# SPOKE REAL ESTATE FINANCIAL, LLC X-17A-5 (2024-02-23) — Broker-dealer annual report - Company: SPOKE REAL ESTATE FINANCIAL, LLC - Form: X-17A-5 - Filed: 2024-02-23 - Period: 2023-12-31 - Accession: 0001783311-24-000002 - CIK: 1783311 - File #: 8-70381 - Type: Broker-dealer - Material weakness: No - Auditor: Weisberg, Mole', Krantz & Goldfarb, LLP - Auditor location: Woodbury, NY - Contact: Michael Levin - Phone: 614 296 3587 - Email: mlevin@spokerecap.com - Website: spokerecap.com - Signed by: Michael levin (Chief Executive Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1783311/000178331124000002/spokeaudit.pdf --- {0}------------------------------------------------ # SPOKE REAL ESTATE FINANCIAL, LLC FINANCIAL STATEMENTS AND SUPPLEMENTARY INFORMATION DECEMBER 31, 2023 {1}------------------------------------------------ #### UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 OMB APPROVAL OMB Number: 3235-0123 Expires: Nov. 30, 2026 Estimated average burden hours per response: 12 ## ANNUAL REPORTS FORM X-17A-5 PART III sec file number 8-70381 FACING PAGE Information Required Pursuant to Rules 17a-5, 17a-12, and 18a-7 under the Securities Exchange Act of 1934 AND ENDING\_12/31/2023 filing for the period beginning 01/01/2023 MM/DD/YY MM/DD/YY A. REGISTRANT IDENTIFICATION ## NAME OF FIRM: Spoke Real Estate Financial, LLC TYPE OF REGISTRANT (check all applicable boxes): 匡 Broker-dealer □ Check here if respondent is also an OTC derivatives dealer ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use a P.O. box no.) ## 161 South Parkview | | (No. and Street) | | | | | | |---------------------------------------------------------------------------|--------------------------------|---------|-----------------------|--|--|--| | Columbus | он | | 43209 | | | | | (City) | (State) | | (Zip Code) | | | | | PERSON TO CONTACT WITH REGARD TO THIS FILING | | | | | | | | Michael Levin
614 296 3587 | | | mlevin@spokerecap.com | | | | | (Name) | (Area Code - Telephone Number) | | (Email Address) | | | | | B. Accountant Identification | | | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose reports are contained in this filing* | | | | | | | | Weisberg, Mole', Krantz & Goldfarb, LLP | | | | | | | | (Name - if individual, state last, first, and middle name) | | | | | | | | 185 Crossways Park Drive Woodbury | | NY | 11797 | | | | | (Address) | (City) | (State) | (Zip Code) | | | | | 12-14-2004 | | 2107 | | | | | (Date of Registration with PCAOB)(if applicable) (PCAOB Registration Number, if applicable) FOR OFFICIAL USE ONLY \* Claims for exemption from the requirement that the annual reports of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis of the exemption. See 17 CFR 240.17a-5(e)(1)(ii), if applicable. Persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. {2}------------------------------------------------ #### OATH OR AFFIRMATION | Michael Levin | | | . swear (or affirm) that, to the best of my knowledge and belief, the | | |---------------|--|--|--------------------------------------------------------------------------------------------|-------| | | | | financial report pertaining to the firm of Spoke Real Estate Financial, LLC | as or | | 12/31 | | | 2 2023 , is true and correct. I further swear (or affirm) that neither the company nor any | | partner, officer, director, or equivalent person, as the case may be, has any proprietary interest in any account classified solely as that of a customer. ![](_page_2_Picture_3.jpeg) | Signature: | | |------------|--| | Title: | | | colora | | Notary Public #### This filing \*\* contains (check all applicable boxes): - (a) Statement of financial condition. - [ (b) Notes to consolidated statement of financial condition. - | (c) Statement of income (loss) or, if there is other comprehensive income in the period(s) presented, a statement of comprehensive income (as defined in § 210.1-02 of Regulation S-X). - (d) Statement of cash flows. - (e) Statement of changes in stockholders' or partners' or sole proprietor's equity. - [ (f) Statement of changes in liabilities subordinated to claims of creditors. - (g) Notes to consolidated financial statements. - (h) Computation of net capital under 17 CFR 240.15c3-1 or 17 CFR 240.18a-1, as applicable. - [ (i) Computation of tangible net worth under 17 CFR 240.18a-2. - | (j) Computation for determination of customer reserve requirements pursuant to Exhibit A to 17 CFR 240.15c3-3. - □ (k) Computation for determination of security-based swap reserve requirements pursuant to Exhibit B to 17 CFR 240.15c3-3 or Exhibit A to 17 CFR 240.18a-4, as applicable. - [ (I) Computation for Determination of PAB Requirements under Exhibit A to § 240.15c3-3. - | (m) Information relating to possession or control requirements for customers under 17 CFR 240.15c3-3. - □ (n) Information relating to possession or control requirements for security-based swap customers under 17 CFR 240.15c3-3(p)(2) or 17 CFR 240.18a-4, as applicable. - | | | Reconciliations, including appropriate explanations, of the FOCUS Report with computation of net capital or tangible net worth under 17 CFR 240.15c3-1, 17 CFR 240.18a-2, or 17 CFR 240.18a-2, as applicable, and the reserve requirements under 17 CFR 240.15c3-3 or 17 CFR 240.18a-4, as applicable, if material differences exist, or a statement that no material differences exist. - [ (p) Summary of financial data for subsidiaries not consolidated in the statement of financial condition. - (q) Oath or affirmation in accordance with 17 CFR 240.17a-5, 17 CFR 240.17a-12, or 17 CFR 240.18a-7, as applicable. - [r] Compliance report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - (s) Exemption report in accordance with 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - O (t) Independent public accountant's report based on an examination of the statement of financial condition. - | (u) Independent public accountant's report based on an examination of the financial statements under 17 CFR 240.17a-5, 17 CFR 240.18a-7, or 17 CFR 240.17a-12, as applicable. - □ {v} Independent public accountant's report based on an examination of certain statements in the compliance report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - [w] Independent public accountant's report based on a review of the exemption report under 17 CFR 240.17a-5 or 17 CFR 240.18a-7, as applicable. - [] (c) Supplemental reports on applying agreed-upon procedures, in accordance with 17 CFR 240.15c3-1e or 17 CFR 240.17a-12, as applicable. - □ (y) Report describing any material inadequacies found to exist or found to have existed since the date of the previous audit, or a statement that no material inadequacies exist, under 17 CFR 240.17a-12(k). - □ (z) Other: \_ - \*\* To request confidential treatment of certain portions of this filing, see 17 CFR 240.17a-5(e)(3) or 17 CFR 240.18a-7(d)(2), as applicable. {3}------------------------------------------------ ## SPOKE REAL ESTATE FINANCIAL, LLC #### DECEMBER 31, 2023 #### TABLE OF CONTENTS #### Report of Independent Registered Public Accounting Firm | Financial Statements
Page | | |--------------------------------------------------------------------------------------------------|--| | Statement of Financial Condition | | | Statement of Operations | | | Statement of Changes in Member's Equity | | | Statement of Cash Flows | | | Notes to the Financial Statements | | | Supplementary Information | | | I - Computation of Net Capital
Pursuant to Rule 15c3-1 | | | Other Information | | | II - Computation for Determination of the Reserve Requirements
Pursuant to Rule 15.3-3. | | | III - Information Relating to the Possession or Control Requirements
Pursuant to Rule 15.3-3. | | | Report of Independent Registered Public Accounting Firm | | | Management Statement Regarding Compliance with the Exemption
Provisions of SEC Rule 15-3-3 | | {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) #### Weisberg, Molé, Krantz & Goldfarb, LLP Certified Public Accountants #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Managing Member of Spoke Real Estate Financial, LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition of Spoke Real Estate Financial, LLC (the "Company") as of December 31, 2023, and the related statements of operations, changes in member's equity, and cash flows for then ended and the related notes and schedules (collectively referred to as the "financial statements"). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2023, and the results of its operations and its cash flows for 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 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 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 everall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. #### Supplemental Information The supplemental information (Schedule I - Computation of Net Capital Pursuant to Uniform Net Capital Rule 15c3-1 of the Securities and Exchange Commission and Schedule II and III - Statement Regarding Rule 15c3-3 of the Securities and Exchange Commission) (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 Company's management. Our audit procedures included determining whether the supplemental information 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 including its form and content, is presented in conformity with 17 C.F.R. §240.17a-5. In our opinion, the supplementary 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 2024. Woodbury, New York February 15, 2024 > 185 Crossways Park Drive, Woodbury, NY 11797 · Phone: 516-933-3800 · Fax: 516-933-1060 700 Kinderkamack Rd, Oradell, New Jersey 07649 · Phone: 201-655-6249 · Fax: 201-655-6098 www.weisbergmole.com {5}------------------------------------------------ #### SPOKE REAL ESTATE FINANCIAL, LLC STATEMENT OF FINANCIAL CONDITION DECEMBER 31, 2023 #### ASSETS | Cash
Prepaid expenses | ಕ್ಕಿ | 58,482
8,333 | |------------------------------------------------------|------|-----------------| | Total assets | ಕಾ | 66,815 | | LIABILITIES AND MEMBER'S EQUITY | | | | Liabilities:
Accounts Payable
Due to affiliate | ಕ್ಕಿ | 1,210
13,619 | | Total liabilities | | 14,829 | | Member's equity | | 51,986 | | Total liabilities and member's equity | ക്ക | 66,815 | The accompanying notes are an integral part of these financial statements {6}------------------------------------------------ #### SPOKE REAL ESTATE FINANCIAL, LLC STATEMENT OF OPERATIONS FOR THE YEAR ENDED DECEMBER 31, 2023 | Revenues: | | | |--------------------------|----|----------| | Fee income | ಕಿ | 107,901 | | Total income | | 107,901 | | Expenses: | | | | Professional fees | ക | 111,927 | | Expense sharing expenses | | 54,477 | | Regulatory fees | | 7,190 | | Communications | | 1,443 | | Office expense | | 35 | | Other expenses | | 4,445 | | Total expenses | | 179,517 | | Net loss | S | (71,616) | The accompanying notes are an integral part of these financial statements {7}------------------------------------------------ #### SPOKE REAL ESTATE FINANCIAL, LLC STATEMENT OF CHANGES IN MEMBER'S EQUITY FOR THE YEAR ENDED DECEMBER 31, 2023 | Member's equity - January 1, 2023 | S | 123,602 | |-------------------------------------|---|----------| | Net loss | | (71,616) | | Member's equity - December 31, 2023 | | 51,986 | The accompanying notes are an integral part of these financial statements {8}------------------------------------------------ #### SPOKE REAL ESTATE FINANCIAL, LLC STATEMENT OF CASH FLOWS FOR THE YEAR ENDED DECEMBER 31, 2023 | Cash flows from operating activities: | | | |---------------------------------------------|---|-----------| | Net loss | | (71,616) | | Changes in operating assets and liabilities | | | | Prepaid expenses | | (1,395 | | Accounts payable | | (47,065) | | Due to affliate | | 10,501 | | Net cash used in operating activities | | (109,575 | | Net decrease in cash | | (109,575) | | Cash, beginning of period | | 168,057 | | Cash, end of period | S | 58,482 | {9}------------------------------------------------ #### 1. ORGANIZATION AND DESCRIPTION OF BUSINESS Spoke Real Estate Financial, LLC (the "Company"), a Delaware Corporation was established on May 13, 2019 and is a wholly owned subsidiary of Spoke Real Estate Enterprises LLC (the "Parent"). The Company is a registered broker-dealer with the Securities and Exchange Commission (the "SEC") and is a member of the Financial Industry Regulatory Authority, Inc. ("FINRA"), as of October 15, 2019. The Company acts as a private placement agent for real estate investment syndications that are structured as direct participation programs. The Company works with investment offerings that are structured and managed by one of its affiliates, Spoke Management LLC. A separate limited liability company is formed for each investment opportunity and controlled by Spoke Management LLC. The syndications are sold pursuant to the private placement exemption under Section 4(a)(2) of the Securities Act and Rule 506 of Regulation D. All transactions are effected through a subscription document on an agency basis and funds are held in a bank escrow account. #### 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES #### Basis of presentation The accompanying financial statements of the Company have been prepared in accordance with accounting principles generally accepted in the United States of America ("U.S. GAAP"). #### 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 financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. #### Revenue recognition In accordance with ASU No. 2014-09, "Revenue from Contracts with Customers" ("ASC Topic 606") revenues from contracts with customers is recognized when, or as, the Company satisfies its performance obligations by transferring the promised services to the customers. A service is transferred to a customer when, or as, the customer obtains control of that service. A performance obligation may be satisfied at a point in time or over time. Revenue from a performance obligation satisfied at a point in time is recognized at the point in time that the Company determines the customer obtains control over the promised service. Revenue from a performance obligation satisfied over time is recognized by measuring the Company's progress in satisfying the performance obligation in a manner that depicts the transfer of the services to the customer. {10}------------------------------------------------ #### 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (continued) The amount of revenue recognized reflects the consideration the Company expects to receive in exchange for those promised services (i.e., the "transaction price"). In determining the transaction price, the Company considers multiple factors, including the effects of variable consideration, if any. This amount is disclosed in each Private Placement Memorandum. Revenue is recognized at a point in time once the contingency is removed and the transaction is closed. ## Cash and Cash equivalents For purposes of the statement of cash flows, the company considers all highly liquid debt instruments purchased with an original maturity of three months or less to be cash equivalents. All of the company's cash is held at Citibank N.A. #### Uncertain tax positions The Company applies the provisions of ASC 740 "Income Taxes" as they relate to uncertain tax positions. The Company was not required to recognize any amounts from uncertain tax positions as of December 31, 2023. The Company's conclusions regarding uncertain tax positions may be subject to review and adjustment at a later date based upon ongoing analyses of tax laws, regulations and interpretations thereof as well as other factors. In the event that tax authorities assess interest and penalties on unrecognized tax benefits, the Company will reflect such amounts in tax expense and income taxes payable. ## 3. CONCENTRATION OF CREDIT RISK The Company's cash deposits are held by one financial institution and therefore, are subject to credit risk to the extent those balances exceeded the Federal Deposit Insurance Corporation ("FDIC") insurance limit of \$250,000. The Company has not experienced any losses in such accounts and does not believe it is exposed to any significant credit risk on cash. At times throughout the year the company may hold balances in excess of federally insured limits. ## 4. RELATED PARTY TRANSACTIONS The Company earns all revenue from investment syndications with related party affiliates. Pursuant to an expense sharing agreement, the Company reimburses the Parent for allocated administration fees, office space, insurance and other services. These expenses were paid for by the Parent. These charges are updated periodically, and determined based on percentages of personnel time and other factors. For the year ended December 31, 2023, the Parent charged the Company \$54,477 for such expenses. At December 31, 2023 the company owed the parent \$13,619. {11}------------------------------------------------ #### 5. NET CAPITAL REQUIREMENTS The Company is subject to the uniform net capital requirements of Rule 15c3-1 ("The Rule") of the Securities and Exchange Act, as amended, which requires the Company to maintain, at all times, sufficient liquid assets to cover indebtedness. In accordance with the Rule, the Company is required to maintain defined minimum net capital of the greater of \$5,000 or 6 2/3 % of aggregate indebtedness. At December 31, 2023, the Company had net capital, as defined, of \$43,653, which exceeded the required minimum net capital of \$5,000 by \$38,653. Aggregate indebtedness at December 31, 2023 totaled \$14,829. The Company's percentage of aggregate indebtedness to net capital was 33.97%. #### 6. SUBSEQUENT EVENTS Management of the Company has evaluated events and transactions that have occurred through February 15, 2024, the date the financial statements are available to be issued, and determined that there are no material events that would require disclosures in the Company's financial statements. {12}------------------------------------------------ # SPOKE REAL ESTATE FINANCIAL, LLC ## SUPPLEMENTARY INFORMATION DECEMBER 31, 2023 {13}------------------------------------------------ #### SPOKE REAL ESTATE FINANCIAL, LLC COMPUTATION OF NET CAPITAL PURSUANT TO RULE 15c3-1 OF THE SECURITIES AND EXCHANGE COMMISSION DECEMBER 31, 2023 #### SCHEDULE I: | Total member's equity | ಕಿ | 51,986 | |-----------------------------------------------------------------------------------------------------|------|--------| | Deductions and/or charges: | | | | Prepaid expenses | | 8,333 | | Net capital | ಕಿ | 43,653 | | | | | | Computation of basic net capital requirement:
Minimum net capital requirement, greater of 6 2/3% | | | | of aggregate indebtedness (\$14,829) | ಿನ | 989 | | Statutory minimum net capital required | ക്ക | 5,000 | | Net capital requirement (greater of the minimum calculation or | | | | the statutory amount) | ക | 5,000 | | Excess net capital | ಕಿ | 38,653 | | Net capital less greater of 10% of aggregate indebtedness or 120% of | | | | minimum net capital | ಕ್ಕಿ | 37,653 | | Computation of aggregate indebtedness: | | | | Accounts payable | ಕಿ | 1,210 | | Due to affiliate | | 13,619 | | Aggregate indebtedness | ಕಿ | 14,829 | | Percentage of aggregate indebtedness to net capital | | 33.97% | There were no material differences existing between the above computation and the computation included in the Company's corresponding unaudited Form X-17A-5 Part IIA filing, as of December 31, 2023. Accordingly, no reconciliation is necessary. {14}------------------------------------------------ #### SPOKE REAL ESTATE FINANCIAL, LLC OTHER INFORMATION DECEMBER 31, 2023 #### Schedule II: Computation for Determination of the Reserve Requirements Pursuant to Rule 15c3-3 of the Securities and Exchange Commission: The Company does not claim an exemption from SEA Rule 15c3-3, in reliance on Footnote 74 to SEC Release 34-70073. #### Schedule III: Information Relating to the Possession or Control Requirements Pursuant to Rule 15c3-3 of the Securities and Exchange Commission: The Company does not claim an exemption from SEA Rule 15c3-3, in reliance on Footnote 74 to SEC Release 34-70073 and did not maintain possession or control of any customer funds or securities as of December 31, 2023. {15}------------------------------------------------ # WMKGG ## Weisberg, Molé, Krantz & Goldfarb, LLP Certified Public Accountants #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Managing Member of Spoke Real Estate Financial, LLC We have reviewed management's statements, included in the accompanying Exemption Report, in which (1) Spoke Real Estate Financial, LLC (the Company") does not claim an exemption under 17 C.F.R. § 15c3-3; and (2) the Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240. 17a-5 because the Company limits its business activities exclusively to effecting securities transactions via subscription way basis where funds are payable to the issuer or its agent and to the Company. In addition, 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's management is responsible for compliance with the provisions of footnote 74 and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversite Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about the Company's compliance with the provisions of Footnote 74. 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 by Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240. 17a-5, and related SEC Staff Frequently Asked Questions. Wisher, Jola's Krang a Kelogeno, it Woodbury, New York February 15, 2024 > 185 Crossways Park Drive, Woodbury, NY 11797 · Phone: 516-933-3800 · Fax: 516-933-1060 700 Kinderkamack Rd, Oradell, New Jersey 07649 · Phone: 201-655-6249 · Fax: 201-655-6098 www.weisbergmole.com {16}------------------------------------------------ ## SPOKE REAL ESTATE FINANCIAL, LLC EXEMPTION REPORT DECEMBER 31, 2023 Spoke Real Estate Financial, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Commission (17 C.F.R §240.17a-5, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. §240.17a-5(d)(1) and (4). To the best of its knowledge and belief, the Company states the following: - 1. The Company does not claim an exemption under paragraph (k) of 17 C.F.R. §240.15c3-3 and - 2. The Company is filing this Exemption Report relying on Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. §240.17 a-5, because the Company limits its business activities exclusively to effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and to the Company, 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 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. Spoke Real Estate Financial, LLC I, Michael Levin, affirm that, to the best of my knowledge and belief, this Exemption Report is true and correct. By: CEO/CCO Title: Dated: February 15, 2024 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.