# STELLA PARTNERS LLC X-17A-5 (2021-05-25) — Broker-dealer annual report - Company: STELLA PARTNERS LLC - Form: X-17A-5 - Filed: 2021-05-25 - Period: 2021-03-31 - Accession: 0001750746-21-000002 - CIK: 1750746 - File #: 8-70196 - Material weakness: No - Auditor: DeMarco Sciaccotta Wilkens & Dunleavy, LLP - Auditor location: Tinley Park, IL - Contact: John Simpson - Phone: 312-493-9242 - Signed by: John Simpson (CEO) Original filing: https://www.sec.gov/Archives/edgar/data/1750746/000175074621000002/sp.pdf --- {0}------------------------------------------------ #### UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: October 31, 2023 Estimated average burden hours per response .... . . 12.00 SEC FILE NUMBER 8-70196 # **ANNUAL AUDITED REPORT FORM X-17A-5 PARTlll** 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 04/01/20 | | AND ENDING 03/31/21
~~~~~~~~~~- | | | |---------------------------------------------------------------------------|--------------------------------------------------------|------------------------------------|--------------------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME OF BROKER-DEALER: Stella Partners LLC | | | OFFICIAL USE ONLY | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | | FIRM l.D. NO. | | | 65 E. Goethe, #7W | | | | | | | (No. and Street) | | | | | Chicago | IL | | 60610 | | | (City) | (State) | | (Zip Code) | | | NAME AND TELEPHONE NUMBER OF PER.SON TO CONTACT IN REGARD TO THIS REPORT | | | | | | John H. Simpson | | | (312) 493-9242 | | | | | | (Area Code - Telephone Number) | | | B. ACCO | UNTANT IDENTIFICATION | | | | | INDEPENDENT PUBLIC ACCOUNT ANT whose opinion is contained in this Report* | | | | | | DeMarco Sciaccotta Wilkens & Dunleavy, LLP | | | | | | | (Name - if individual, state last, first, middle name) | | | | | 9501 W. 171 st Street, H-103 | Tinley Park | IL | 60487 | | | (Address) | (City) | (State) | (Zip Code) | | | CHECK ONE: | | | | | | I./ I
Certified Public Accountant | | | | | | Public Accountant
O | | | | | | D
Accountant not resident in United States or any of its possessions. | | | | | | | | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | *\*Claims for exemption from the requirement th al the annual report be covered by the op in ion 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}------------------------------------------------ L .b""' 5.mii"°" , **, ... ur tot 11fTi,m) Ut .. 1 10 \be \!oel'** ~ **Sf•rt.&...-..;** ~IUi~tnctl e.al\dtup-:io.')nlt: ,lCb.."If Tl .. ~''" • • con·1uu {lh;<.1. all mrr'•W>h!c t..""'1 **0 ta1** ~ae **... • Pa,c-** ·" IZJ tbl \i.tcll'tr.t .. 1 ~ .... ,, •• n'nd111 ~ (<;) **\I.Ater. ttn l(~'"Ir on for n 11 Cod u on **•c)** ~t.ucrr **rnt pf C"h.Jngf'1 UI <;:ou. olden•** l-G~1i) **\l"' f-'an r:tn or \iol< .,.,orncton• Cipt.t.•I** 11 \ll't:en n&llOll of Re .fl'\.t ltcq•ir•rnrrt> Pul'>unt 10 Ru r ISC)· ) I l lnl.:on~u ron Rcl111ng rt> the P\)J""'"" or ( <1n1rol Rtqn-ror~ll l r er Roi< IS-.\· } 0 1 ) A Rec"~· 11..s>on. rd~J,n1 •P>'' >rna:cc•r r "'on ••I l'1tCompV1•l10n d "•U ap I.II l:ndcr Ruic lScl·hrdthc C'o1:1pu:al10n for Df l.;) ~ Rc.on~ilii:ror t-cl\'U:rn:cnts ofhiunc al c ndlll«>ll"' th rtspc• § i ) An 0,111 or Affirm•il"n tll \ ,·op> ol lh< Sf Pl '>•rplcmcnt&l Rcp.:ort en) A repon dc>-rib,o~ '"t nmcnal na.ic~uac cs fJondton 1todo.:ndtollavt"""4 **llCClkdalc** ofllleprcvlwu1acb1 {2}------------------------------------------------ !Financial Statements with Supplemental Information March 31, 2021 {3}------------------------------------------------ #### Contents | Report of Independent Registered Public Accounting Firm | | |---------------------------------------------------------------------------|-----| | Financial Statements | | | Statement of Financial Condition | 2 | | Statement of Operations | 3 | | Statement of Changes in Member's Equity | 4 | | ement of Cash Flows
Stat | 5 | | Notes to Financial Statements | 6-8 | | Supplemental Information | 9 | | ation of Net Capital Pursuant to SEC Rule 15c3-1
ule I-Comput
Sched | 10 | | Report of Independent Registered Public Accounting Firm | 11 | | Exemption Report | 12 | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) ## REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Member of Stella Partners LLC #### **Opinion on the Financial Statements** We have audited the accompanying statement of financial condition of Stella Partners LLC (the "Company") as of March 31, 2021, and 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 Stella Partners LLC as of March 31, 2021 , 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 responsjbility 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 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. #### **Auditor's Report on Supplemental Information** The information identified in Schedule I (the "supplemental information") 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 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. §240.17 a-5. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as Stella Partners LLC's auditor since 2020. ~~t"'~~fb...ltdal Tinley Park, lllinois May 20, 2021 {5}------------------------------------------------ # Statement of Financial Condition March 31, 2021 | Assets | | | |---------------------------------------|----|-----------| | Cash | \$ | 1,235,958 | | Prepaid expenses and other assets | | 2,137 | | Tota I assets | \$ | 1,238,095 | | | | | | Liabilities and Member's Equity | | | | Accrued expenses | \$ | 28,183 | | Due to officer | | 9,568 | | Total liabilities | | 37,751 | | Member's Equity | | 1,200,344 | | Total liabilities and member's equity | \$ | 1,238,095 | {6}------------------------------------------------ | | Statement of Operations
For the Year Ending
March 31, 2021 | | |----------------------------------------|------------------------------------------------------------------|--| | Revenue | | | | Investment Banking | \$
1,200,000 | | | Interest | 38 | | | Total revenue | 1,200,038 | | | Expenses | | | | Travel | 57,036 | | | Professional fees | 42,581 | | | State registration and fi
ling fees | 4,460 | | | Total expenses | 104,077 | | | Net Income | \$
1,095,961 | | {7}------------------------------------------------ # Statement of Changes in Member's Equity For the Year Ending March 31, 2021 | ng of year
Balance -
beginni | \$
104,383 | |------------------------------------|-----------------| | Net income | 1,095,961 | | end of year
Balance - | \$
1,200,344 | {8}------------------------------------------------ ## **Statement of Cash Flows For the Year Ending March 31, 2021** | Cash Flows from Operating Activities
Net income
Adjustments to reconcile net income to net
cash provided by operating activities | \$
1,095,961 | |-------------------------------------------------------------------------------------------------------------------------------------------|-----------------| | Change in prepaid expenses and other assets | 1 | | Change in accrued expenses | 2,676 | | Change in due to officer | 9,568 | | Net cash provided by operating activities | 1,108,206 | | Net Increase in Cash | 1,108,206 | | Beginning of year
Cash - | 127,752 | | End of year
Cash - | \$
1,235,958 | {9}------------------------------------------------ # Notes to Financial Stateme nts March 31, 2021 # Note **1-** Nature of Business and Summary of Significant Accounting Policies Stella Partners LLC (the "Company") was formed on May 17, 2018 and is organized as a limited liabi lity company pursuant to the Limit ed Liability Company Act of the State of Delaware. There is one member of the Company. The Company was approved as a FINRA/SEC broker-dealer firm on January 11, 2019. As a registered securities brokerdealer, the Company provides investment banking and consulting services to closely held companies throughout the United States. Aspects of the Limited Liability Company - As a limited liability company, the member's liability is limited to the capital invested. Under the operating agreement, the Company has one class of member interest, and the m ember' s interest is in proportion to the number of equity units issued. Allocation of profit, losses, and distributions is in accordance with the terms as defined in t he operating agreement. The Company shall continue in perpetuity unless sooner terminated as defined in the operating agreement. Basis of Accounting - The financial statements are prepared using the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America ("GAAP"). Income Taxes - The Company is treated as a partnership for federal income tax purposes. Consequently, federal income taxes are not payable by, or provided for, the Company. The member is taxed individually on t he Company' s earnings. Accordingly, t he financial statements do not reflect a provision for income taxes. Cash - The Company maintains its cash in a bank account, w hich at times may exceed federally insured limits. The Company has not experienced any losses in such account and believes it is not exposed to any significant credit risk on cash. {10}------------------------------------------------ # **Note 1- Nature of Business and Summary of Significant Accounting Policies (Continued)** **Revenue Recognition** - Revenue from Contracts with Customers Standard (ASU 2014-09) core principle is that an entity should recognize revenue when it transfers promised goods or services to customers in an amount t hat reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. ASU 2014-09 prescribes a five-step process to accomplish this core principle, including: - Identification of the contract with the customer; - Identification of the performance obligation(s) under the contract; - Determination of transaction price; - Allocation of the transaction price to the identified performance obligation(s); and - Recognition of revenue as (or when) an entity satisfies the identified performance obligation(s). Investment banking revenue includes consulting fees earned from providing merger and acquisition and other advisory services to clients or other broker-dealers. Such revenue is recognized when the performance obligations are satisfied. This normally occurs at closing of t he transaction or as services are completed as specified under the contract. **Accounts Receivable** - Accounts receivable are non-interest bearing uncollateralized obligations receivable in accordance with the terms agreed upon with each customer. The Company regularly reviews its accounts receivable for any uncollectible amounts. The review for uncollectible amounts is based on an analysis of the Company's collection experience, customer credit worthiness, and current economic treads. **Management Estimates** - The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities as of the date of the financial statements and the reported amounts of revenue and expenses during the reporting period. Actual results could differ from those estimates. #### **Note 2** ~ **Uniform Net Capital Rule** The Company is subject to the Securities and Exchange Commission's Uniform Net Capital Rule (SEC 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 to 1. The net capital rule may also effectively restrict the distribution of member's capital. As of March 31, 2021, the Company had net capital of \$1,198,207, of which \$1,193,207 was i n excess of its required net capital of \$5,000. The Company's ratio of aggregate indebtedness to net capital was 0.03 to 1.0. {11}------------------------------------------------ # **Notes to Financial Statements March 31, 2021** #### **Note 3 - Major Customers** During the year ended March 31, 2021, the Company's revenue was attributable to one client. There was no balance owed from this client as of March 31, 2021. #### **Note 4 - Related Party Transactions** The Company operates from the home office of the managing member of the Company under a no cost rent agreement. The managing member does not charge the Company for the home office space or utilities expenses paid by the managing member. #### **Note 5- Contingencies** The Company is subject to litigation in the normal course of business. There was no litigation in progress as of March 31, 2021. #### **Note 6 - Subsequent Events** The Company has evaluated subsequent events through May 20, 2021 the date the financial statements were issued. #### **Note 7 - Economic Risks** In March 2020, the World Health Organization (WHO) declared COVID-19 a global pandemic. This pandemic event has resulted in significant business disruption and uncertainty in both global and U.S. markets. While the Company believes that it is in an appropriate position to sustain the potential short-term effects of these world-wide events, the direct and long-term impact to the Company and its financial statements is undetermined at this time. {12}------------------------------------------------ Supplemental Information {13}------------------------------------------------ | Ratio of Aggregate Indebtedness to Net Capital | 0.03 to 1.0 | |---------------------------------------------------|-----------------| | Aggregate Indebtedness | \$
37,751 | | Excess net capital | \$
1,193,207 | | Net Capital Requirement | 5,000 | | Net capital | 1,198,207 | | Haircuts | | | Net capital before haircuts | 1,198,207 | | Deductions and/or Charges
Non-allowable assets | 2,137 | | Total Member's Equity | \$
1,200,344 | | | | Schedule I - Computation of Net Capital Pursuant to SEC Rule 15c3-1 March 31, 2021 There were no material differences between the audited computation of net capital in this report and the Company's unaudited corresponding schedule FOCUS Part llA of Form X-17A 5 as of March 31, 2021. {14}------------------------------------------------ May 20, 2021 To Whom It May Concern: We, as members of management of Stella Partners LLC (the "Company "), are responsible for complying with Rule 17a-5, "Reports to be made by certain brokers and dealers". We have performed an evaluation of the Company's compl iance with the requirements of Rule 17a-5 and the exemption provisions in Rule 15c3-3(k) (the "exemption provisions ") and of t he 2013 Release adopting amendments to Rule 17a-5, including Footnote 74 of the 2013 Release. We have determined that the Company does not meet any of the exemption conditions of paragraph (k) of Rule 15c3-3 (i.e., paragraph (k)(1 ), (k)(2)(i) or (k)(2)(ii)) but also (1) does 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 Exchange Act Rule 15c2-4 ("Rule 15c2-4"); (2) does not carry accounts of or for customers; and (3) does not carry PAB accounts (as defined in Rule 15c3-3) and therefore is covered by Footnote 74 of the 2013 Release. Accordingly, based on our evaluation we make the following statements to the best knowledge and belief of the Company: - 1. We reviewed the provi sions of Rule §15c3-3 and related guidance stated in the SEC Staffs FAQ and confirmed that the Company relied on Footnote 74 of the 2013 Release. - 2. The Company conducted business activities involving merger and acquisition advisory services activity throughout the year ended March 31, 2021 without exception. - 3. The Company met the identified conditions for such reliance throughout the period April 1, 2020 through March 31, 2021 without exception. Signed: cr- tf. .Ji-~ ----- Name: John H. Simpson Title: CEO {15}------------------------------------------------ ![](_page_15_Picture_0.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Member of Stella Partners LLC We have reviewed management's statements, included in the accompanying exemption report, in which (1) Stella Partners LLC claimed it may file an exemption report because it had no obligations under 17 CFR section 240. l 5c3-3 and (2) Stella Partners LLC, as a non-covered firm, met the provisions of footnote 74 of the Securities and Exchange Commission Release No. 34-70073 throughout the most recent year ended ended March 31, 2021 without exception. Stella Partners 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 Stella Partners LLC's compliance with the exemption provisions for a non-covered firm. 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 Lhem to be fairly stated, in all material respects, based on Lhe provisions set forth by the Securities and Exchange Commission. ~~tr.<~ t;;ft~,.~j~ltd al Tinley Park, Illinois May20, 2021 {16}------------------------------------------------ ![](_page_16_Picture_0.jpeg) #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM ON APPL YING AGREED UPON PROCEDURES Member of Stella Partners LLC We have performed the procedures included in Rule 17a-5(e)(4) under the Securities Exchange Act of 1934 and in the Securities Investor Protection Corporation (SIPC) Series 600 Rules, which are enumerated below and were agreed to by Stella Partners LLC and the SIPC, solely to assist you and SIPC in evaluating Stella Partners LLC's compliance with the applicable instructions of the General Assessment Reconciliation (Form SIPC-7) for the year ended March 31, 2021. Stella Partners LLC's management is responsible for its Form STPC-7 and for its compliance with those requirements. This agreed-upon procedures engagement was conducted in accordance with standards established by the Public Company Accounting Oversight Board (United States) and in accordance with attestation standards established by the American Institute of Certified Public Accountants. The sufficiency of these procedures is solely the responsibility of those parties specified in this report. Consequently, we make no representation regarding the sufficiency of the procedures described below either for the purpose for which this report has been requested or for any other purpose. The procedures we performed and our findings are as follows: - I) Compared the listed assessment payments in Form SIPC-7 with respective cash disbursement records entries noting no differences; - 2) Compared the Total Revenue amounts reported on the Annual Audited Report Form X-l 7A-5 Part III for the year ended March 31, 2021 with the Total Revenue amounts reported in Fonn SIPC-7 for the year ended March 31, 2021, noting no differences; - 3) Compared any adjustments reported in Form SIPC-7 with supporting schedules and working papers noting no differences; - 4) Recalculated the arithmetical accuracy of the calculations reflected in Form SIPC-7 and in the related schedules and working papers supporting the adjustments noting no differences; and - 5) Compared the amount of any overpayment applied to the current assessment with the Form SIPC-7 on which it was originally computed noting no differences. We were not engaged to and did not conduct an examination or review, the objective of which would be the expression of an opinion or conclusion, respectively, on Stella Partners LLC's compliance with the applicable instructions. of the Form SIPC-7 for the year ended March 31, 2021. Accordingly, we do not express such an opinion or conclusion. Had we performed additional procedures, other matters might have come to our attention that would have been reported to you. This report is intended solely for the information and use of Stella Partners LLC and the SIPC and is not intended to be and should not be used by anyone other than these specified parties. ~~.<"~ ~f *b.,,,.lt'd* al Tinley Park, Illinois May 20, 2021 {17}------------------------------------------------ ### STELLA PARTNERS LLC DETERMINATION OF "SIPC NET OPERA TING REVENUES" AND GENERAL ASSESSMENT FOR THE YEAR ENDED MARCH 3 I , 202 I #### SCHEDULE OF ASSESSMENT PAYMENTS | General Assessment | | \$
1,800 | |-------------------------------|-------------------------------------------|-------------| | Less Payments Made: | | | | Date Paid | Amount | | | | \$ | \$ | | Interest on late payments(s) | | | | | Total Assessment Balance and Interest Due | \$
L800 | | Payment made with Form SIPC 7 | | \$
1,aoo | {18}------------------------------------------------ #### STELLA PARTNERS LLC DETERMINATION OF "SIPC NET OPERA TING REVENUES" AND GENERAL ASSESSMENT FOR THE YEAR ENDED MARCH 3 I, 202 I | Total Revenue | 1,200,037
\$ | |-----------------------------|-----------------| | | | | | | | SIPC NET OPERATING REVENUES | 1,200,037
\$ | | GENERAL ASSESSMENT @ .0015 | 1,800
\$ | {19}------------------------------------------------ | SIPC-7 | | |----------------|--| | (36-REV 12/18) | | #### SECURITIES INVESTOR PROTECTION CORPORATION P.O. Box 92185 Washington, D.C. 20090-2185 202-371-8300 General Assessment Reconciliation **SIPC-7** (36-RIEV 12/18) For the fiscal year ended ~~~~!21 \_\_\_\_\_\_\_ \_ (Read carefully the instructions in your Working Copy before completing this Form) ### TO BE FILED BY ALL SIPC MEMBERS WITH FISCAL YEAR ENDINGS 1. Name of Member, address, Designated Exam ining Authority , 1934 Act registration no. and month in which fiscal year ends for purposes of the audit requ irement of SEC Rule 17a-5: | | lo70196
Stella Partners LLC
65 E. Goethe, #7
Chicago, IL 60610 | Note: If any of the information shown on the
mailing label requires correction, please e-mail
any corrections to form@sipc.org and so
indicate on the form filed.
Name and telephone number of person to
contact respecting this form . | |-------|--------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | | _J
L | Rick Alvarez (770) 263-7300 | | 2. A. | General Assessment (item 2e from page 2) | \$1,800 | | B. | Less payment made with SIPC-6 filed (exclude interest) | | | | Date Paid | | | | C. Less prior overpayment applied | | | | D. Assessment balance due or (overpayment) | 1,800 | | E. | Interest computed on late payment (see instruction E) for _____ days at 20% per annum | 0 | | | F. Total assessment balance and interest due (or overpayment carried forward) | \$ 1,800 | | | G. PAYMENT:
-/ the box
Check mailed to P.O. BoxD Funds WiredD
Total (must be same as F above) | | | | H. Overpayment carried forward | | | | | | 3. Subsidiaries (S) and predecessors (P) included in this form (give name and 1934 Act registrat ion number): | The SIPC member submitting this form and the
person by whom it is executed represent thereby
that all information co ntained herein is true, correct | Stella Partners LLC | |------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------| | and com plete. | (Name of Corporation, Partnership or other organization)
~d
ay of_A_p_r_i_· _1
, 20~.
Dated th | CEO | | | (Title) | | ~ Dates:
;: | Postmarked | Received | Reviewed | | |---------------------------------|-------------------------------|----------|--------------------------|--------------------------| | LLI
LLI | > Calculations __
_ | | __
Documentation
_ | ___
Forward Copy
_ | | a::
c:.:> Exceptions:
Q,, | | | | | | | en Disposition of exceptions: | | | | {20}------------------------------------------------ # **DETERMINATION OF "SIPC NET OPERATING REVENUES" AND GENERAL ASSESSMENT** Amounts for the fiscal period beginning \_4\_11\_12\_0 \_\_\_\_ \_ and ending ... 3 ... 13 ..... 11 .... 2..\_1 \_\_\_ \_ | | Item No.
2a. Total revenue (FOCUS Line 12/Part llA Line 9, Code 4030) | Eliminate cents
\$1,200,037 | |--|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------| | | 2b. Additions: | | | | (1) Total revenues from the securities business of subsidiaries (except foreign subsidiaries) and
predecessors not included above. | | | | (2) Net loss from principal lransactions in securities in trading accounts. | | | | (3) Net loss from principal lransactions in commodities in trading accounts. | | | | (4) Interest and dividend expense deducted in determining item 2a. | | | | (5) Net loss from management of or participation in lhe underwriling or distribution of securities. | | | | (6) Expenses other than advertising, printing, registration fees and legal fees deducted in determining net
profit from management of or participation in underwriting or distribution of securities. | | | | (7) Net loss from securities in investment accounts. | | | | Total additions | 0 | | | 2c. Deductions:
(1) Revenues from the distribution of shares of a registered open end investment company or unit
investment trust, from the sa le of variable annu ities, from the business of insurance, from investment
advisory services rendered to registered investment companies or insurance company separat,e
accounts, and from transactions in security futures products. | | | | (2) Revenues from commodity transactions. | | | | (3) Commissions, floor brokerage and clearance paid to other SIPC members in connection with
securities transactions. | | | | (4) Reimbursements for postage in connection with proxy solicitation. | | | | (5) Net gain from securities in investment accounts. | | | | (6) 100% of commissions and markups earned from transactions in (i) certificates of deposit and
(ii) Treasury bills, bankers acceptances or commercial paper that mature nine months or less
from issuance date. | | | | (7) Direct expenses of printing advertising and legal fees incurred in connection with other revenue
related to the securities business (revenue defined by Section 16(9)(L) of the Act). | | | | (8) Other revenue not related either directly or indirectly to the securities business.
(See Instruction C): | | | | (Deductions in excess of \$100,000 require documentation) | | | | (9) (i) Total interest and dividend expense (FOCUS Line 22/PART llA Line 13,
Code 4075 plus line 2b(4) above) but not in excess
__________
\$
_
of total interest and dividend income. | | | | (ii) 40% of margin interest earned on customers securities
accounts (40% of FOCUS line 5, Code 3960). | | | | Enter the greater of line (i) or (ii) | 0 | | | Total deductions | 0 | | | 2d. SIPC Net Operaling Revenues | \$ 1,200,037 | | | 2e. General Assessment @ .0015 | \$ 1,800 | | | | (to page 1, line 2.A.) | Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.