# SPEYSIDE ADVISORS, LLC X-17A-5 (2020-02-28) — Broker-dealer annual report - Company: SPEYSIDE ADVISORS, LLC - Form: X-17A-5 - Filed: 2020-02-28 - Period: 2019-12-31 - Accession: 0001717927-20-000002 - CIK: 1717927 - File #: 8-70023 - Material weakness: No - Auditor: McBee & Co., PC - Auditor location: Dallas, TX - Contact: Daniel Gillett - Phone: (214) 228-8732 - Signed by: Daniel Gillett (Sole Member) Original filing: https://www.sec.gov/Archives/edgar/data/1717927/000171792720000002/2019auditspeyside_.pdf --- {0}------------------------------------------------ **UNITEDSTATES SECURITIESANDEXCHANGECOMMISSION Washington, D.C. 20549** OMB APPROVAL OMB Number: 3235-0123 Expires: August 31,2020 Estimated average burden > **SEC FILE NUMBER** s-290234 # **ANNUAL AUDITED REPORT** hoursper response 12.00 **FORM X-17A-5 PART III** **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 01/01/19 | | 12/31/19
AND ENDING | | | |-------------------------------------------------------------------------------------------|---------------------------------------------------------------------|------------------------|-------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: Speyside
Advisors,
LLC | | | OFFICIAL USE ONLY | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | FIRM I.D. NO. | | | 1910
Pacific
Ave.,
Ste
5060 | | | | | | | ( No. and Street) | | | | | Dallas | Texas | | 75201 | | | (City) | (State) | | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT
Daniel Gillett | | | 214-228-8732 | | | | | ( Area Code | Telephone Number) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | | Co
., PC
McBee
& | | | | | | | if individual, slate last, first, middle name )
(Name | | | | | 718
Paulus | Dallas | Texas | 75214 | | | ( 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 | | | | *'Claims for exemption from the requirement that the annual report he covered by the opinion of an independent public accountant must he 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 notrequired to respond unless the form displays a currently valid OMB control number.** SEC 1410 (11-05) {1}------------------------------------------------ #### OATH OR AFFIRMATION | Daniel Gillett
I | . swear (or afYirm) that, to the best of | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------| | my knowledge and belief the accompanying financial
Speyside Advisors, LLC | statement and supporting schedules pertaining to the firm of | | Qf December 31 | . as
2019
arc true and correct. I further swear (or affirm) that | | neither the company nor any partner, proprietor, principal
classified solely as that of a customer, except
as follows: | ,
,
officer or director has any proprietary interest in
any account | | | n
/
.•
Signature | | | Sole Member | | | Title | | Notary Public
This report ** contains (check all applicable boxes):
El
(a) Facing Page. | DEREK
M DORSEY
k
Notary PuMc'
State
Texas
V
y
Expires APRIL 16, 2022
^
I.O.# 131528355 | | Q
(b) Statement of Financial Condition.
n
of Comprehensive Income (as defined in §210.1-02 of Regulation S-X). | (c) Statement of Income (Loss) or, if there is other comprehensive income in the period(s) presented, a Statement | | (d) Statement of Changes in Financial Condition.
/1 (e) Statement of Changes in Stockholders' Equity or Partners* or Sole Proprietors' Capital.
(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
—
(g) Computation of Net Capital. | | | £
( h) Computation for Determination of Reserve Requirements Pursuant to Rule I 5C3-3.
2
(0 Information Relating to the Possession or Control Requirements Under Rule 15c3-3. | (j) A Reconciliation, including appropriate explanation of theComputation of Net Capital Under Rule 15c3-1 and the | | | Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3. | | []
consolidation. | ( k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of | | (l) An Oath or Affirmation. | | | i
(m) A copy of the SIPC Supplemental Report. | | | | (n) A report describing any material inadequaciesfound to existorfound to have existed since the date of the previous audit. | | **For conditions of confidential treatment of certain portions of this filing, see section 240.l7a-5(e)(3). | | {2}------------------------------------------------ **SPEYSIDE ADVISORS, LLC REPORT PURSUANT TO RULE 17a-5(d) YEAR ENDED DECEMBER 31, 2019** {3}------------------------------------------------ #### CONTENTS | REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM | | 1 | |------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|------| | FINANCIAL
STATEMENTS | | | | Statement
of
financial | condition | 2 | | Statement
of
operations | | 3 | | Statement
of
changes
in member's
equity | | 4 | | Statement
of
cash
flows | | 5 | | Notes
to
financial | statements | 6-8 | | Supporting
Schedules | | | | Schedule
I: | Computation
of
15c3-l
Net
Capital
Under
Rule
of
the
Securities
and
Exchange
Commission | 9-10 | | Schedule
II: | Computation
for
of
Determination
Reserve
15c3-3
of
the
Requirements
Under
Rule
Securities
Exchange
and
Commission | 1 1 | | REPORT
OF
INDEPENDENT
REGISTERED
PUBLIC
ACCOUNTING
FIRM
12
MANAGEMENT'S
EXEMPTION
REPORT
ON | | | | BROKER-DEALER
ANNUAL
EXEMPTION
REPORT | | 13 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) A ProfesMDVul Corporation Certified Public Accountants #### **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** ## **To the Managing Member of Speyside Advisors, LLC** #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Speyside Advisors, LLC as of December 31, 2019,the related statements of operations, changes in member's equity, and cash flows for the year then ended, and the related notes (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of Speyside Advisors, LLC as of December 31, 2019, 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 Speyside Advisors, LLC's management. Our responsibility is to express an opinion on Speyside Advisors, 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 the Speyside Advisors, 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. ## **Auditor's Report on Supplemental Information** The supplemental information contained in Schedule I, Computation of Net Capital Under Rule 15c3-lof the Securities and Exchange Commission and Schedule II, Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission has been subjected to audit procedures performed in conjunction with the audit of Speyside Advisors, LLC's financial statements. The supplemental information is the responsibility of Speyside Advisors, 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. §240.17a-5. In our opinion, the supplemental information contained in Schedule I, Computation of Net Capital Under Rule 15c3-lof the Securities and Exchange Commission and Schedule II, Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission is fairly stated, in all material respects, in relation to the financial statements as a whole. McBee & Co.,PC We have served as Speyside Advisors, LLC's auditor since 2017. Dallas,Texas February 25, 2020 718 Paulus Avenue • Dallas, Texas 75214 • (ph) 214.823.3500 • www.mcbeeco.com Dallas|Keller/Southlake {5}------------------------------------------------ # **SPEYSIDE ADVISORS, LLC STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31, 2019** ## **Assets** | Cash
and
cash
equivalents
Accounts
receivable
expenses
Prepaid | \$
\$ | 56,462
20,419
1,686 | |-------------------------------------------------------------------------------------|----------|---------------------------| | Total
Assets | \$ | 78,567 | | Member's
and
Equity
Liabilities | | | | Liabilities
payable
Accounts
and
accrued
expenses | \$ | | | Total
Liabilities | | | | Member's
Equity | | 78,567 | | Member's
Total
Liabilities
and
Equity | \$ | 78,567 | {6}------------------------------------------------ # **SPEYSIDE ADVISORS, LLC STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 2019** | Revenues | | |----------------------------------------------|---------------| | Consulting
income | \$
305,000 | | Dividend
and
interest
income | 2,051 | | Revenues
Total | 307,051 | | Expenses | | | Registered
representative
compensation | 271,887 | | Regulatory
fees
expenses
and | 2,088 | | Professional
fees | 22,978 | | Occupancy | 2,200 | | Other
expenses | 3,158 | | Expenses
Total | 302,311 | | Gain
on
stock
positions | 5,260 | | provision
taxes
Gain
before
for | 10,000 | | Provision
for
state
income
tax | | | Net
Income | \$
10,000 | {7}------------------------------------------------ # **SPEYSIDE ADVISORS, LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31, 2019** | Balances
at
31,
December
2018 | \$63,567 | |-------------------------------------------|----------| | Member's
contributions | 5,000 | | Net
income | 10,000 | | | | | Balances
at | | | 31,
2019
December | \$78,567 | {8}------------------------------------------------ # **SPEYSIDE ADVISORS, LLC STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2019** | activities:
operating
Cash
flows
provided
by
(used
for) | | |----------------------------------------------------------------------------------------|--------------| | Net
income | \$
10,000 | | to
Adjustments
reconcile
net
income
to
net
cash
provided
by | | | activities:
(used)
for
operating | | | positions,
Unrealized
on
stock
net
gain | (5,260) | | Changes
assets
and
liabilities
in | | | Increase
accounts
receivable
in | (20,419) | | Increase
other
assets
in | (993) | | Decrease
account
and
accrued
expenses
payable
in | ( 190) | | cash
activities
used
for
operating
Net | ( 16,862) | | Cash
flows
from
investing
activities: | | | Proceeds
of
securities
owned
from
sale | 62,340 | | Net
cash
provided
by
investing
activities | 62,340 | | | | | Cash
flows
from
financing
activities: | | | Contributions
managing
member
by | 5,000 | | cash
activities
Net
provided
(used)
by
financing | 5,000 | | Net
increase
(decrease)
cash
and
cash
equivalents
in | 50,478 | | and
cash
equivalents
at
year
Cash
beginning
of | 5,984 | | | | | at
Cash
and
cash
equivalents
end
of
year | \$
56,462 | | | | | Supplemental
Disclosures
of
Cash
Information:
Flow | | | for:
Cash
(received)
during
the
year
paid | | | Interest | \$ | | taxes
Income | \$ | {9}------------------------------------------------ #### **NOTES TO FINANCIAL STATEMENTS** #### **DECEMBER 31, 2019** # **NOTE 1 -Organization and Nature of Business** Speyside Advisors, LLC (the "Company"), was formed on May 11, 2017. The Company is a broker-dealer registered with the Securities and Exchange Commission ("SEC") and is a member of the Financial Industry Regulatory Authority. The Company operates as a Texas Limited Liability Company ("LLC"). Its member has limited personal liability for the obligations or debts of the entity. The Company commenced its broker-dealer operations on January 18, 2019 and shall continue unless terminated in accordance with its operating agreement. The Company is engaged in providing advisory services involving private placement and mergers and acquisitions for its clients. It is intended that all offerings will be exempt from registration under the provisions of either Regulation D or Rule 144A. The Company operates pursuant to SEC Rule 15c3-3(k)(2)(i) (the Customer Protection Rule) and does not hold customer funds or safe-keep customer securities or engage in the underwriting of securities. Upon commencing operations, the Company adopted the new accounting standard for revenue for contracts with customers. The Company provides advisory services on mergers and acquisitions (M&A). Revenue for advisory arrangements is generally recognized at the point in time that performance under the arrangement is completed (the closing date of the transaction) or the contract is cancelled. However, for certain contracts, revenue is recognized over time for advisory arrangements in which the performance obligations are simultaneously provided by the Company and consumed by the customer. In some circumstances, significant judgment is needed to determine the timing and measure of progress appropriate for revenue recognition under a specific contract. Retainers and other fees received from customers prior to recognizing revenue are reflected as contract liabilities. At December 31, 2019, there are no recognized contract liabilities. ### Cash and Cash Equivalents The Company considers all highly liquid investments with a maturity of three months or less when purchased to be cash equivalents. At December 31, 2019, the Company had no such investments. The Company maintains is operating cash at a financial institution. At times, the amount on deposit at this institution may exceed amounts covered by insurance provided by the U.S. Federal Deposit Insurance ("FDIC"). The Company has not experienced any losses related to amount in excess of FDIC limits. #### Revenue Recognition The Company provides advisory services on mergers and acquisitions. Advisory fees represent 100% of revenue earned by the Company. Revenue for advisory arrangements is generally recognized at the point in time that performance under the arrangement is completed (the closing date of the transaction). However, for certain contracts, revenue is recognized over time for advisory arrangements in which the performance obligations are simultaneously provided by the Company and consumed by the customer. Retainers and other fees received from customers prior to recognizing revenue are reflected as deferred revenue. {10}------------------------------------------------ ### **NOTES TO FINANCIAL STATEMENTS** ### **DECEMBER 31, 2019** # **NOTE 1 -Organization and Nature of Business (Cont.)** The Company's financial statements are presented in conformity with accounting principles generally accepted in the United States of America ("U.S. GAAP"). The Financial Accounting Standards Board ("FASB") Accounting Standards Codification (the Codification) is the single source of U.S. GAAP. 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 disclosures of contingent assets and liabilities at the date of the financial statements and the reported amounts of income and expenses during the reporting period. Actual results could differ from those estimates. The Company's net income will be taxed at the member level rather than at the corporate level for federal income tax purposes. The Company is subject to state income taxes. Any potential interest and penalty associated with a tax contingency, should one arise, would be included as a component of income tax expense in the period in which the assessment arises. The Company's federal and state income tax returns are subject to examination over various statutes of limitations generally ranging from three to five years. # **NOTE 2 -Net Capital Requirements** Pursuant to the net capital provisions of Rule 15c3-1 of the Securities and Exchange Act of 1934, the Company is required to maintain a minimum net capital, as defined under such provisions. Net capital and the related net capital ratio may fluctuate on a daily basis. At December 31, 2019, the Company had net capital of \$56,462 and net capital requirements of \$5,000. The Company's ratio of aggregate indebtedness to net capital was .0 to 1. The Securities and Exchange Commission permits a ratio of no greater than 15 to 1. # **NOTE 3 -Possession or Control Requirements** The Company holds no customer funds orsecurities. There were no material inadequaciesin the procedures followed in adhering to the exemptive provisions of (SEC) Rule 15c3-3(k)(2)(i). # **NOTE 4 -Concentration Risk** The Company may at various times during the year have cash balances in excess of federally insured limits. The Company believes that it is not exposed to any significant risk related to cash. # **NOTE 5 -Related Party Transactions** The Company and various entities are under common control and the existence of that control creates operating results and financial position significantly different than if the companies were autonomous. {11}------------------------------------------------ ## **NOTES TO FINANCIAL STATEMENTS** ## **DECEMBER 31, 2019** # **NOTE 6 -Liabilities Subordinated to Claims of General Creditor** During the year ended December 31, 2019, there were no subordinated liabilities to the claims of general creditors. Accordingly, a statement of changes in liabilities subordinated to claims of general creditors has not been included in these financial statements. # **NOTE 7 -Recent Accounting Pronouncements** Upon commencing operations, the Company adopted ASU No. 2014-09, Revenue from Contracts with Customers (Topic 606). Revenue from contracts with customers includes fees from investment banking services. The recognition and measurement of revenue is based on the assessment of individual contract terms. Significant judgment is required to determine whether performance obligations are satisfied at a point in time or over time; how to allocate transaction prices where multiple performance obligations are identified; when to recognize revenue based on the appropriate measure of the Company's progress under the contract; and whether constraints on variable consideration should be applied due to uncertain future events. Other recently issued accounting standards that have been issued or proposed by the FASB or other standards-setting bodies are not expected to have a material impact on the Company's financial position or results of operations. The Company plans to adopt any new standards in accordance with the standards. # **NOTE 8 - SIPC Supplemental Reporting** The Company is exempt from the filing of the SIPC Supplemental Report as net operating revenues are less than \$500,000. # **NOTE 9 -Commitments and Contingencies** The Company had no commitments or contingencies that were required to be accrued or disclosed. # **NOTE 10 -Subsequent Events** Subsequent events have been evaluated for potential recognition and disclosure through February 25, 2020, which represents the date the financial statements were available for issuance. {12}------------------------------------------------ **Supplemental Information Pursuant to Rule 17a-5 of the Securities Exchange Act of 1934 as of** **December 31, 2019** {13}------------------------------------------------ # **Schedule I** # **SPEYSIDE ADVISORS, LLC Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission As of December 31, 2019** | Computation
of
Net
Capital | | |----------------------------------------------------------------------------------------------------------------------------|--------------| | Total
member
capital
for
capital
qualified
net | \$
78,567 | | Deductions
and/or
charges
Non-allowable
assets: | | | Accounts
receivable | (20,419) | | Other
assets | (1,686) | | capital
before
haircuts
securities
Net
on
positions | 56,462 | | Net
Capital | \$
56,462 | | Aggregate
indebtedness | | | Items
included
statement
of
financial
condition:
in
Accounts
payable
and
accrued
expenses | | | indebtedness
Total
aggregate | \$ | See accompanying report of independent registered public accounting firm. {14}------------------------------------------------ # **Schedule I (continued)** # **SPEYSIDE ADVISORS, LLC Computation of Net Capital Under Rule 15c3-l of the Securities and Exchange Commission As of December 31, 2019** # **Computation of Basic Net Capital Requirement** | Minimum
net
capital
required | | | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|----------------| | (6
2/3%
of
aggregate
indebtedness) | S | | | Minimum
dollar
Net
Capital
Requirement
of
Reporting
or
Dealer
Broker | \$ | 5,000 | | Minimum
Capital
Requirement
Net | \$ | 5,000 | | of
Net
Capital
Excess
Minimum
Requirement
in | \$ | 51,462 | | 10%
capital
less
greater
of
net
capital
less
greater
of
of
Net
aggregate
or
capital
indebtedness
120%
of
minimum
net | \$ | 50,462 | | Indebtedness
Ratio
of
Aggregate
to
Net
Capital | | 0.0
to
1 | No material differences existed between the audited computation of net capital pursuant to Rule 15c3-1 as of December 31, 2019 and the corresponding unaudited fding of part IIA of the FOCUS Report/Form X-17A-5 filed by Speyside Advisors, FFC See accompanying report of independent registered public accounting firm. {15}------------------------------------------------ ### **Schedule II** # **SPEYSIDE ADVISORS, LLC Computation for Determination of Reserve Requirements Under Rule 15c3-3 of the Securities and Exchange Commission As of December 31, 2019** ### **EXEMPTIVE PROVISIONS** The Company operates under the provisions of Paragraph (k)(2)(i) of Rule 15c3-3 of the SEC and, accordingly, is exempt from the remaining provisions of the Rule. Essentially, the requirements of Paragraph (k)(2)(i) provide that the Company will not hold customer funds or safe keep customer securities. Under these exemptive provisions, the Computation for Determination of Reserve Requirements is not required. See accompanying report of independent registered public accounting firm. {16}------------------------------------------------ Report of Independent Registered Public Accounting Firm On Management's Exemption Report Required by SEC Rule 17a-5 Year Ended December 31, 2019 {17}------------------------------------------------ ![](_page_17_Picture_0.jpeg) ## **REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM** #### **To the Managing Member of Speyside Advisors, LLC** Certified Public Accountants We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Speyside Advisors, LLC identified the following provisions of 17 C.F.R. §15c3-3(k) under which Speyside Advisors, LLC claimed an exemption from 17 C.F.R. §240.15c3-3: (2)(i) (the "exemption provisions") and (2) Speyside Advisors, LLC stated that Speyside Advisors, LLC met the identified exemption provisions throughout the most recent fiscal year, December 31, 2019, without exception. Speyside Advisors, 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 Speyside Advisors, 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 on the provisions set forth in paragraph (k)(2)(i) of Rule 15c3-3 under the Securities Exchange Act of 1934. **McBee & Co., PC** Dallas,Texas February 25, 2020 {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) #### **BROKER-DEALER ANNUAL EXEMPTION REPORT** #### **DECEMBER 31, 2019** Speyside Advisors, LLC, (the company) is responsible for complying with 17 C.F.R. §240.17a-5, "Reports to be made by certain brokers and dealers" and complying with 17 C.F.R. §240. l 5c3-3: (k)(2)(i) (the "exemption provisions"). We have performed an evaluation of the Company's compliance with the requirements of 17 C.F.R. §240.17a-5 and the exemption provisions. Based on this evaluation, we assert the following: - ( 1 ) Speyside Advisors, LLC identified the following provisions of 17 C.F.R. §15c3-3 under which the Company claimed an exemption from 17 C.F.R. §240.15c3-3: (k)(2)(i) (the "exemption provisions") and - (2) Speyside Advisors, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. I, Daniel Gillett, swear (or affirm) that, to my best knowledge and belief, this Exemption Report is true and correct. By: Daniel Gil/ett *SC* Member February 25, 2020 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.