPC Supplemental Report. | | (k) A Reconciliation between the audited Statements of Financial Condition with respect to methods of
(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). | | | {2}------------------------------------------------ # ASSETPOINT FINANCIAL, LLC Financial Statements and Supplementary Information Pursuant to Rule 17a-5 under the Securities Exchange Act of 1934 December 31, 2019 (With Report of Independent Registered Public Accounting Firm Thereon) This report is deemed CONFIDENTIAL in accordance with Rule 17a-5(e)(3) of the Securities Exchange Commission Act of 1934. {3}------------------------------------------------ # ASSETPOINT FINANCIAL, LLC #### Table of Contents Page | Report of Independent Registered Public Accounting Firm | 1 | |------------------------------------------------------------------------------------------------------------------------------------------------------------|-----| | Financial Statements: | | | Statement of Financial Condition, December 31, 2019 | 3 | | Statement of Income, Year ended December 31, 2019 | 4 | | Statement of Changes in Member's Equity, Year ended December 31, 2019 | 5 | | Statement of Cash Flows, Year ended December 31, 2019 | 6 | | Notes to Financial Statements | 7 | | Report of Independent Registered Public Accounting Firm on Exemption Report | 11 | | Assetpoint Financial, LLC Exemption Report, December 31, 2019 | 12 | | Supplementary Information | | | Schedule I - Computation of Net Capital and Aggregate Indebtedness under Rule 15c3-1 of the
Securities and Exchange Commission, December 31, 2019 | 13 | | Schedule II - Computation of Determination of Reserve Requirements under Rule 15c3-3 of the
Securities and Exchange Commission, December 31, 2019 | 14 | | Schedule III - Information Related to Possession or Control Requirements under Rule 15c3-3 of the
Securities and Exchange Commission, December 31, 2019 | ો ર | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) KPMG LLP Suite 900 8350 Broad Street McLean, VA 22102 #### Report of Independent Registered Public Accounting Firm To the Member and Management Assetpoint Financial, LLC: #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Assetpoint Financial, LLC (the Company) as of December 31, 2019, the related statements of income, changes in member's equity, and cash flows for the year then ended, and the related notes (collectively, 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, 2019, 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 these 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. #### Accompanying Supplemental Information The supplemental information contained in Schedules I, II, and III 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 and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented {5}------------------------------------------------ ![](_page_5_Picture_0.jpeg) 240.17a-5. In our opinion, the supplemental information contained in Schedules I, II, and III is fairly stated, in all material respects, in relation to the financial statements as a whole. ![](_page_5_Picture_2.jpeg) We have served as the Company's auditor since 2015. McLean, Virginia February 28, 2020 {6}------------------------------------------------ # ASSETPOINT FINANCIAL, LLC #### Statement of Financial Condition #### 12/31/2019 | Assets | | 2019 | |---------------------------------------|-----------|-------------| | Cash and cash equivalents | ਦਿੱਤਾ। ਉਹ | 1,621,703 | | Accounts receivable | | 29,219 | | Prepaid expenses | | 12,939 | | Fixed assets, net | | 390,216 | | Total assets | ਦਿੱਤਾ। ਉਹ | 2,054,077 | | Liabilities and member's equity | | | | Due to Member | ಲ್ಲಾ | 19,348 | | Other current liabilities | | 18,376 | | Total liabilities | | 37,724 | | Member's equity: | | | | Contributed capital | | 3,139,339 | | Accumulated deficit | | (1,122,986) | | Total member's equity | | 2,016,353 | | Total liabilities and member's equity | S | 2,054,077 | {7}------------------------------------------------ # ASSETPOINT FINANCIAL, LLC #### Statement of Income #### Year ended December 31, 2019 | | | 2019 | |-------------------------------|---|---------| | Revenue | S | 887,052 | | Operating expenses: | | | | Corporate allocation | | 233,158 | | Depreciation | | 263,190 | | Professional fees | | 122,897 | | Dues, fees, and subscriptions | | 53,426 | | Incentive compensation | | 2,000 | | Other | | (2,875) | | Total operating expenses | | 671,796 | | Income from operations | | 215,256 | | Net Income | S | 215,256 | {8}------------------------------------------------ # ASSETPOINT FINANCIAL, LLC Statement of Changes in Member's Equity Year ended December 31, 2019 | | | Changes in Member's Equity | | | |------------------------------|---|----------------------------|------------------------|-----------------------------| | | | Contributed
Capital | Accumulated
Deficit | Total
Member's
Equity | | Balance at December 31, 2018 | S | 3.139.339 | (1,338,242) | 1,801,097 | | Net Income | | | 215,256 | 215,256 | | Balance at December 31, 2019 | S | 3,139,339 | (1,122,986) | 2,016,353 | {9}------------------------------------------------ # ASSETPOINT FINANCIAL, LLC #### Statement of Cash Flows #### Year ended December 31, 2019 | | | 2019 | |-----------------------------------------------------------------------------------|---|-----------| | Cash flows from operating activities: | | | | Net Income | S | 215,256 | | Adjustments to reconcile net income to net cash provided by operating activities: | | | | Depreciation | | 263,190 | | Decrease in accounts receivable | | 82,503 | | Increase in prepaid expenses | | (9,008) | | Decrease in due to Member | | (176,972) | | Decrease in other current liabilities | | (16,618) | | Net cash provided by operating activities | | 358,351 | | Cash and cash equivalents, beginning of year | | 1,263,352 | | Cash and cash equivalents, end of year | S | 1,621,703 | {10}------------------------------------------------ ### Notes to Financial Statements # December 31, 2019 #### (1) Summary of Significant Accounting Policies #### (a) Organization Assetpoint Financial, LLC (Company or APF) was formed in the State of Delaware in July 2013 as a wholly owned subsidiary of Promontory Interfinancial Network, LLC (PIN and or Member). PIN is the sole member of APF and is a Delaware limited liability company that was formed in May 2002. Nexus Buyer LLC is the sole member of PIN. Nexus Buyer LLC is a wholly owned subsidiary of Nexus Intermediate Parent LLC, who, in turn, is a wholly-owned subsidiary of Nexus Parent LLC. The Company is a registered broker-dealer with the Securities and Exchange Commission and a member of the Financial Industry Regulatory Authority (FINRA). PIN provides services to APF including, but not limited to, sales, legal, marketing, human resources, and finance and accounting pursuant to an intercompany services agreement. APF is an affiliate through common ownership of Assetpoint Services, LLC (APS), a Delaware limited liability company formed in September 2012. APS operates an informational website named Bank Assetpoint® (www.bankassetpoint.com) on which eligible participants can post and view listings of certain eligible assets. Eligible participants include banks, savings associations, credit unions, licensed commercial real estate brokers, loan sale advisory firms, and other sophisticated entities that meet certain requirements indicating that they have experience in buying or selling real estate or loan assets. Eligible assets include commercial real estate and certain loan assets. The Company's business plan involves offering securities listing services, private placement services, services involving hedging instruments for customers offering marketed-linked certificates of deposit, as well as other brokerage services. The Company also offers a service ("Repo Service") through which the Company refers banks and other financial institutions (each, a "Referred Institution") to a third-party securities dealer ("Repo Dealer") to enter into repurchase agreement transactions (each, a "repo transaction") for themselves or as agents for their customers. Repo transactions executed in the Repo Service are typically overnight transactions. In connection with the Repo Service, APF is not a party to any repo transaction, and does not at any time have custody of cash or securities. Pursuant to a referral agreement between the Repo Dealer and APF, the Repo Dealer pays APF a referral fee attributable to repo transactions entered institutions. In 2019, all APF revenue was attributable to referral fees earned from providing the Repo Service. #### (b) Use of Estimates The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures 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 estimated amounts. #### (c) Cash and Cash Equivalents The Company considers all highly liquid investments with original maturities of three months or less to be cash equivalents. {11}------------------------------------------------ ## Notes to Financial Statements # December 31, 2019 #### (d) Accounts Receivable Substantially all accounts receivable are expected to be collected within one year. Management monitors past due balances with clients and, for accounts where collectability is not probable, management records an allowance for uncollectible accounts receivable to reflect management's best estimate of expected recovery. As of December 31, 2019, there is no allowance for uncollectible accounts. ### (e) Software Developed for Internal Use Costs incurred for software developed for internal use are capitalized during the implementation stage and depreciated over the estimated useful life of the software. Such amounts are reported as fixed assets. Costs incurred in the project planning or post-implementation stages are expensed as incurred. #### (f) Recent Accounting Pronouncements #### Adopted in the Current Period Effective January 1, 2019, APF adopted the requirements of the Accounting Standards Update No 2016-02, Leases (Topic 842), which requires lessees to recognize a right-of-use asset and a lease liability on the balance sheet for all leases with the exception of short-term leases. For lessees, leases will be classified as either operating or finance leases, with the classification affecting the pattern and classification of expense recognition in the income statement. APF is not a party to any leases during the period ending December 31, 2019, there is no financial impact under the new ASC 842. #### To be Adopted in Future Periods In June 2016, the FASB issued ASU No. 2016-13, Financial Instruments-Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments (ASU 2016-13) and a subsequent amendment ASU 2019-04, Codification Improvements to Topic 326, Financial Instruments-Credit Losses, Topic 815, Derivatives and Hedging, and Topic 825, Financial Instruments (ASU 2019-04) in April 2019. ASU 2016-13 requires that expected credit losses relating to financial assets measured on an amortized cost basis, including trade accounts receivable, and available-for-sale debt securities be recorded through an allowance for credit losses. ASU 2016-13 and ASU 2019-04 became effective for APF on January 1, 2020. The adoption of these standards is not expected to have a material impact on APF's financial statements and related disclosures. #### (g) Revenue Recognition The Company offers the Repo Service, through which APF refers banks and other financial institutions to a Repo Dealer to enter into repo transactions for themselves or as agents for their customers. Pursuant to a referral agreement between the Repo Dealer and APF, APF earns Repo Service revenues by providing a series of services which form a single performance obligation. APF's performance obligation is satisfied at the point in time when a repo transaction is executed. As compensation for such services, the Repo Dealer pays APF a referral fee equal to a contractually determined percentage of the dollar amount of the repo transaction. {12}------------------------------------------------ ### Notes to Financial Statements December 31, 2019 #### (2) Income Taxes The Company is a single-member limited liability company. No amounts related to income taxes have been recogmized in the accompanying financial statements since the Company is treated as a disregarded entity for income tax purposes. PIN, the sole member of the Company, is also disregarded entity for income tax purposes. Nexus Buyer LLC, the sole member of PIN, is a wholly owned subsidiary of Nexus Intermediate Parent LLC, who, in turn, is a wholly-owned subsidiary of Nexus Parent LLC. Therefore, the members of Nexus Parent LLC, a partnership for tax purposes, would be responsible for recording the Company's net income (loss) on their income tax filings. The Company had no unrecognized tax benefits as of or during the year ended December 31, 2019. ### (3) Rule 15c3-3 Customer Protection and Possession and Control The Company claims exemption from Rule 15c3-3 of the Securities and Exchange Commission as provided by paragraph (k)(2)(i). Accordingly, the Company is not required to submit a computation for determination of reserve requirements or information relating to possession or control requirements. The Company does not hold funds or securities for customers and does not at any time have custody of cash or securities in connection with the Repo Service. The Company claims exemption under 15c3-3 under (k)(2)(i) as a result. ### (4) Net Capital Requirements The Company is subject to the Securities and Exchange Commission's Uniform Net Capital Rule 15c3-1 (Rule 15c3-1) and is required to maintain minimum net capital equivalent to \$5,000 or 6 2/3% of aggregate indebtedness, whichever is greater, as these terms are defined. Rule 1503-1 restricts a broker-dealer from engaging in any securities transactions when its aggregate indebtedness exceeds 15 times its net capital as those terms are defined by Rule 15c3-1. Net capital and aggregate indebtedness change from day to day. At December 31, 2019, the Company had net capital of \$1,583,980, which was \$1,578,980 in excess of its required capital of \$5,000. The Company's aggregate indebtedness at December 31, 2019 was \$37,723. # (5) Transactions with Affiliates #### (a) Due to Member The Company has a balance Due to Member of \$19,348 as of December 31, 2019. During 2019, the Company reimbursed PIN for expenses incurred by the Company and paid by PIN on the Company's behalf. The December 31, 2019 ending balance of \$19,348 was be paid by the Company on February 20, 2020. {13}------------------------------------------------ ### Notes to Financial Statements ## December 31, 2019 #### (b) Corporate Allocation In addition to specific operating expenses incurred by the Company and charged directly to operations, certain compensation and occupancy costs are incurred by PIN but shared with the Company. Pursuant to an agreement with PIN effective October 1, 2014, the Company is allocated a share of these costs as follows: | Overhead costs: | | | |-------------------------------|---|---------| | Wages and related expenses | S | 186,605 | | Telephone | | 2,666 | | Office supplies/furnishings | | 618 | | Rent | | 11,857 | | Depreciation and amortization | | 8,123 | | Professional Services | | 7,574 | | Other miscellaneous | | 15,714 | | Total corporate allocation | S | 233.158 | In the opinion of management, the aforementioned corporate allocation is believed to be reasonable; however, the allocated costs are not necessarily indicative of the expenses the Company may have incurred on its own account. #### (6) Fixed Assets Fixed assets at December 31, 2019 consist of capitalized software development costs of \$1,322,269 and accumulated depreciation of \$932,054 and is being depreciated on a straight-line basis over its estimated useful life of five years. In 2019 the Company recorded \$271,313 of depreciation expense. #### (7) Commitments and Contingencies In the ordinary course of business, various claims and lawsuits may be brought by or against the Company. As of the end of the year, there were no such claims or lawsuits brought by or against the Company. #### (8) Subsequent Events Subsequent to December 31, 2019 and through February 28, 2020, the date through which management evaluated subsequent events and on which date the financial statements were available to be issued, the Company did not identify any material subsequent events. {14}------------------------------------------------ ![](_page_14_Picture_0.jpeg) KPMG LLP Suite 900 8350 Broad Street McLean, VA 22102 #### Report of Independent Registered Public Accounting Firm The Member and Management Assetpoint Financial, LLC: We have reviewed management's statements, included in the accompanying Exemption Report (the Exemption Report), in which (1) Assetpoint Financial, LLC (the Company) identified the following provisions of 17 C.F.R. § 240.15c3-3 (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 year ended December 31, 2019 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. ![](_page_14_Picture_7.jpeg) McLean, Virginia February 28, 2020 {15}------------------------------------------------ # Assetpoint Financial, LLC Exemption Report December 31, 2019 I, as a member of management of Assetpoint Financial, LLC (the Company), am responsible for complying with 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-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following: (1) We 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: exemption provision pursuant to Paragraph (k)(2)(i), and (2) We met the identified exemption provisions in paragraph (k)(2)(i) of Rule § 240.15c3-3 throughout the period from January 1, 2019 to December 31, 2019 without exception. #### Assetpoint Financial, LLC I, William T. Bergin\_affirm that, to my best knowledge and belief, this Exemption Report is true and correct. By: Title: Chief Compliance Officer February 28, 2020 {16}------------------------------------------------ #### ASSETPOINT FINANCIAL, LLC Computation of Net Capital and Aggregate Indebtedness under Rule 15c3-1 of the Securities and Exchange Commission #### December 31, 2019 | Total member's equity | S | 2,016,353 | |-----------------------------------------------------------------------------------|---|-----------| | Less nonallowable assets | | 432,373 | | Net capital before haircuts | | 1,583,980 | | Haircuts on exempt securities (cash equivalents) | | | | Haircuts on other securities | | | | Net capital | | 1,583,980 | | Net capital required (the greater of \$5,000 or 6 2/3% of aggregate indebtedness) | | 5,000 | | Excess net capital | S | 1,578,980 | | Aggregate indebtedness | | 37,723 | | Ratio of aggregate indebtedness to net capital | | 2% | There are no material differences between the preceding computation and the Company's corresponding unaudited part II of Form X-17A-5 as of and for the year ended December 31, 2019, which was filed on January 25, 2020. See accompanying report of independent registered public accounting firm. {17}------------------------------------------------ #### ASSETPOINT FINANCIAL, LLC Computation of Determination of Reserve Requirements under Rule 15c3-3 of the Securities and Exchange Commission December 31, 2019 The Company claims exemption from the provision of Rule 15c3-3 of the Securities Exchange Act of 1934 pursuant to Section (k)(2)(i) of the Rule. See accompanying report of independent registered public accounting firm. {18}------------------------------------------------ #### ASSETPOINT FINANCIAL, LLC Information Related to Possession or Control Requirements under Rule 15c3-3 of the Securities and Exchange Commission #### December 31, 2019 The Company claims exemption from the provision of Rule 15c3-3 of the Securities Exchange Act of 1934 pursuant to Section (k)(2)(i) of the Rule. See accompanying report of independent registered public accounting firm. Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.